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

r .. Case 3:02-cv-021 -AVC Document 27 Filed O4/@2004 Page 1 of 3
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UNITED STATES DISTRICT COURT Zim API? 39 {3 '_
DISTRICT OF CONNECTICUT 5 {W I ` 32
CYNTHIA WELFARE 2 CIVIL ACTION NO- Ii‘)iii I
Plnintw" : 3:02C\/2101 (AVC) ' ‘
v. E
PETER O'MEARA, COMMISSIONER
DEPARTMENT OF MENTAL :
RETARDATION : I
Defendant ‘ : April 29, 2004

JOINT MOTION FOR AN EXPANSION OF DISCOVERY AND PRE-TRIAL
DEADLINES
Pursuant to Rule 9(b) ofthe Local Rules of Civil Procedure, Discovery in the above- I
captioned matter is set to close on May ll, 2004, The parties hereby request an additional fifty
days to complete discovery, and ask that the other pre-trial deadlines in this matter be similarly “ I
extended. i
This is the fourth request for an expansion ofthe discovery period and pre-trial deadlines.
The parties have been pursing the litigation in good faith, having both served discovery requests,
including the defendant’s request dated January 20, 2004. The defendant served a notice of I
deposition dated April 15, 2004 on the plaintiff to take the plaintiff s deposition on April 27, I
2004. I
The plaintiff’ s counsel requested a postponement of that deposition because of difficulty
he has encountered in contacting the plaintiff to prepare her for the deposition. The plaintiff is
currently out on medical leave from the Department of Mental Retardation which may have
contributed to the scheduling difficultiesii 'At the direction ofthe 'defendant’s counsel, employees
of the department of mental retardation have contacted the plaintiff and asked herto contact her I
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counsel. In addition, the defendant’s counsel has furnished the plaintiff’ s counsel with the
plaintiff’ s home phone number in an attempt to facilitate contact between them. Given these `
difficulties, the defendant agreed to postpone the deposition. The undersigned cotmsel for the
defendant hereby represents that he has been authorized to tile this motion on behalf of both i
parties.
Wherefore the parties hereby request that the court expand all existing pre-trial deadlines I
by ninety days so that: 1
(1) All discovery, including depositions of all witnesses shall completed by June 30, I
20004;
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(2) All motions except motions in limine incident to a trial, shall be filed on or before
July so, 2004,
DEFENDANT, PETER O’MEARA,
COMMISSIONER, DEPARTMENT OF
MENTAL RETARDATION N
RICHARD BLUMENTHAL p
ATTORNEY GENERAL y
BY: A I
Aww - " {
homas M. io no l
Assistant Attorney General l
Federal Bar No. ct09031
55 Elm Street
1>.o. Box 120 l
Hartford, CT 06141-0120 i
Tel: (860) 808-5330 gag`-- 53l { ;
Fax: (860) 808-5383
[email protected] l
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, _ . · . Case 3:02-cv-O21(O1,-AVC Document 27 Filed O4{30)/2004 Page 3 of 3
CERTIFICATION

I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b) of
the Federal Rules of Civil Procedure on this 29th day of April 2004, first class postage prepaid
to:
Peter Goselin, Esq.
Livingston, Adler, Pulda, Meiklejohn & Kelly, P.C.
557 Prospect Avenue
Hartford, Connecticut 06105
homas M. Fio o
Assistant Attorney General
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