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

Case 3:03-cv-00452-CFD

Document 53

Filed 05/08/2007

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)

MAY 8, 2007

MOTION ON CONSENT TO ENLARGE THE SCHEDULING ORDER Pursuant to the Federal Rules of Civil Procedure and Local Rule 9 of this Court, the Plaintiff, on consent, respectfully requests a forty-five (45) day enlargement of time of the scheduling order currently in place, pursuant to which discovery is due to close on May 21, 2007 and dispositive motions are due thirty days thereafter. With the granting of this motion, discovery would close on July 5, 2007 and dispositive motions would be due on August 4, 2007. In support of this motion, Plaintiff states the following: 1. Pursuant to the current scheduling order, discovery is to be completed by May 21, 2007. 2. The parties have been diligent in conducting and scheduling depositions and written discovery following previous extension of time. However, due to scheduling difficulties affecting numerous witnesses and lawyers, counsel for the parties have determined that it is not feasible to conclude all discovery activities within the allotted time frame.

ORAL ARGUMENT IS NOT REQUESTED NOR IS TESTIMONY REQUIRED

Case 3:03-cv-00452-CFD

Document 53

Filed 05/08/2007

Page 2 of 3

3.

Accordingly, the parties respectfully and jointly request a forty-five day enlargement of time within which to conclude discovery, with a corresponding extension of time for the filing of dispositive motions.

5.

This is the sixth such enlargement of time with regard to the discovery deadline, it is with the agreement of counsel as discussed between the undersigned and Attorney Mark Newcity on May 8, 2007, and counsel state that they do not anticipate seeking further extensions.

WHEREFORE, Plaintiff, on consent, hereby respectfully request a forty-five (45) day enlargement of time in which to complete discovery and within which to file dispositive motions, pursuant to which discovery will close on July 5, 2007 and dispositive motions will be due on August 4, 2007.

PLAINTIFF, DAVID RURAN

By:

/s/ William G. Madsen (ct09853) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave., Suite 201 Hartford, CT 06106 TEL. (860) 246-2466 FAX. (860) 246-1794 Email: [email protected]

Case 3:03-cv-00452-CFD

Document 53

Filed 05/08/2007

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on this 8th day of May, 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/ William G. Madsen (ct09853) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave.; Suite 201 Hartford, CT 06106 Telephone: (860) 246-2466 Facsimile: (860) 246-1794 E-mail: [email protected]