Free Stipulation - District Court of Connecticut - Connecticut

I Case 3:03-cv-00551-JCH Document 24 Filed 12/23/2003 Page 1 of 3 A
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‘ UNITED STATES DISTRICT COURT V [ [
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DISTRICT OF CONNECTICUT 2 Q " 23 A 6* 50
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CAROL CONNELLY, : 'J A ‘ ‘ I I
Plaintiff, ;
: CIVIL NO. 3:03CV055l(J CH)
IKON OFFICE SOLUTIONS, INC. :
Defendant. : DECEMBER 12, 2003 I
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STIPULATED MOTION FOR ENLARGEMENT OF TIME 5
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Pursuant to the Federal Rules of Civil Procedure and the parties’ discussion with
this Court, plaintiff Carol Connelly and defendant IKON Office Solutions, Inc. join in a request
for enlargement of time. The parties request a ninety (90) day enlargement of time, up to and
iiitzluding March 8, 2004, in which to complete discovery in this matter. The parties further
reiquest a ninety day enlargement of time, up to and including April 8, 2004, in which to file
dispositive motions in this matter. In support of this Motion, the parties state as follows:
1. Pursuant to this Court’s scheduling order, discovery was to have been N
completed by December 1, 2003, and dispositive motions were to have been filed by January 1,
2004. 1
2. On June ll, 2003, after extensive settlement negotiations, the Defendant
believed the parties had reached an agreement in settlement of this matter.
A 3. On July 2, 2003, the Defendant filed a Motion for Enforcement of the
Settlement Agreement.
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Case 3:03-cv-00551-JCH Document 24 Filed 12/23/2003 Page 2 of 3 I
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l 4. On December 5, 2003, Defendant’s Motion for Enforcement of the I
Settlement Agreement was denied by this Court. I
5. The parties now require additional time to investigate this matter. J
WHEREF ORE, the parties respectfully move for a ninety (90) day time
enlargement, up to and including March 8, 2004, in which to complete discovery in this matter.
The parties further request a ninety day enlargement of time, up to and including April 8, 2004,
in which to tile dispositive motions in this matter.
. I THE DEFENDANT, l II
“ IKON OFFICE SOLUTIONS, INC. I
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Byr " Hamm ` <-/“
Marg ge I
Holly . E
Jackson LLP
55 Farmi Avenue, Suite 1200 i
I I Hartford, C 06105
I (860) 522-0404 _
I Juris No. 04067 i
THE PLAINTIFF,
CAROL CONNELLY
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I I By: _ { Q i I
C I thia R. Jenni s / l
The Barrister L ~/ Group / C
211 State Street E
Bridgeport, CT 06604 E
(203) 334-4800 !
Juris No. Q Sc? 7/ l
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Case 3:03-cv-00551-JCH Document 24 Filed 12/23/2003 Page 3 of 3
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CERTIFICATION OF SERVICE /
I This is to certify that a copy ofthe foregoing was sent by first class mail, postage I
prepaid, on this Lggay of December, 2003, to the following counsel of record:
Margaret J. Strange i
Holly L. Cini N
Jackson Lewis LLP I
55 Farmington Avenue, Suite 1200
Hartford, CT 06105 _
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