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

Case 3:03-cv-00452-CFD Document 61 Filed 08/16/2007 Page 1 of 4
UNETI.-ED STATES DiSTRICT COURT
DiSTRlCT OF CONNECTICUT
DAVHD RURAN 2 CIVIL ACTION NO.
Plaintiff, : 3:03~CV—00·452—CFD
VS. :
BETH EL TEMPLE OF WEST 2
HARTFORD, SNC. :
Defendant. 2 AUGUST i6, 2007
EMERGENCY MOTION FOR ENLARGEMENT OF SCHEDULTNG ORDER
Pursuant to Federai Ruie of Civil Procedure 16 and Local Rule 7, the
undersigned defendant, Beth EI Temple of West Hartford, Inc., hereby respectfully
moves the Court for good cause shown, for an emergency enlargement of time of the
deadlines in the Courts scheduling order. In support ofthis motion, the undersigned
represents that under the Courts current scheduling order, the following deadlines
currently exist:
(a) Discovery due by Q/15/2007; and
(b) Dispositive motions due by 10/15/07.
On consent ofthe plaintiff, the defendant respectfully requests that this Court
grant an enlargement of time of sixty days for the foregoing deadlines for the completion
of discovery and dispositive motions.
In support ot this rnotion, the defendant represents as foilowsz
1. Aithough numerous motions for extension of time have been sought and
granted in the past with respect to deadlines for discovery and dispositive motions and

Case 3:03-cv-00452-CFD Document 61 Filed 08/16/2007 Page 2 of 4
significant discovery has been conducted to date, the present extension is crucial
because the defense of this matter was transferred tothe undersigned firm oniy four
days ago on Monday, August 13, 2007, We are advised the gredecessor firm, Fitzhugh,
Parker & Alvaro, disbanded as a firm last week. Consequently, the insurance carrier for
the defendant was cornpelied to transfer the fire,
2. The undersigned counsel has not yet obtained the entire file from
previousiy appearing defense counsel, Mark Newcity, and those parts of the file
received to date are voiuminous, consisting of three fuli banker's boxes.
3, The undersigned defense counsel has not yet had an opportunity to digest
the volurnineus discovery materials contained in the file.
4. Plaintiffs counsel has scheduled four depositions to take piace next week,
and has informed the undersigned that the plaintiff intends to ieave for israel on a five
week vacation for the Jewish high holidays beginning of August 24, 2007 and returning
after the current discovery deadline has passed.
5. Although the defendant needs to conduct the deposition ofthe plaintiff, the
undersigned is unabie to do so in accordance with the present deadlines due to the
upcoming schedule of depcsiticns and the piaintiffs unavailabiiity.
6. Additionaily, as indicated in a prior motion, depositions by plaintiffs
counsel, William Madsen, have been delayed as he and his wife were recently involved
in a serious car accident, Attorney Madsen’s wife continues to recover from serious
iniuries sustained in that accident, and, as a result, Attorney Madsen has spent a

Case 3:03-cv-00452-CFD Document 61 Filed 08/16/2007 Page 3 of 4
significant amount of time away from his iaw practice in order to care for his wife and
small children.
7. Due to the fact that the undersigned defense counsel has just taken over
the defense of this matter and that the plaintiff will be unavailable for deposition until
after the discovery deadline has passed, it is imposslbie for the parties to meet the
existing discovery deadlines.
8. Attorney William G. Madsen has consented to the l\/lotion on behalf of the
plaintiff, David Ruran, and both counsel are wiillng to participate in a telephone
conference with the Court if the Court so desires.
WHEREFORE, for all the foregoing reasons, and for good cause shown, the
plaintiff respectfully requests that the Court enlarge certain deadlines as follows:
1. Ail discovery will be compieted by November 14, 2007.
2. Dispositive motions will be filed on or before December 14, 2007
THE DEFEENIDANT,
BETH EL. TEMPLE OF WEST
HARTFORD, il\lC.
By
. oseph tl. drio ·crf/
HALLORA SAGE LLP
Fed Bar #ct26830
One Goodwin Square
225 Asylum Street
Hartford, CT 06103
Its Attorneys
Tel.: (860)522-6103
Fax: (B60)548-0006
email: andrioIa@nalioran—sage.com

Case 3:03-cv-00452-CFD Document 61 Filed 08/16/2007 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on August 16, 2007, a copy of foregoing Notice of
Appearance was filed eiectronicaliy and served by mail on anyone unabie to accept
electronic filing, Notice of this filing will be sent by e—-mail to all parties by operation of
the Court's electronic filing system or by mail to anyone nnabie to accept electronic filing
as indicated on the Notice of Electronic Filing. Parties may access this filing through the
Courts CM/ECP system.
\/Viiliam G. Madsen
Kataiin A. Derriitrus
Madsen, Prestley & Parenteau, LLC
44 Capital Ave., 2"“ Floor E., Suite 201
Hartford, CT 06106
(Attorneys for Piaintiff)
Mark A. Newcity
Fitzhugh, Parker & Alvaro
155 Federal Street
Suite 1700
Boston, MA 02110
(Attorney for Defendant)
Josep . ndriola of
HALLORAN & SAGE LLP
Fed Bar #c1:26830
One Goodwin Square
225 Asyium Street
Hartford, CT 06103
its Attorneys
Tel.: (860)522-6103
Fax: (860)548-—0006
email: anclrioIa@haItoran—sage.com
1026B65_1DOC