Free Motion to Stay - District Court of Connecticut - Connecticut

Case 3:03-cv-01045-WWE

Document 11

Filed 02/12/2004

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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)

FEBRUARY 10, 2004

MOTION FOR STAY OF DEPOSITIONS The Plaintiff, William Laput, ("Plaintiff Laput") by and through his undersigned counsel, requests that the scheduling of depositions be stayed until March 12, 2004. As good cause for this request, the Plaintiff Laput represents as follows: 1. On February 9, 2004 Plaintiff's counsel Michael Satti underwent a spinal fusion and removal of a cervical disc and will be unable to work for approximately two (2) weeks and is prohibited from driving for one (1) month. 2. As a result of Attorney Satti's surgery and recuperation he is unable to attend

depositions on this matter until approximately March 12, 2004 and the undersigned is attempting to cover both Attorney Satti's and her files in his absence.

ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-01045-WWE

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Filed 02/12/2004

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3. Plaintiff's counsel contacted Bernard Jacques, counsel for the defendant, Larkin Enterprises, Inc., who stated that he consents to the requested stay/postponement of depositions but requested that the Plaintiff Laput file a Motion with the Court. WHEREFORE, for the foregoing reasons the Plaintiff Laput respectfully requests that the scheduling of depositions be postponed/stayed until March 12, 2004 at which time the Plaintiff's counsel should be fully recovered from the aforesaid surgery.

THE PLAINTIFF, WILLIAM LAPUT By:________________________ Holly Quackenbush Darin Michael E. Satti Satti & Satti, P.C. 225 State Street, Suite 200 New London, CT 06320 Juris No. 418059 -His Attorneys-

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Case 3:03-cv-01045-WWE

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Filed 02/12/2004

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CERTIFICATION The undersigned hereby certifies that the foregoing has been sent via facsimile and mailed first class postage prepaid, this 10th day of February 2004 to all counsel as listed below: Bernard E. Jacques Pepe & Hazard, L.L.P. 225 Asylum Street Hartford, CT 16103-4302

___________________ Holly Quackenbush Darin

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