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

Case 3:03-cv-00608-AVC

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Filed 11/24/2003

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UNITED STATES DISTRICT COURT for the DISTRICT OF CONNECTICUT __________________________________________ : JOHN P. NAIDEN, : Plaintiff, : : : v. : : : ECOLAB INC. : Defendant. : __________________________________________:

CIVIL NO. 303CV0608 (AVC)

NOVEMBER 24, 2003

MOTION ON CONSENT FOR ENLARGEMENT OF TIME TO FILE REPORT OF PARTIES' PLANNING MEETING

Pursuant to the Federal Rules of Civil Procedure and the Local Rules for this Court, the Defendant, Ecolab Inc., hereby respectfully moves on behalf of both parties for a 10 day enlargement of time, to December 4, 2003, to file the Rule 26(f) Report of Parties' Planning Meeting. In support of this Motion, Defendant states as follows: 1. The current deadline to file the Rule 26(f) report of parties' planning

meeting is November 24, 2003. 2. On November 21, 2003, Plaintiff contacted the undersigned counsel for

Defendant to conduct the parties planning conference via telephone and faxed to the undersigned a proposed report. 3. Due to travel schedules and holidays, the Parties require additional time to

finalize the report and file with the Court. 4. This is the first such Motion filed in this matter.

Case 3:03-cv-00608-AVC

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5.

The pro se Plaintiff consents to this Motion as the Parties agreed in their

telephone conversation on November 21, 2003 that Defendant would file this Motion.

WHEREFORE, Defendant respectfully moves for a 10 day enlargement of time, to December 4, 2003, to file the Rule 26(f) Report of Parties' Planning Meeting.

THE DEFENDANT, ECOLAB INC.

By: Tasos C. Paindiris (ct 16739) Margaret J. Strange (ct 08212) Jackson Lewis LLP 55 Farmington Avenue, Suite 1200 Hartford, CT 06105 Tel. (860) 522-0404 Fax. (860) 247-1330 [email protected]

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Case 3:03-cv-00608-AVC

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CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing was sent by first class mail, postage prepaid, on this 24th day of November, 2003, to the following:

John P. Naiden 66 Route 313 West Arlington, VT 05250

Certified Mail No.

Tasos C. Paindiris

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Case 3:03-cv-00608-AVC

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Filed 11/24/2003

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H:\Client Folder\E\ECOLAB\Naiden\COURT\Pled\Mot Extension Time 26f Report.DOC

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