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

{ ` Case 3:03-cv—00968-WIG Document 28 Filed 1 1/18/2003 Page 1 of 4
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UNITED STATES DISTRICT COURT 1
DISTRICT OF CONNECTICUT
THOMAS MATYASOVSZKY, on behalf of 2
himself and all other persons similarly situated, 1 CIVIL ACTION NO. 1
Plaintiffs, :
p : 3:03-CV-968 (RNC)
V. :
HOUSING AUTHORITY OF THE CITY OF i
BRIDGEPORT, COLLIN VICE, individually and :
in her capacity as Executive Director of the Housing:
X Authority of the City of Bridgeport, and JONAS : NOVEMBER 17, 2003 1
1 DE GUZMAN, individually and in his capacity as : qt; '___
Special Assistant to the Executive Director of the : :3: I
Housing Authority of the City of Bridgeport, : 6-;,;; ·=——·
Defendants. 1 —~—s;1·t fi
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PLAIN'I`IFF’S MOTION TO EXTEND TIME W 1
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Plaintiff Thomas Matyasovszky moves this Court to extend by six weeksczill 1
deadlines in the Rule 26(f`) Report approved by the Court on August 26, 2003. The N
parties have agreed to this extension because they find it unlikely that they will be able to 1
meet the originally proposed deadlines. A deposition started on November I4, 2003 was I
suspended because of a conflict over the interpretation of an asserted privilege. Plaintiff
intends to file a Motion to Compel to seek clarification from the Court, but it may not be K
l possible to obtain this ruling and, if necessary, finish the deposition prior to the original `
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Case 3:03-cv—00968-WIG Document 28 Filed 11/18/2003 Page 2 of 4 1
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date for completing discovery. Plaintiffs will also need additional time to resolve 1
objections by defendants to production requests, and both parties have identified conflicts
that will force them to reschedule the remaining two scheduled deposition dates.
The proposed six week extension, if granted, would result in the following dates:
Change to p.5, V.E.2 & E.3: Discovery completed by May 12, 2004
1 Change to p.6, V.E.4: Depositions completed by January 26, 2004
1 Change to p.6, V.E.6: Plaintiff s expert disclosure by January 26, 2004
Change to p.6, V.E.6: Deposition of plaintiff’ s experts by March 13, 2004 1
Change to p.6, V.E.7: Defendants’expert disclosure by April 13, 2004 1
Change to p.6, V.E.7: Deposition of def`endants’ experts by May 13, 2004
Change to p.6, V.E.8: Damages analysis by March 8, 2004
Change to p.6, V.F: Dispositive motions due by June 4, 2004
1 Change to p.7, V.G: Joint trial memorandum due September 13, 2004 1
1 Change to p.7, VI: Trail ready by October 13, 2004 1
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Case 3:03-cv—00968-WIG Document 28 Filed 11/18/2003 Page 3 of 4 I
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Counsel for all defendants, Michael Ryan of Ryan, Ryan, Johnson & Deluca, I
LLP, consented to the extensions requested herein on November 14, 2003. I
Respectfully submitted,
PLAINTIFF THOMAS MATYASOVSZKY
By *1. [ I
Jennifer kery, Es . I
(ct 24089 ’
1115 Main Street, Suite 415 I
Bridgeport, CT 06604
Tel.(203) 384-1245, Fax. (203) 384-1246 3
Email: [email protected]
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Case 3:03-cv—00968-WIG Document 28 Filed 11/18/2003 Page 4 of 4 |
CERTIFICATION
This is to certify that a copy of the foregoing has been sent by mail on this l7th day of K
November, 2003 to:
_ Michael Ryan, Jeffrey Nagle, and James Mahar
Ryan, Ryan, Johnson & Deluca, LLP
80 Fourth Street, P.O. Box 3057 J
Stamford, cr osaosaosv N
Commigioner o%uperior Court
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