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

Case 3:03-cv-00301-DJS

Document 17

Filed 03/11/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

VICTOR PEREIRA, : PLAINTIFF,

:

CIVIL NO.: 3:03CV0301(AWT)

: : vs. : : DETECTIVE FRANK KOSHES, DETECTIVE : LAWRENCE SMITH, PATROLMAN TIMOTHY : JACKSON, DETECTIVE MICHAEL GOGGIN, : AND DETECTIVE GARY PECE, : DEFENDANTS.

MARCH 8, 2004

MOTION TO ENLARGE SCHEDULING ORDER Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, defendants, Frank Koshes, Lawrence Smith, Timothy Jackson, Michael Goggin and Gary Pece, hereby respectfully request an extension of the scheduling order in the above captioned matter as follows. The defendants seek an enlargement of time of six months for the completion of discovery, to be completed, not propounded, until October 1, 2004. The defendants also seek an enlargement of time of six months for the filing of dispositive motions until February 1, 2005.

Case 3:03-cv-00301-DJS

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Filed 03/11/2004

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The undersigned is presently conducting jury selection in the case of Sylbert Ramsay v. City of Waterbury, Docket Number CV010166898S, taking place at Waterbury Superior Court. It is

believed that this case will not begin evidence until sometime in the week of March 15, 2004, and the trial is expected to last at least five days. The undersigned is scheduled to begin jury selection on March 30, 2004, in the case of William Ondrick v. Town of Ridgefield, Docket Number CV000341074 S, at Danbury Superior Court, and is expected to take two weeks or more before it is completed. Additionally, the undersigned has two briefs due to the Second Circuit Court of Appeals in the month of March. This is the first such request to enlarge the scheduling order requested by these defendants. Pursuant to Rule 9(b)(2), on this date the office of the undersigned called the office of plaintiff's attorney, Christopher Santarsiero, Esquire, who stated that he has no objection to this motion.

Case 3:03-cv-00301-DJS

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Filed 03/11/2004

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DEFENDANTS, DETECTIVE FRANK KOSHES, DETECTIVE LAWRENCE SMITH, PATROLMAN TIMOTHY JACKSON, DETECTIVE MICHAEL GOGGIN, AND DETECTIVE GARY PECE

BY_______________________________ Michelle Holmes Federal Bar Number: ct20014 Sack, Spector & Karsten 836 Farmington Avenue West Hartford, CT 06119 Their Attorney CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, this 8th day of March, 2004, to the following counsel of record:

Christopher Santarsiero, Esquire 100 Grand Street, Suite 2C Waterbury, CT 06702

________________________ Michelle Holmes

Case 3:03-cv-00301-DJS

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Filed 03/11/2004

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United States District Court Attn: Clerk's Office 450 Main Street Hartford, CT 06103 Honorable Alvin W. Thompson United States District Court 450 Main Street Hartford, CT 06103