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

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llllllt APR 22 P 2= 2U
U.S. DISTRICT COURT
UNITED STATES DISTRICT COURT BRIDGEPORT. CONN
I DISTRICT OF CONNECTICUT ` I
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I THOMAS MATYASOVSZKY, on behalf of : I
I himself and all others similarly situated, : CIVIL ACTION NO. .
I Plaintiff, : 3:03 CV 968 (WIG) I
I V. I I
HOUSING AUTHORITY OF THE CITY OF I
BRIDGEPORT et al. : APRIL 22, 2004 ‘
Defendants. : I
PLAINTIFF’S MOTION TO MODIFY SCHEDULING ORDER I
Pursuant to Fed.R.Civ.P. Rule 26 and D.Conn.Loc.R.Civ.P. Rule 7, plaintiff
respectfully moves the Court for an order modifying the Scheduling by extending the I
time for plaintiff to disclose an expert until April 30, 2004 and by modifying all other I
= deadlines accordingly. Counsel for defendants have consented to this proposed I
modification. F
Plaintiff has been delayed in disclosing an expert and expert report by the large I
volume of documents plaintiff` s cotmsel has been required to review to properly present E
plaintiff s case. The discovery process has involved review of approximately 700 tenant I
files, defendant procedure manuals and annual plans, meeting minutes, and many other I
documents. There have also been delays by the BHA in disclosing documents and, in
fact, discovery of documents is still not fully complete.

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{ The proposed extensions, if granted, would modify the following terms in the
\ Scheduling Order: I
i Plaintiffs expert disclosure: April 30, 2004 {
Damages analysis: May 8, 2004 I
Defendant’s deadline to depose plaintiffs expert: June l, 2004
Defendanfs expert disclosure: July 1, 2004
Plaintiffs deadline to depose defendanfs expert: August 1, 2004 {
Discovery completed: August 1, 2004
Dispositive motions: September 1, 2004
Joint Trial Memorandum: December 1, 2004
Trial Ready: January 1, 2005 ¥
Plaintiff has moved this Court to modify the Scheduling Order on three prior l
occasions. I
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{ Respectfully submitted, 4 l
1 PLAINTIF F THOMAS MATYASOVSZKY [
BY
Alan Rosner, Esq. (CT 1041 )
1115 Main Street, Suite 415
Bridgeport, CT 06604
(203) 384-1245, fax 384-1246
Alanr0sner@,a0l.c0m
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N CERTIFICATION I
Q This is to certify that a copy of the foregoing motion has been delivered by
l facsimile (203-357-7915) and by regular mail to Michael Ryan, Esq., and James Mahar,
Esq., Ryan Ryan Johnson & Deluca, LLP, 80 Fourth Street, P.O. Box 3057, Stamford, CT E
06905-3057.
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Alan Rosner [
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