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


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Date: September 1, 2004
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State: Connecticut
Category: District Court of Connecticut
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I · " Case 3:02-cv-O2101(A\/C Document 32 Filed O9/O1/2(IO4 Page 1 of 3
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DISTRICT OF CONNECTICUT H
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CYNTHIA WELFARE, : ACTION
Plaimmr i 3=02CV?l‘?1.(AYaQ1—; ‘I·. ti `¤"- it
i PETER O’MEARA COMMISSIONER OF
. THE DEPARTMENT OF MENTAL :
RETARDATION FOR THE STATE OF :
CONNECTICUT :
Ddendant : August 31, 2004
y l
JOINT MOTION FOR AN EXPANSION OF DISCOVERY AND PRE-TRIAL
l DEADLINES
Pursuant to Rule 9(b) ofthe Local Rules of Civil Procedure, Discovery in the above
captioned matter was set to close on August 30, 2004. The parties hereby request an additional
sixty days to complete discovery, and ask that the other pre-trial deadlines in this matter be )
similarly extended.
This is the sixth request for an expansion of the discovery period and pre-trial deadlines.
The parties have been pursing the litigation in good faith. The plaintiff has finally obtained her
medical records, the release of which has been delayed by the hospital’s slow progress in
obtaining older records of the plaintiff The parties have exchanged and answered interrogatories
and requests for production. Counsel for the defendant has been unable to depose the plaintiff
without her medical records. The parties have agreed upon a date for the plaintiff s deposition.
Counsel for the plaintiff has indicated that he intends to take at least one more deposition. There
is also a potential dispute regarding discovery. The undersigned counsel for the defendant
hereby represents that she has been authorized to file this motion on behalf of both parties.




I ` Case 3:O2—cv-O2101€A)’C Document 32 Filed O9/O1@$O4 Page 2 of 3
Wherefore, the parties hereby request that the court expand all existing pre—trial deadlines
by sixty days so that:
I (1) All discovery, including depositions of all witnesses shall be completed by October
30, 2004;
(2) All motions except motions in limine incident to a trial shall be filed on or before
November 30, 2004.
I THE DEFENDANT I
MJ. McCart y .
Assistant Attorney General
Federal Bar No. ct00319
55 Elm Street, PO Box 120 ,
- Hartford, CT 06141-0120 I
Tel: (860) 808-5210 =
Fax: (860) 808-5385
l‘I‘1]..I'I'1CC3fth}[email protected]

i t ~ - Case 3:02-cv-021 O1 Document 32 Filed O9/O1/2004 Page 3 of 3
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{ CERTIFICATION
X I hereby certify that a copy ofthe foregoing motion was mailed in accordance with Rule
5(b) of the Federal Rules of Civil Procedure on this 31st day of August, 2004, first class postage
prepaid to:
Peter Goselin
Livingston, Adler, Pulda, Meiklejohn, & Kelly, P.C. `
557 Prospect Ave. i
Hartford, CT 06105
l
MJ. gctjarthy Q _ i
Assistant Attorney General