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

Case 3:03-cv-00452-CFD

Document 58

Filed 07/20/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DAVID RURAN, Plaintiff, V. BETH EL TEMPLE OF WEST HARTFORD, INC., Defendant : : : : : : : : CIVIL ACTION NUMBER 3: 03 CV 452 (CFD)

JULY 20, 2007

JOINT MOTION TO ENLARGE THE SCHEDULING ORDER Pursuant to the Federal Rules of Civil Procedure and Local Rule 9 of this Court, the parties respectfully request an enlargement of time of the scheduling order currently in place In support of this motion, the parties state the following: 1. Pursuant to the current scheduling order, discovery is to be completed by August 10, 2007; and dispositive motions are due by September 10, 2007. 2. Despite the best efforts of the parties, the undersigned counsel do believe that they will be able to complete the contemplated depositions by August 10, 2007. 3. As indicated in a prior motion, Plaintiff's counsel William Madsen and his wife were recently involved in a serious car accident. Attorney Madsen's wife continues to recover from serious injuries sustained in that accident, and as a result Attorney Madsen has spent a significant amount of time away from his law practice in order to care for his wife and small children. 4. Defendant's counsel Mark Newcity will be leaving his current firm and joining another firm on or about August 1, 2007. He is in the process of settling his affairs with his current firm and moving to his new office. As a result, he will have little or no time prior to the discovery deadline to meet with the witnesses who will be deposed and attend their depositions.

Case 3:03-cv-00452-CFD

Document 58

Filed 07/20/2007

Page 2 of 2

5.

In addition, due to the vacation schedules of many of the witnesses, they are not available for a deposition prior to August 10, 2007.

6.

This parties believe that at least seven depositions will be taken and that they will need ample time to take said depositions.

7.

This is the eighth enlargement of time sought by either party in this case.

WHEREFORE, the parties respectfully request an enlargement of time for the completion of discovery until September 15, 2007, and for the filing of dispositive motions until October 15, 2007. THE PLAINTIFF, David Ruran THE DEFENDANT, Beth El Temple of West Hartford, Inc.

By /s/ William G. Madsen William G. Madsen (CT 09853) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave.; Suite 201 Hartford, CT 06106 (860) 246-2466 - telephone (860) 246-2794 - facsimile [email protected] - email

By /s/ Mark A. Newcity Mark A. Newcity (ct07991) Fitzhugh, Parker & Alvaro, LLP 155 Federal Street, Suite 1700 Boston, MA 02110 (617) 695-2330 - telephone (617) 695-2335 - facsimile [email protected] - email

CERTIFICATE OF SERVICE I hereby certify that on July 20, 2007, a copy of the foregoing document was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by email to all parties by operation of the court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the court's CM/ECF System. /s/ Mark A. Newcity Mark A. Newcity