Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cv-00560-AWT Document 31 Filed 04/16/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
;
Plaintiff, CIVIL NO. 3:03CV0560 (AWT)
CRYSTAL RESTORATION ENTERPRISES, INC.
Defendant. April 16, 2004
DEFENDANT’S MOTION ON CONSENT
TO CONTINUE EVIDENTIARY HEARING
The defendant Crystal Restoration Enterprises, Inc. ("CREI"), with the consent of the
plaintiff, hereby moves for an order continuing the evidentiary hearing presently scheduled for
April 26, 2004 until a date in September 2004 convenient to the Court’s schedule. In support of
this motion, CREI represents as follows:
l. The parties are continuing to assess whether there is a basis for settlement of this
matter.
2. Counsel for the parties have agreed to conduct limited discovery in advance of any
hearing that may need to be held on the plaintiff' s request for a preliminary injunction. The
parties hope that the completion of that discovery may assist them in resolving this matter.
3. Counsel for the parties believe that this additional period, combined with the
completion of the contemplated discovery, will allow them to determine whether a settlement is
possible, or whether it will be necessary for them to ask the Court to conduct a hearing on the
plaintiff s request for a preliminary injunction.

Case 3:03-cv-00560-AWT Document 31 Filed 04/16/2004 Page 2 of 3
4. Undersigned counsel has conferred with counsel for the plaintiff, Andrew B. Bowman,
Esq., who has authorized undersigned counsel to represent that the plaintiff consents to and joins
in the request described in this motion.
5. This is the parties’ second motion for an extension of time in regard to this deadline.
WHEREFORE, Crystal Restoration Enterprises, Inc., joined by the plaintifi respectfully
requests a continuance of the date for a preliminary injunction hearing until a date in September
2004 convenient to the Court’s calendar.
DEFENDANT,
CRYSTAL RESTORATION
ENTERPRISES, INC.
///r
By: Thomas J. Murp (ct 959
Cowdery, Ecker & Murphy, L.L.C.
750 Main Street
Hartford, CT 06103-2703
(860) 278-5555
(860) 249-0012 Fax
E—mail: [email protected]
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Case 3:03-cv-00560-AWT Document 31 Filed 04/16/2004 Page 3 of 3
CERTIFICATION
I hereby certify that I caused a true copy of the foregoing Defendant’s Motion On Consent
To Continue Evidentiary Hearing to be mailed, postage prepaid, this l6"‘ day of April, 2004, to:
Andrew B. Bowman, Esq.
1804 Post Road East
Westport, CT 06880
Thomas J. Murr;T;y Q ;

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