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

Case 3:03-cv-00459-PCD

Document 28

Filed 07/27/2004

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CROSSROADS COMMUNICATIONS OF OLD SAYBROOK, LLC, Plaintiff, VS. TOWER VENTURES, INC., Defendant. : : : : : : : : :

CIVIL NO. 3:03CV459(PCD)

JULY 27, 2004

JOINT MOTION TO MODIFY SCHEDULING ORDER Plaintiff Crossroads Communications of Old Saybrook, LLC ("Crossroads") hereby moves for an extension of time to August 9, 2004 for the service of dispositive motions in this matter. support thereof, plaintiff states as follows: 1. Under the scheduling order currently in place, In

dispositive motions are due to be served on opposing counsel by July 30, 2004. 2. Discovery in this matter was concluded in late June, with Counsel received the

several depositions taken in that time frame.

deposition transcripts shortly before leaving for a vacation during the week of July 12th. 3. Counsel had planned to finalize and file plaintiff's However, much of the week

motion for summary judgment this week.

will be consumed with an ongoing civil investigative demand deposition with lawyers from the Department of Justice, as well as out-of-state counsel. This testimony was originally scheduled to

Case 3:03-cv-00459-PCD

Document 28

Filed 07/27/2004

Page 2 of 4

be completed prior to the undersigned's vacation, but was postponed because of the deponent's illness to the current dates, based on the availability of the respective parties. 4. The rescheduled obligation in the Department of Justice

matter will make it very difficult to complete and serve plaintiff's motion by the current filing deadline. 5. Based on the foregoing, plaintiff respectfully requests

an extension of time to August 9, 2004, for the service of dispositive motions in this matter. 6. Steven Humphrey, Esq., counsel for the defendant, does Because defendant also

not object to the requested extension.

plans to serve a dispositive motion, plaintiff seeks a corresponding extension for the service of motions by the defendant. 7. No prior motions to extend the dispositive motion service The discovery deadline and scheduling order

date have been filed.

has been extended several times, with corresponding modifications to the dispositive motion service date and other pertinent deadlines.

2

Case 3:03-cv-00459-PCD

Document 28

Filed 07/27/2004

Page 3 of 4

WHEREFORE, plaintiff respectfully requests an extension of time to August 9, 2004 for the service of dispositive motions by the parties. THE PLAINTIFF CROSSROADS COMMUNICATIONS OF OLD SAYBROOK, LLC By____________________________________ David T. Grudberg, ct01186 JACOBS, GRUDBERG, BELT & DOW, P.C. 350 Orange St. P.O. Box 606 New Haven, CT 06503 Ph.:(203) 772-3100 Fax:(203) 772-1691 Email: [email protected]

3

Case 3:03-cv-00459-PCD

Document 28

Filed 07/27/2004

Page 4 of 4

CERTIFICATION I hereby certify that a copy of the foregoing was faxed and mailed first class, postage pre-paid, on July 27, 2004 to: Steven R. Humphrey, Esq. Elizabeth R. Leong, Esq. Marion B. Manzo, Esq. Robinson & Cole, LLP 280 Trumbull St. Hartford, CT 06103-3597 ____________________________________ David T. Grudberg

4