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

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Case 3:03-cv-OO55§—PCD Document 17 Filed 12/Q2/2003 Page 1 of 2 1
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1 THOMAS K. vnnnocx, ; ,.;;; 1
Plaintiff, ; 1
: No. 3:03CV0556 (PCD) |
v. : 1
EMSAR, INC., December 1, 2003 1
Defendant.
REVISED MOTION TO EXTEND SCHEDULING DEADLINES 1
Pursuant to Rule 7(b) of the Local Rules of Civil Procedure, the Defendant
Emsar, Inc. respectfully requests that the scheduling deadlines incorporated in the parties' Rule
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26(f) report be extended to provide that discovery shall be completed by February 27, 2004, 1
dispositive motions shall be tiled by March 28, 2004, and if no dispositive motions are filed, the 1
case shall be ready for trial by April 15, 2004. In support of this motion, the Defendant
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represents:
l. This motion is filed to supplement and amend the November 26, 2003
Motion to Extend.
2. The undersigned has spoken to Attorney Andrew Houlding, representing 1
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the Plaintiff, and he has no objection to the granting of this motion. '
3. The parties each previously requested one extension of time to respond to 1
the opposing party's interrogatories and requests for production. 1
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4. The current schedule provides that discovery shall be completed by
November 28, 2003, dispositive motions shall be tiled by January 15, 2004, and if no dispositive
motions are tiled, the case is to be ready for trial by January 30, 2004.
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D r Case 3:03-cv-OO5?6—f’CD Document 17 Filed 12/P2/}2003 Page 2 of 2
i 5. The requested extensions are necessary because Attorney David Powilatis, {
W who was assigned to this tile, accepted an in—house position, and is no longer employed by
; Jackson Lewis, LLP. His departure has delayed discovery and other efforts on this case.
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Y WHEREFORE, the Defendant respectfully requests that this Motion for
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Extension be granted.
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Respectfully submitted. Q
DEFENDANT,
EMSAR, mc. __ I
By M ,... ,
·Dan` reen l
CT 08746
Jackson Lewis LLP
177 Broad Street \
Stamford, Connecticut 06904-0251
(203) 961-0404
[email protected] i
ITS ATTORNEYS

CERTIFICATION
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THIS IS TO CERTIFY that a copy of the foregoing was sent via regular mail, this date,
to Andrew I-Ioulding, Esq., Rome McGuigan Sabanosh, P.C., One State Street, 13th Floor, i
Hartford, CT 06103-310l. I
Green
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