O A T
l
l
H a a
UNITED STATES DISTRICT couariilll lim 20 A mt BI
p1STr
CRYSTAL RESTORATION SERVICES, iNc. ;
Plarnrlrr, ; f
vs. ; pocr
1Nc., T
Defendant. : NOVEMBER 18, 2003
JOINT MOTION TO CONTINUE Evu:>ENT1ARY R
HEARING AND ron LIMITED orscovanv
The plaintiff and defendant jointly move the Court for an order continuing the I
evidentiary hearing presently Scheduled for December 2, 20I until the week of April
26, 2004 for the following reasons:
1. The parties are attempting to determine whether there is a basis for
Settlement.
2. in order to make that determination the parties believe that a meaningful
period of time for determining whether there can be a resolution would include the N
winter months through the end of March 2004. R
l
‘ l
' l
ll T
ggggg ‘ iii‘i
ééri. . .... H _ H __ V r_V_V -
......__,__ ,__g__ i"i`i`
· `· ‘ Case 3:03-cv-005505AWT Document 28 Filed 11/6%2003 Page 2 of 3 \}
l
l
3. This period has been selected by the parties, since it will allow both parties
to have an empirical view of each party’s conduct during a period of intense business
activity.
4. The parties are requesting a hearing at or about the end of April 2004,
consistent with the Court’s schedule, which is approximately 30 days after the test
period so that if there is a necessity for a hearing, the parties can conduct limited
discovery and any appropriate experts can be made aware of the empirical data j
gathered during the winter months by each of the parties. I
5. The parties will advise the Court not later than April 9, 2004 of the necessity _
for such a hearing and whether the case will be or has been settled.
6. The parties also request that limited discovery be conducted by each party
during the months of December through March which will also provide each party with
a meaningful basis for determining whether settlement is possible and what possible
terms would be appropriate in this case.
For these reasons the plaintiff and the defendant have joined in this request for
continuance and for limited discovery as set forth above.
l
i
I
l
l
ll 2 l
~ ' · · Case 3:O3—cv—OO . AWT Document 28 Filed 11 · ,2003 Page 3 of 3
NN 7). 1
1
THE PLAINTIFF, THE BEFENDANT,
B N BY
ANDREW B. BO AN, 6100122 THOMAS J. R Y, 107959
1804 Post Roa East Cowdery, Ecker & Murphy
Westport, CT 06880 750 Main Street N
(203) 259-0599 Hartford, CT 06103-2703
(203) 255-2570 (Fax) (860) 278-5555 N
, (860) 249-0012 (Fax) N
CERTIFICATION N
· N
This is to certify that a copy of the foregoing was mailed, postage prepaid on N
this Z 2 day of November, 2003 to: N
5 Thomas J. Murphy, Esq.
Cowdery, Ecker 8. Murphy
750 Main Street N
Hartford, CT 06103-2703 N
ANDR B. BOWMA N -
NN 3 “
N
United States Free Forms
Canada Free Forms
United Kingdom Free Forms
Australia Free Forms