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

Case 3:02-cv-02101-AVC

Document 18

Filed 11/06/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : Plaintiff, : : vs. : : PETER O'MEARA THE COMMISSIONER OF : THE DEPARTMENT OF MENTAL : RETARDATION FOR THE STATE OF : CONNECTICUT, : Defendant : _____________________________________ : CYNTHIA WELFARE, CIVIL ACTION NO. 3:02CV2101(AVC)

November 5, 2003

PARTIES' JOINT MOTION FOR AN EXPANSION OF DISCOVERY AND PRE-TRIAL DEADLINES The Complaint in this matter was filed on November 27, 2002. Per the Court's order, discovery is set to close on November 13, 2003. The parties request an additional ninety days to complete discovery, and asks that the other pre-trial deadlines in this matter be similarly expanded. This is the second request for an expansion of the discovery period and pre-trial deadlines; however, the parties are currently briefing Defendant's Rule 12(b)(6) motion to dismiss, so the expansion would cause no undue delay in the trial of this matter. Plaintiff's counsel has consulted with Defendant's counsel, who has stated that he joins in this request.

Case 3:02-cv-02101-AVC

Document 18

Filed 11/06/2003

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Therefore, the parties respectfully request that the Court expand the existing pre-trial deadlines as follows: discovery to close by February 11, 2004, dispositive motions, if any, to be filed by March 12, 2004.

THE PLAINTIFF,

By:

____________________ Peter Goselin ct16074 Livingston, Adler, Pulda, Meiklejohn & Kelly, P.C. 557 Prospect Avenue Hartford, CT 06105 (860) 233-9821 [email protected]

Case 3:02-cv-02101-AVC

Document 18

Filed 11/06/2003

Page 3 of 3

CERTIFICATE OF SERVICE This hereby certifies that the forgoing Parties' Joint Motion for an Expansion of Discovery and Pre-trial Deadlines has been mailed, first class mail, postage pre-paid, on this day of November 2003 to all counsel of record as follows: Thomas M. Fiorentino Assistant Attorney General 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Peter Goselin