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

Case 3:03-cv-00160-PCD

Document 16

Filed 11/26/2003

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

____________________________________ : MAHA B. MIKHAIL WASSEF, M.D., : Plaintiff, : : v. : : JOAN RAIMONDO, : Defendant. : ____________________________________:

Civil Action No. 3:03CV160 (PCD)

November 25, 2003

PLAINTIFF'S MOTION ON CONSENT FOR EXTENSION OF TIME TO SERVE TRIAL MEMORANDUM Pursuant to Local Rule of Civil Procedure 7(b), plaintiff Maha B. Mikhail Wassef, M.D., hereby moves for an extension of time of two weeks (or until December 22, 2003) to serve her compliance with Part A of the Court's Trial Preparation Order dated November 18, 2003. In support of this motion, plaintiff represents as follows: 1. Pursuant to the Trial Preparation Order, plaintiff's compliance with Part A is currently required to be served on or before December 8, 2003. 2. The undersigned has conferred with counsel for defendant, Constance Epstein, Esq., and counsel for the third-party defendant, Susan O'Donnell, Esq., and they have stated that they have no objection to this motion. 3. Upon receipt of the Court's November 18 Order, counsel discussed among themselves the prospects for mediating the case. At this point, mediation seems likely to take place.

ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-00160-PCD

Document 16

Filed 11/26/2003

Page 2 of 4

Plaintiff and the third-party defendant are interested in pursuing mediation promptly. Although the vacation of her client this week has prevented counsel for defendant from responding to plaintiff's invitation to mediate the case, defendant's counsel has represented to the undersigned (and authorized him to inform the Court) that she has recommended mediation to her client. 4. A two-week extension is warranted so that counsel can have time to solidify the plans regarding mediation. In the likely event that mediation is pursued, pursuant to Local Rule 16 counsel will advise the Court of the details and apply for a referral to ADR, seeking a further extension of the deadline for the trial preparation memorandum if necessary to accommodate the mediation schedule. 5. A two-week extension of time is also warranted because the long-standing plans of the undersigned for the Thanksgiving Holiday period, in conjunction with substantial work obligations associated with other cases pending in state and federal court, make it very difficult for counsel to complete plaintiff's compliance by the December 8, 2003 deadline. 6. This is plaintiff's first motion for an extension of time in regard to any deadline in this case.

WHEREFORE, plaintiff respectfully requests a two-week extension of time (until December 22, 2003) to serve her compliance with the Court's November 18, 2003 Trial Preparation Order.

2

Case 3:03-cv-00160-PCD

Document 16

Filed 11/26/2003

Page 3 of 4

THE PLAINTIFF, MAHA WASSEF MIKHAIL

By_/s/______________________ Steven D. Ecker (ct03762) James R. Smart (ct20982) Cowdery, Ecker & Murphy, L.L.C. 750 Main Street Hartford, CT 06103 (860) 278-5555 (860) 249-0012 E-mail: [email protected] E-mail: [email protected] - Her Attorneys -

3

Case 3:03-cv-00160-PCD

Document 16

Filed 11/26/2003

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that the original of the foregoing was mailed, this 25th day of November, 2003, by United States mail, postage prepaid, to: Constance L. Epstein, Esq. Howard, Kohn, Sprague & FitzGerald 237 Buckingham Street Hartford, CT 06106 Susan O'Donnell, Esq. Halloran & Sage, LLP One Goodwin Square Hartford, CT 06103.

__/s/_______________________ James R. Smart

4