Free Motion to Stay - District Court of Connecticut - Connecticut

Case 3:03-cv-00444-AWT

Document 75

Filed 03/16/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ROSEMOUNT AEROSPACE INC. Plaintiff, vs. HARCO LABORATORIES, INC., a Connecticut Corporation and BRAD POWELL, an individual, Defendants. ) ) ) Civil Action No. 3:03CV0444(AWT) ) ) ) ) ) ) )

JOINT MOTION TO STAY CASE SCHEDULE
WHEREAS, the parties continue to engage in constructive discussions to resolve this litigation; and WHEREAS, the parties' schedules have not permitted finalization of a settlement agreement, but now have a March 16, 2005 meeting to continue negotiating specific settlement language; and WHEREAS, the parties would like to minimize litigation costs and other inefficiencies; Plaintiff and Defendants hereby jointly request a stay of all deadlines. Plaintiff and Defendants will return to the Court on or before April 15, 2005 with a status report as to settlement negotiations and will at that time propose new deadlines for the prosecution of this matter or report to the Court at that time that the case has been settled. All parties agree to this motion. The parties have been engaged in conversations to try to resolve this matter, and although the parties have reached agreement on several settlement issues, resolving all matters of a settlement has taken longer than the parties intended. For that reason, the parties respectfully request that this motion be granted.

41580641.1 077736-00000 March 16, 2005 2:32 PM

Case 3:03-cv-00444-AWT

Document 75

Filed 03/16/2005

Page 2 of 2

Respectfully Submitted,

Dated:_____________, 2005 PLAINTIFF, ROSEMOUNT AEROSPACE INC.

Dated:_____________, 2005 DEFENDANTS, HARCO LABORATORIES, INC. and BRAD POWELL

____________________________ Daniel W. McDonald (ct23281) William D. Schultz (ct25198) Joel E. Bergstrom, (ct25647) MERCHANT & GOULD P.C. 3200 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402-2215 Ph. (612) 332-5300 Fx. (612) 332-9081 James Mahanna (ct24681) DAY, BERRY & HOWARD LLP CityPlace I Hartford, CT 06103-3499 Tel. (869) 275-0100 Fax: (806) 275-0343 [email protected]

____________________________ David S. Poppick (ct13202) Jonathan Plissner (ct23773) Epstein, Becker & Green, P.C. One Landmark Square Suite 1800 Stamford, CT 06901-2691 Ph. (203) 348-3737 Fx. (203) 324-9291 Robert Wise (ct25476) Harco Laboratories, Inc. 1100 Summer Street Stamford, CT 06905 Ph. (203) 359-8877

41580641.1 077736-00000 March 16, 2005 2:32 PM

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