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

Case 3:03-cv-00452-CFD

Document 56

Filed 06/11/2007

Page 1 of 3

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)

JUNE 11, 2007

MOTION ON CONSENT TO ENLARGE THE SCHEDULING ORDER Pursuant to the Federal Rules of Civil Procedure and the Local Rules of this Court, the Plaintiff, on consent, respectfully requests a thirty-five (35) day enlargement of time of the scheduling order currently in place, pursuant to which discovery is due to close on July 5, 2007 and dispositive motions are due thirty days thereafter. With the granting of this motion, discovery would close on August 10, 2007 and dispositive motions would be due on September 10, 2007. In support of this motion, Plaintiff states the following: 1. Pursuant to the current scheduling order, discovery is to be completed by July 5, 2007. 2. The parties have been diligent in conducting and scheduling depositions and completing written discovery. 3. Just last week, however, with several additional depositions that remain to be taken, Attorney William Madsen was involved in a serious car accident in which his spouse was very seriously injured. She remains in the hospital and sometime in the future will be transferred to a rehabilitation facility. ORAL ARGUMENT IS NOT REQUESTED NOR IS TESTIMONY REQUIRED

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Case 3:03-cv-00452-CFD

Document 56

Filed 06/11/2007

Page 2 of 3

4.

Accordingly, for good cause, Attorney Madsen needs additional time to complete discovery in this matter.

5.

This is the seventh such enlargement of time with regard to the discovery deadline. On inquiry to counsel for the Defendant, Attorney Mark Newcity, Defendant has no objection to the granting of this motion.

WHEREFORE, Plaintiff, on consent, hereby respectfully requests a thirty-five (35) day enlargement of time in which to complete discovery and within which to file dispositive motions, pursuant to which discovery will close on August 10, 2007 and dispositive motions will be due on September 10, 2007.

PLAINTIFF, DAVID RURAN

By:

/s/ Katalin A. Demitrus (ct26884) Madsen, Prestley & Parenteau, 44 Capitol Ave., Suite 201 Hartford, CT 06106 TEL. (860) 246-2466 FAX. (860) 246-1794 Email:

LLC

[email protected]

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Case 3:03-cv-00452-CFD

Document 56

Filed 06/11/2007

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on this 11th day of June, 2007, a copy of foregoing Motion On Consent to Enlarge the Scheduling Order was filed electronically [and served by mail on anyone unable 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 unable to accept electronic filing]. Parties may access this filing through the Court=s system.

By:

/s/ Katalin A. Demitrus (ct26884) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave.; Suite 201 Hartford, CT 06106 Telephone: (860) 246-2466 Facsimile: (860) 246-1794 E-mail: [email protected]

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