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

,1; Case :03-cv-O0?6—PCD Document 16 Filed 12[OS /2003 Page 1 of 2
i J (_
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT gf; I L
rHoMAs1<.vERnoc1<, ; DEC I ill W
Plaint ff,
: No. 3:03CV0556 (PCD)
v. : A
EMSAR, IN ‘., November 26, 2003
Defen ant.
MOTION TO EXTEND SCHEDULING DEADLINES
Pursuant to Rule 7(b) of the Local Rules of Civil Procedure, the Defendant
Emsar, Inc. r pectfully requests that the scheduling deadlines incorporated in the parties' Rule I
26(D report be extended to provide that discovery shall be completed by February 27, 2004,
dispositive m ·tions shall be filed by March 28, 2004, and if no dispositive motions are tiled, the
case shall be ready for trial by April 15, 2004. In support of this motion, the Defendant
represents:
1. The undersigned this day attempted to reach Plaintiffs counsel, Andrew
Houlding. I s unable to reach him, and was thus unable to determine whether he consents or
objects to this otion.
2. The parties each previously requested one extension of time to respond to
the opposing arty‘s interrogatories and requests for production.
3. The current schedule provides that discovery shall be completed by
November 28, 2003, dispositive motions shall be filed by January 15, 2004, and if no dispositive
motions are filed, the case is to be ready for trial by January 30, 2004.

l
tl


l
C Case :03-cv-OOi5f5—PCD Document 16 Filed 12/Ot/2003 Page 2 of 2 ,
· »`k_ _ Q
4. The requested extensions are necessary because Attorney David Powilatis,
who was assi ned to this file, 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. i
WHEREFORE, the Defendant respectfully requests that this Motion for
Extension be ranted.
!
Respectfully submitted.
1
DEFENDANT, _r__,,_ l
sMsAR, inc
l
By
el Green
CT 08746 i
Jackson Lewis LLP l
177 Broad Street H
Stamford, Connecticut 06904-0251
(203) 961-0404 l
[email protected]
ITS ATTORNEYS
E
CERTIFICATION I
THIS S TO CERTIFY that a copy of the foregoing was sent via Federal Express, this {
date, to Andrew Houlding, Esq., Rome McGuigan Sabanosh, P.C., One State Street, 13th Floor,
Hartford, CT 6103-3101. {
l
niel Green
l
l
l
Page 2 I