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

Case 3:03-cv-00452-CFD

Document 39

Filed 06/03/2005

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)

JUNE 3, 2005

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 a ninety day enlargement of time of the scheduling order currently in place beginning on the date that a ruling is made on the Defendant's currently pending Objection to the Ruling on the Plaintiff's Motion to Compel and for Attorneys fees [doc. #34] in this matter. In support of this motion, the parties state the following: 1. Pursuant to the current scheduling order, discovery is to be complete by May 24, 2005; and dispositive motions are due by June 23, 2005. 2. On September 8, 2004, the Plaintiff filed a Motion to Compel discovery responses together with a supporting memorandum of law [docs. #22 and 23 ]. The Defendant opposed that Motion [doc. # 24 and 25] and the Plaintiff subsequently filed a Reply [doc. #26]. 3. On February 23, 2005, Magistrate Judge Thomas Smith issued a ruling in connection with the Plaintiff's Motion to Compel.

ORAL ARGUMENT IS NOT REQUESTED NOR IS TESTIMONY REQUIRED

Case 3:03-cv-00452-CFD

Document 39

Filed 06/03/2005

Page 2 of 2

4. 5.

On March 4, 2005, Defendant filed an Objection to that Ruling. There remain several depositions to be taken, which cannot be taken without the aid of documents that are the subject of the Defendant's Objection.

6.

This parties believe that at least ten (10) depositions will be taken and that they will need ample time to take said depositions.

7.

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

WHEREFORE, the parties respectfully request a ninety day enlargement of time beginning on the date that a ruling is made on the Objection to the Plaintiff's Motion to Compel and for Attorneys fees within which to complete discovery and file dispositive motions. Thus, discovery would close ninety days following any ruling on the Objection and dispositive motions would be due thirty days thereafter.

THE PLAINTIFF, David Ruran

THE DEFENDANT, Beth El Temple of West Hartford, Inc.

By_____________________________ 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___________________________ Mark A. Newcity (ct07991) Fitzhugh, Parker & Alvaro, LLP One Constitution Plaza, Suite 900 Hartford, CT 06103 (860) 549-6803 - telephone (860) 728-0546 - facsimile [email protected] - email