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

I _ Case 3:03-cv—OO612-RNC_—f)ocument 16 _I§eMd@00E004 l
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i UNITED STATES DISTRICT COURT if if CQMQI }
l DISTRICT OF CONNECTICUT ‘ " " ‘ ‘ ‘ *~‘* *D= U F.
i ROBERT R. CARLSON, ; CIVIL ACTION N0: s;03Cv0612 (RNC)
Plaintiff, : J
VS. ; I
HARTFORD FINANCIAL SERVICES
GROUP, INC. ; I
Defendant. March 5, 2004 {
AGREED-UPoN MOTION FOR EXTENSION OF TIME E
Pursuant to Local Rule 9(b), plaintiff Robert Carlson hereby moves for a two—week
extension of time within which to complete discovery in the above-captioned case. Discovery is
currently scheduled to be completed by March 15, 2004. There has been no previous requrest for
an extension of this deadline.
In support of this Motion, the plaintiff respectfully represents as follows.
A. Plaintiff had subpoenaed a third party witness, his former supervisor who is no longer
employed by the defendant, for a deposition to be held on Monday, March 8. 2004. X
B. Defense counsel has informed the undersigned that the witness is leaving for Colorado
and expects to be away and unavailable next week.
C. Defense counsel has also informed the undersigned that this witness works out of state
several days a week.



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D. In order to accommodate this third party witness and reasonably schedule the deposition, I
additional time will be needed beyond the March 15, 2004 deadline, because two other
witnesses were to follow this witness in the discovery sequence.
1 E. Defense counsel William Anthony has authorized the undersigned to represent that the l
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defendant has no objection to, and supports, this request for an extension of time.
Wherefore plaintiff requests an extension of the discovery deadline through March 29,
2004, an extension of two weeks, to allow for the orderly and reasonable completion of discovery I
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in this case.
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PLAINTIFF, l
ROBERT R. CARLSON
By U. 1
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Fe ar No.: 4976
152 Simsbury Road l
i>.o. Box 451 l
Avon, CT 06001-0451
Tel. (860) 678-7711 ,
CERTIFICATION $
This is to certify that a copy of the foregoing was sent, via tirst class mail, postage
prepaid, this S"` day of March, 2004, to the following counsel of record; }
William J. Anthony, Esq. l
Jackson Lewis LLP i
55 Farmington Avenue, Suite 1200
Hartford, CT 06105
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