Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

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Case 3:03-cv-00979-JCH Document 8 Filed 10/24/2003 Page 1 of 3 _Q I
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I UNITED STATES msriucr comrr I II Ii (
I DISTRICT OF CONNECTICUT I I I 'C`O1' " I `3:' J `
, JESUS ROSA ) CASE NO· ZIIIIJ UCI 2 LI IZ? |?: QQ I
Plaintiff ) 3:03CV979(J CH) I .·;.
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) MOTION ON CONSELNT FOR ` I I I - . '
) EXTENSION OF TIME To ‘ · I Q
V- ) COMPLY WITH RULE 26(f) ‘ I
) AND EXTEND DISCOVERY
HARTE NISSAN, INC. ) DEADLINES I
Defendant ) " - E
) October 22, 2003 _
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Pursuant to Rule 7(b) of the Rules of the United States District Court for the District of
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Connecticut, as amended, the Plaintiff in the above-captioned matter hereby moves for an extension of
time of twenty (20) days from the date hereof, or to and including November 11, 2003, to comply with .
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Fed. R. Civ. P. 26(i) and further moves for an extension of the discovery deadlines in the standing order I
of three (3) months, to and including January 21, 2004. Good cause exists for the granting of this motion _ I
as follows: `I
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l. The instant case was incorrectly entered in Plaintiffs counsel’s tracking system and the I
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deadline to comply with Fed. R. Civ. P. 26(f) (July 30, 2003) was unintentionally missed.
2. The 26(t) Report was faxed to Attorney McGrath for review of even date herewith. , I
3. Due to the length of time which has transpired since the tiling of this suit, Plaintiff further
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moves for an extension of three (3) months, to and including January 21, 2004, to complete discovery. I
4. Attorney McGrath has agreed and consented to this motion for extension of time. W
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_ , Case 3:03-cv—OO9 —JCH Document 8 Filed 10/2} 003 Page 2 of 3 ;
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5. This is the first motion tiled by the undersigned with respect to these time limitations.
PLAINTIFF, Jesus Rosa _
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Daniel S. Blinn ct02l88 _
Sarah Poriss ct:24372 I
Consumer Law Group, LLC I
P. O. Box 1039 2138 Silas Deane Highway I
Rocky nm, or 06067-9997
rei (860) 571-0408 Fax (860) sn-7457 I


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E _ Case 3:03-cv-009(79)-JCH Document 8 Filed 10/2;l/2003 Page 3 of 3 [
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i This is to certify that a copy of the foregoing Motion on Consent for Extension of Time was
mailed, via first class mail, postage prepaid, this 22“d day of October, 2003. `
William J. McGrath, Jr., Esquire I
HALLoRAN & snon LLP l
One Goodwin Square 225 Asylum Street ( l
Hartford, _CT 06103 {\./-—-/
Sarah Poriss
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