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

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1 . Case 3:02-cv-O21O&5AVC Document 30 Filed 07/O§§OO4 Page 1 of 1
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1 UNITED STATES DISTRICT 1COUE`E E _
1 DISTRICT OF CONNECTICUT
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1 PETER O’MEARA COMMISSIONER OF
. THE DEPARTMENT OF MENTAL :
1 RETARDATION FOR THE STATE OF :
CONNECTICUT :
1 Defendant 1 : June 29, 2004
1 JOINT MOTION FOR AN EXPANSION OF DISCOVERY AND PRE-TRIAL
1 DEADLINES
1 Pursuant to Rule 9(b) ofthe Local Rules of Civil Procedure, Discovery in the above
captioned matter is set to close on June 30, 2004. The parties hereby request an additional sixty
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1 day§t‘o c jplete discovery, and ask that the other pre—tria1 deadlines in this matter be similarly
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1 HL the fifth request for an expansion of the discovery period and pre—tr1al deadlines. 1
Théyoaiqeifsghave been pursing the litigation in good faith. The plaintiff has completed three
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Cj depositidns, one ofthe defendant and two other depositions of employees. The defendant has A
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1;; served a notice of deposition on the plaintiftl The plaintiff is attempting to obtain her medical '
6 records, but has been delayed by the hospital’s slow progress in obtaining older records of the
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1 ¢ ` · gi plaintiff. The parties have exchanged and answered interrogatories and requests for production.
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§ 1 _ 1 1 S Additionally, there has been a change of counsel for the defendant. Assistant Attorney General 1
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E3 1 _ E MJ. McCarthy has replaced Assistant Attorney General Thomas M. Fiorentino as counsel for the 1
qi 1 'Q1; defendant. The undersigned counsel for the defendant hereby represents that she has been
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N Q . 1 authorized to file this motion on behalf of both parties. 1
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