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

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_ Case 3:03-cv—O09@~)DJS Document 21 Filed O1/ZGMSOEIZ Cu Hag} iI’Ic}f’S&lI"\€·· I
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UNITED STATES DISTRICT COU|1II§;imv.·imTD i*_Qi»’Fl`i' ?
DISTRICT OF CONNECTICUT ’ ` ' L [ =
LISA TILUM 1 CIVIL ACTION NO: 3:03 CV973 (DJS)
Plaintiff ; I
vs. Z l
: I
STATE OF CONNECTICUT, : I
DEPARTMENT OF TRANSPORTATION: l
Defendant : JANUARY 16, 2004 I
MOTION FOR MODIFICATION OF SCHEDULING ORDER NUNC PRO TUNC
The Plaintiff in the above-entitled action hereby moves to modify the scheduling
order previously issued in this case for the purpose of extending the deadline for disclosure
of Plaintiffs expert witness on damages from January 16 until January 20, 2004. ln
support of this motion, the undersigned states:
1) On June 23, 2003, Plaintiff filed a First Request for Disclosure and Production
seeking, among otherthings, documents necessary to make a calculation of damages in
. this case. Although Defendant responded to this Request by making said records available
for review on September 25, 2003, and although Plaintiffs counsel on that date identified
documents to be copied in accordance with Defendants instructions, she has only recently
received documents relevant to the issue of damages.
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2) Said information has now been reviewed and compiled by the undersigned, and *
has been reviewed by Plaintiffs expert in order to prepare an expert disclosure and report. I
Biack ANDMQEIEEEILL, P.C.
447 CENTER STREET - MANCHESTER, CT 06040 • (B60)646-5606 - juizis No. 02702

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N · I. Case 3:03-cv—009@JS Document 21 Filed 01/2Q@04 Page 2 of 3
N 3) Plaintiff had previously requested an extension of to disclose her expert until
N January 16, 2004. Due to the unexpected absence ofthe undersigned during this past
N week, counsel has been unable to review data compiled by Plaintiff's expert for the N
N purpose of finalizing her expert report. N
4) The undersigned represents she has attempted to contact Assistant Attorney
N General Steven Courtney, who represents the Defendant in this matter, but has been N
N unable to ascertain his position as to this request, as he is out of his office until January 20,
4 2004. N
N 5) Based on the above, the Defendants will not be prejudiced by the granting of this F
request.
r 6) This is the third motion requesting an extension of this deadline. N
N Wl-ll-EREFORE, the Plaintiff requests that the scheduling order be altered to provide I
as follows:
Plaintiff will designate all trial experts and provide opposing counsel with reports N
from retained experts by January 20, 2004. Z
PLAINTIFF
By: 'llix MN _,_, ` n
4 Beck & Eldergill, P.C.
447 Center Street l
Manchester, CT 06040 E
(860) 646-5606 {
Fed Bar No: ct00024 N
I
l
BECK ANDAVEEDEEEILL, P.C.
447 CENTER Srurartr • Mr\NCHES'l`ER,CT 06040 · (860)646-5606 · jurzrs No. 02702 N
Mini r

l · ` * Case 3:03-cv-OO97@JS Document 21 Filed O1/2@@>04 Page 3 of 3
1 CERTIFICATION
l I hereby certify that a copy of the foregoing has been mailed this 16"‘ day of January
1 2004, to the following parties:
l Stephen J. Courtney
· Assistant Attorney General
\ Attorney GeneraI's Office
. 55 Elm Street .
I i=>.o. BOX 120 l
l Hartford, CT 06141-0120 {
I Kathleen Eidergill
Ti|um\MotExtE> l
BECK AN1l;wl`;1;:;£11.L, P.C.
447 CENTER STREET • MAm<;T1nsTm1, CT 06040 • (B60)6465606 • jums No. 02702 f