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

i _ _ Case 3:02-cv-O210@VC Document 22 Filed O2/1 1[2004 Page 1 of 3
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l PETER O'MEARA, COMMISSIONER : i
; DEPARTMENT OF MENTAL : Q
RETARDATION : y
i Defendant : FEBRUARY 10, 2004
JOINT MOTION FOR AN EXPANSION OF DISCOVERY AND PRE-TRIAL )
DEADLINES `
Pursuant to Rule 9(b) of the Local Rules of Civil Procedure, Discovery in the above-
captioned matter is set to close on February ll, 2004. The parties hereby request an additional
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ninety days to complete discovery, and ask that the other pre-trial deadlines in this matter be (
similarly extended.
This is the third request for an expansion of the 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. In addition, the defendant filed a
motion to dismiss on September] 8, 2003 which the plaintiff has- opposed with the filing of brief
in opposition on November 20, 2003. (The court has not yet ruled on the motion.) The
undersigned counsel for the defendant hereby represents that he conferred with counsel for the i
plaintiff by telephone on February 9, 2004 and has been authorized to file this motion on behalf 0
of both parties.
‘ Wherefore the parties hereby reques_t that the court expand all existing pre—tria1 deadlines
by ninety days so that: _ __
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I . . . _ Case 3:O2>cv-O210@VC Document 22 Filed 02/ 1 6/$004 Page 2 of 3
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, (1) All discovery, including depositions of all witnesses shall completed by May 11, ,
2004;
(2) all motions except motions in limine incident to a trial, shall be filed on or before i
June 11, 2004.
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DEFENDANT, PETER O’MEARA,
COMMISSIONER, DEPARTMENT OF I
MENTAL RETARDATION
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RICHARD BLUMENTHAL I
ATTORNEY GENERAL
BY- . `i''” l in
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omas . ' o I
Assistant At eneral 5
Federal Bar No. 01509031
55 Elm Street i
P.O. Box 120 I
Hartford, CT 06141-0120
. Tel: (860) 8086330
Fax: (860) 8086383
[email protected] p
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! . . . , Case 3:02-cv-O21OCAVC Document 22 Filed 02/ 1 }[%OO4 Page 3 of 3
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W CERTIFICATION
§ I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b) of
, the FederalRules of Civil Procedure on this 10th of February 2004, first class postage prepaid to: R
Peter Goselin, Esq.
Livingston, Adler, Pulda, Meiklejohn & Kelly, P.C. t
557 Prospect Avenue
Hartford, Connecticut 06105 _
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United States District Court
District of Connecticut
450 Main Street
Hartford, CT 06103 i
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Thomas M. no I
Assistant Attorney General `
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