Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:03-cv-01045-WWE

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Filed 10/07/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WILLIAM LAPUT, Plaintiff v. LARKIN ENTERPRISES, INC., Defendant ) ) ) ) ) ) ) ) ) CIVIL ACTION NO.: 3:03CV1045 (WWE)

OCTOBER __, 2004

JOINT MOTION FOR RESCHEDULING OF SETTLEMENT CONFERENCE Plaintiff, William Laput, and Defendant, Larkin Enterprises, Inc. (Larkin), by and through the undersigned counsel, hereby jointly move for the rescheduling of the settlement conference before the Honorable H. Fitzsimmons, which is presently scheduled for Friday, October 29, 2004. Presently, discovery is scheduled to close on October 15, 2004. However, plaintiff will be filing a motion to extend discovery and the defendant will not object. Plaintiff will be seeking the extension because plaintiff's counsel is facing surgery and will have medical restrictions on his ability to work. Both parties' counsel believe that mediation is more likely to be successful, and settlement more likely to occur, after discovery closes. Therefore, the parties seek an adjournment of the scheduled settlement

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Case 3:03-cv-01045-WWE

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conference. WHEREFORE, the parties respectfully request that this motion be granted.

PLAINTIFF: WILLIAM LAPUT

DEFENDANT: LARKIN ENTERPRISES, INC.

By____________________________ Michael E. Satti (ct 01311) Satti, Provatas, McNamara, P.C. His Attorney 225 State Street, Suite 200 New London, CT 06320 Telephone No.: (860) 447-8975 Fax No.: (860) 447-9136 E-mail: [email protected]

By____________________________ Bernard E. Jacques (ct 12293) Pepe & Hazard LLP Its Attorney 225Asylum Street Hartford, CT 06103-4302 Telephone No.: (860) 522-5175 Fax No.: (860) 522-2796 E-mail: [email protected]

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Case 3:03-cv-01045-WWE

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Filed 10/07/2004

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CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, this __ day of October 2004 to all counsel and parties of record as follows: Counsel for Defendant: Bernard E. Jacques Pepe & Hazard LLP Goodwin Square 225 Asylum Street Hartford, Connecticut 06103 ____________________________ Michael E. Satti

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