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

i ‘ ‘ Case 3:02-cv-019161AWT Document 18 Filed 10/$$003 Page 1 of 3 I
itil} (Iii 30 l`¥—¥” I= OU
N UNITED STATES DISTRICT COURT L-: fi Rim
y DISTRICT OF CONNECTICUT *·"‘ `
i WILLIAM C. KOI-ILER, : CIVIL ACTION
Plaintiff NO. 302CV1918 (AWT)
V. :
CRABTREE SUBARU, I
Defendant : OCTOBER 30, 2003 ‘
DEFENDANT’S MOTION FOR MODIFICATION OF SCHEDULING ORDER _ I
Pursuant to D. Conn. L. Civ. R. 7(b), the Defendant, Crabtree Subaru,
respectfully moves the Court for a modification of the current scheduling order to extend
the discovery and dispositive motion deadlines for an additional ninety (90) days to
accommodate settlement negotiations and discovery. ln support of this motion, the J
undersigned counsel for the Defendant represents the following:
1. The Plaintiff commenced this action by complaint dated October 29, 2002.
On December 18, 2002, the Defendant filed its Answer and Affirmative Defenses. On
gust 7, 2003, the parties filed their Rule 26(f) report and case management plan, which ,
set forth the scheduling deadlines in this matter, including the discovery deadline of
October 30, 2003 and the dispositive motion deadline of February 1, 2004.
2. On September 30, 2003, the undersigned counsel filed an appearance in
this matter following the motion to withdraw appearance filed by Attorney Kristi |\/lackin
on August 15, 2003. As such, the undersigned counsel has only recently become
HALLORAN I:;;:·I;, rnnnrord. cr imwr Sz SAGE LLP rmi, 1%.26105


eie~ if


sis~ il

i h ` Case 3:02-cv-0191@?9tWT Document 18 Filed 10/30/2003 Page 2 of 3
i
i involved in this matter and requires the additional time to become acquainted with the
N facts of this case.
i 3. Prior to the withdrawal of Attorney Mackin, the Defendants had noticed the
deposition ofthe Plaintiff for September 4, 2003, which was marked off due to
scheduling conflicts. No witnesses have been deposed in this matter to date. in the l
interim, this case had been referred to Magistrate Donna F. Martinez for a settlement
conference by order dated September 15, 2003. l !
4. The parties are currently attempting to schedule the settlement conference N
with Magistrate Martinez. In the event that the parties fail to reach a settlement of this
L matter, significant discovery remains to be completed including written discovery and
the deposition of the Plaintiff, among other witnesses. l
5. This is the Defendant's first motion for extension of time with respect to
the modification of the scheduling order. The undersigned counsel has contacted
Tanya Wolanic, counsel for the Plaintiff who consents to this motion.
WHEREFORE, the Defendant respectfully requests the Court to grant the
Defendant’s motion for modification of the scheduling order for an additional ninety (90) I
days and to accommodate settlement discussions and discovery and enter an order as
follows:
1. All discovery, including depositions of all witness, shall be completed by
January 30, 2004;
2. Dispositive motions shall belfigad on or before May 1, 2004. l
HALLOW £;‘:2;rt6§liit8é°i
1a1arrrm·r1,c:*1*n6i0z & SAGE LLP Im N,,_ 26105

N Case 3:02-cv-O191@-AWT Document 18 Filed 10/3-0/2003 Page 3 of 3
N THE DEFENDANT,
I CARBTREE SUBARU
By:
James M. Sconzo {
Fed. Bar #ct04571 and
Kevin R. Brady
Fed. Bar #ct22135 |
HALLORAN 8. SAGE, LLP
One Goodwin Square
225 Asylum Street
Hartford, CT 06103 ,
860—522-6103 · I
CERTIFICATION
This is to certify that on this 30th day of October 2003, the foregoing was either l
mailed, postpaid, or hand—deIivered to:
Gary Phelan, Esq.
Tanya Wolanic
Klebanoff & Phelan PC
433 South Main Street Suite 117
West Hartford CT 06110 ,
l
Kevin R. Brady I
469648,1{HSFP) i
. 3 -
;$¤·i·dwigtS¤r·;¤¤= HALLORAN Phone (000) 522-6103
umrugd, Cr 06103 & SAGE LLP §;;S(?,9)2LQ4iE:;;,)0(]6
i