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

Case 3:03-cv—O0556-PCD Document 20 Filed O1/27/2004 Page 1 of 3
UNITED STATES DISTRICT C()URT
DISTRICT OF CONNECTICUT

Plaintiff,
: No. 3:03CV0556 (PCD)
v. :
EMSAR, INC., January 27, 2004
Defendant.
MOTION TO EXTEND SCHEDULING DEADLINES
Pursuant to Rule 7(b) of the Local Rules of Civil Procedure, the Defendant
Emsar, Inc. respectfully requests that the scheduling deadlines previously established by
the Court be extended to provide that discovery shall be completed by February 27,
2004, dispositive motions shall be liled by l\/larch 24, 2004, and if no dispositive motions
are filed, the case shall be ready for trial by April 2, 2004. In support of this motion, the
Defendant represents:
l. The current schedule established by the Court provides that
discovery is to be completed by January 30, 2004, dispositive motions are to be tiled by
February 23, 2004, and absent the filing of dispositive motions, the case is to be ready for
trial by March 5, 2004.
2. Despite diligent efforts, counsel for the Defendant will be unable
to complete discovery in this matter by January 30, 2004. PJO Shancupp previously
ordered that an authorization be provided by the Plaintiff which would allow the
Defendant to obtain records from a non—party witness. The authorization was provided

Case 3:03-cv—O0556-PCD Document 20 Filed O1/27/2004 Page 2 of 3
and sent to the witness, but, to date, despite repeated follow-up inquiry by counsel, the
witness has not made the records available.
3. The parties had agreed that the Plaintiff would be deposed on
January 28, 2004, but the deposition has been postponed due to the anticipated winter
storm.
4. The Defendant represents that all discovery will be completed by
February 27, 2004.
5. The undersigned has spoken to Attorney Andrew Houlding,
representing the Plaintiff, and he joins in the request that this motion be granted.
6. The Defendant previously liled a Motion to Extend Scheduling
Deadlines, and a Revised Motion to Extend Discovery Deadlines
WHEREFORE, the Defendant respectfully requests that this Motion for
Extension be granted.
Respectfully submitted.
DEFENDANT,
EMSA I .
By "r~···~···r·
Conra . ee
CT 16904
Jackson Lewis LLP
177 Broad Street
Stamford, Connecticut 06904-0251
(203) 96] -0404
Email: [email protected]
ITS ATTORNEYS

Case 3:03-ov—O0556-PCD Document 20 Filed O1/27/2004 Page 3 of 3
CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing was sent via regular mail, this
date, to Andrew Iloulding, Esq., Rome MeGuigan Sabanosh, P.C., One State Street, l3th
Floor, Hartford, CT O6lO3—3l0l.
Conrad S. Kgwmu-~~“lMmT_l”Tw*~_i