Free Motion for Conference - District Court of Connecticut - Connecticut


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Pages: 3
Date: February 2, 2004
File Format: PDF
State: Connecticut
Category: District Court of Connecticut
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URL

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Case 3:02-cv-01797-@:53 Document 34 Filed O2/O2/ZOB)4 Page 1 of 3 I
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT l
MARSHA HANNA, ; _ ` {gt 2
: CIVIL ACTION T Q
Plaintiff, : 3:02CVl707_i(DJS)_, . ;
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‘ CAROLE PANNOZZO, in her official capacity Z. -
as Interim Director of Human Resources for : { if (
the Bridgeport Board of Education; CITY OF : i·_* Z _ g i
BRIDGEPORT BOARD OF EDUCATION, :
Defendants. JANUARY 30, 2004
MOTION FOR EXTENSION OF TIME
AND REQ QUEST FOR SETTLEMENT CONFERENCE
Counsel for the parties have conferred and believe that the chance for a settlement in this
matter is greater if discovery and motion practice can be stayed pending a settlement conference
with a Magistrate Judge. Thus, Defendants hereby request the scheduling of a settlement
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conference before a Magistrate Judge at the earliest possible convenience. (
l In the interim, Defendants, by and through their undersigned counsel, request pursuant to
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Local Rule 7(b) of the Federal Rules of Civil Procedure and Judge Squatrito’s September 17, J
2003 Order, an enlargement of time of thirty (30) days after the date of a settlement conference
to complete the depositions of Plaintiffs treating physicians and an enlargement of time of thirty
(30) days after the completion of the depositions to serve dispositive motions. In support of this
motion Defendant’s represent that Plaintiff’ s physician, Dr. Z.A. Adefuin, is presently out of the
country and will not be back in the United States until the second week of February 2004. Thus,

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Case 3:02-cv-O1797 I
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Dr. Adefuin is not available for a deposition prior to the discovery cutoff date of February 2,
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2004. Therefore, Defendants require additional time to conduct the deposition of Dr. Adefuin
and, if necessary, Defendants will require additional time to prepare dispositive motions after the R
deposition of Dr. Adefuin. p
This is Defendants’ third request for an enlargement of time regarding this deadline.
Defendants‘ counsel has contacted Plaintiffs counsel and P1aintiff’s counsel has no objection to
this motion. The case is not assigned for trial.
_ Done at Bridgeport, Connecticut, this 30th day of January, 2004.
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i David J. Kel
Durant, Nichols, Houston, Hodgson & p
Cortese—Costa, PC
1057 Broad Street p
i _ Bridgeport, CT 06604
` 203-366-3438
I Federal Bar No. ctl 9775 R
` ATTORNEYS FOR DEFENDANTS p
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Case 3:02-cv-O1797RD:1)S Document 34 Filed O2/O2/@004 Page 3 of 3
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CERTIFICATION J
I hereby certify that a copy of the foregoing was caused to be served this 30th day of I
January, 2004, via U. S. Mail, Certified Mail, Return Receipt Requested, to the following
, counsel and lg g parties of record:
Thomas W. Bucci, Esq.
Willinger, Willinger & Bucci, PC
855 Main Street
Bridgeport, CT 06604 _
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David J. Ke y
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