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

Case 3:03-cv-00945-CFD Document 127 Eiled O2/O1/2005 Page 1 of 3
O O I
I I
I UNITED STATES DISTRICT COURT _
DISTRICT OIT CONNECTICUT
I ZIIIIE FEB rl A IU¤ 30 I
CLARENCE R. COLLINS, JR., et al, 3:03-CV-945 T W ? my
I rams Q , a‘ 2>2 Ir;a%.‘ e§=}.r"“
VS. :
I OLIN CORPORATION, et al,
I Defendants JANUARY 31, 2005
I CONSENTED-TO MOTION TO AMEND SCHEDULING ORDER {
The plaintiffs, 0n consent of defendant Olin Corporation, hereby move the Court to
modify the Scheduling Order in this case, so as to allow them an additional two weeks within
which to file their opposition to Olin’s Motion for Partial Summary Judgment. In support, /
movants state as follows: ,
I. Under the Scheduling Order, as amended, the plaintiffs have until February I,
2005 to file their memorandum and supporting materials in opposition to Olin’s motion.
2. Because of the complexity of the issues raised by Olin’s motion, and, in
particular, because of the number of facts and age of the factual record involved, it has taken
plaintiffs’ counsel longer than anticipated to complete their responsive papers.
3. O1in’s counsel does not object to the extension requested, provided that there is a
corresponding extension of time within which they may file their reply brief in support of the
motion, specifically up to and including March 15, 2005. Olin’s counsel has also advised that
they may require more time to file their reply brief on this motion, because of a trial conflict of
which they were recently made aware.
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i ‘ J` Case 3:03-cv-00945-CFD Document 127 Filed O2/O1/2005 Page 2 of 3 {
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l 4. Thus, as a practical matter, the extension requested by p1aintiffs’ counsel will not
materially delay the resolution of the motion.
5. The remaining deadlines set forth in the Scheduling Order as amended by the
Court on February 2, 2004; May 4, 2004; August 19, 2004; October 25, 2004; and December 16,
2004 shall remain the same.
WHEREFORE, the plaintiffs respectfully request that the Court modify the Scheduling
Order in this case to allow them until February 15, 2005 within which to file their opposition to
Olin Corporation’s Motion for Partial Summary Judgment, and to allow defendant Olin
Corporation until March 15, 2005 within which to file its reply brief in support of the motion.
THE PLA TIFF ,
By i
ark Roberts, sq. Fed Bar t25062)
Andrew Rainer, Es . (Fed Bar #ct25938)
_@[email protected]
McRoberts, Roberts & Rainer, L.L.P.
53 State Street
Boston, Massachusetts 02114
Tele: (617) 722-8222
David B. Zabel, Esq. ct01382 ‘
@,[email protected]
Monte E. Frank, Esq. ctl3666
_n;1ra,111<@cohenandwo1f.con1.
Cohen and Welt] PC
1115 Broad Street
Bridgeport, Comiecticut 06604
Tele: (203) 368-0211
Neil T. Leifer, Esq. ?
@g:[email protected]
Thornton & Naumes L.L.P .
100 Summer Street, 30th Floor
Boston, Massachusetts 02110 I
Tele: (617) 720-1333 Q
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5 ° n Case 3:03-cv-00945-CFD Document 127 Filed O2/O1/2005 Page 3 of 3 {
CERTIFICATION
I This is to certify that on this 31st day of January, 2005, I hereby mailed via first class
` mail a copy of the foregoing to:
5 Michael H. Wetmore, Esq.
i Joel B. Samson, Esq.
I Husch & Eppenberger, LLC
190 Carondelet Plz Ste 600
Saint Louis MO 63105-3433
Sandra K. Davis, Esq.
Mark S. Baldwin, Esq.
Brown Rudnick Berlack Israels LLP
185 Asylum St Pl 38
Hartford CT 06103-3408
Ann M. Catino, Esq.
Joseph Portner, Esq.
Halloran & Sage, LLP
One Goodwin Square
225 Asylum Street
Hartford, CT 06103 ,
Khdrew A. Rainer "‘
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