Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:03-cv-01045-WWE Document 22 Filed 08/12/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WILLIAM LAPUT, ) CIVIL ACTION NO.
)
Plaintiff ) 3:03CV1045 (WWE)
)
v. )
)
LARKIN ENTERPRISES, INC., )
)
Defendant ) AUGUST 11, 2004
SECOND JOINT MOTION TO MODIFY
SCHEDULING ORDER AND DISCOVERY DEADLINE
Plaintiff, William Laput, and Defendant, Larkin Enterprises, Inc. (Larkin), by
and through the undersigned counsel, hereby jointly move that the current scheduling
order and discovery deadline be modified as follows:
1. Discovery shall be completed by October 15, 2004.
2. Dispositive motions shall be filed on or before December 15, 2004.
In support of this Motion, the parties state the following:
1. In accordance with the schedule established in the Form 26(i) Report of
Parties’ Planning Meeting approved and ordered by the Honorable Warren W. Eginton,
Sr., U.S.D.J ., on September 25, 2003, all discovery was to be completed by July 1,
2004 and dispositive motions were to be filed by September 1, 2004.
BE]/32497/2/688840vl
08/10/04-HRD
· 1 .. t.=, ¤ tzwinsw ‘ ll tit'? l-=

) _ Case 3:03-cv—01045-WWE Document 22 Filed 08/12/2004 Page 2 of 3
2. On June 7, 2004, the parties filed a Joint Motion to Modify Scheduling
Order and Discovery Deadlines, which was granted by the Honorable Warren W. Eginton,
Sr., U.S.D.J., on June 9, 2004.
3. Under the modified Scheduling Order, all discovery is to be completed by
September 15, 2004 and dispositive motions are to be tiled by November 15, 2004.
4. Due to a serious illness and death in the family, Defendant’s counsel had to
postpone the depositions of key witnesses.
5. The parties are in the process of rescheduling these depositions and expect
to have them completed by the end of September 2004.
This is the second Joint Motion to Modify Scheduling Order and Discovery
Deadline filed by the parties.
WHEREFORE, the parties respectfully request that this motion be granted.
PLAINTIFF: DEFENDANT:
WILLIAM LAPUT LARKIN ENTERPRISES, INC.
By By ` - ·
i hael E. Satti (ct 01311) Bernard E. Ja es (ct 12293)
Satti, Provatas & McNamara, P.C. Pepe & Hazard LLP
His Attorney Its Attomey
225 State Street, Suite 200 225Asylum Street
New London, CT 06320 Hartford, CT 06103-4302
Telephone N0.: (860) 447-8975 Telephone No.: (860) 522-5175
Fax No.: (860) 447-9136 Fax No.: (860) 522-2796
E-mail; [email protected] E-mail: bj acg uesgadpepehazardcom
2
sm/32497/2/6ssa40vi
os/09/04.uRw
‘ . 1

Case 3:03-cv—01045-WWE Document 22 Filed 08/12/2004 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing has been mailed, postage prepaid,
this llm day of August 2004 to all counsel and parties of record as follows:
Counsel for Plaintiff:
Michael E. Satti
Satti, Provatas & McNamara, PC
225 State Street — Suite 200
New London, CT 06320
72;* ,
Bernard E. Jacques
3
BE1/32497/2/ssssauvi
0S/l0/04»HRT/ i
i i = =<¤r=i; H #2;; ` [-it EQ; ?`?E