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

Case 3:03-cv-00452-CFD

Document 49

Filed 02/05/2007

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)

February 5, 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 two month enlargement of time of the scheduling order currently in place, pursuant to which discovery is due to close on March 18, 2007 and dispositive motions are due thirty days thereafter. With the granting of this motion, discovery would close on May 21, 2007 and dispositive motions would be due on June 21, 2007. In support of this motion, Plaintiff states the following:

1.

Pursuant to the current scheduling order, discovery is to be completed ninety (90) days following the Court's ruling on the Defendant's Objection to Magistrate Judge Smith's Ruling on Plaintiff's Motion to Compel and for Attorneys fees.

2.

On December 18, 2006, after hearing argument, this Court issued its Ruling on said Objection, thereby making the due date for the completion of discovery March 19, 2007­which is the Monday following the 90th day (which falls on a weekend).

ORAL ARGUMENT IS NOT REQUESTED NOR IS TESTIMONY REQUIRED

Case 3:03-cv-00452-CFD

Document 49

Filed 02/05/2007

Page 2 of 3

3.

The parties have been diligent in conducting and scheduling depositions and written discovery following the Court's December 18, 2006 Ruling. 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.

4.

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

5.

This is the fifth 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 February 5, 2007, and counsel state that they do not anticipate seeking further extensions.

WHEREFORE, Plaintiff, on consent, hereby respectfully request a two month enlargement of time in which to complete discovery and within which to file dispositive motions, pursuant to which discovery will close on Monday, May 21, 2007 and dispositive motions will be due on Thursday, June 21, 2007.

Case 3:03-cv-00452-CFD

Document 49

Filed 02/05/2007

Page 3 of 3

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]

CERTIFICATION OF SERVICE I hereby certify that on this 5th day of February, 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]