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

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· Case 3:02-cv-0172]-AHN Document 28 Filed O1/08/2004 Page 1 of 3 `
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UNITED STATES DISTRICT C()l[I§mlS“l'RlC.lél§$$~l§;i l l
DISTRICT OF CONNECTICUT BR\UGF.P0 —\ » T
JULIA JACKSON, : CIVIL ACTION NO. N
Plaintiff : 3:02CV17'77(AHN) I
NORWALK BOARD OF EDUCATION, E
LOUIS LaBOSCO, DR. NORMAN :
ZAMCHECK, ART DOOLEY, and :
RICK FOLLMAN :
Defendants : JANUARY 6, 2004
DEFENDANTS’ MOTION FOR EXTENSION OF TIME AND TO REVISE PRE—
TRIAL SCHEDULING OFDER
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Pursuant to Rule 7(b) of the Local Rules of Civil Procedure, defendants Norwalk Board `
of Education, Louis LaBosco, Dr. Norman Zamcheck, Art Dooley and Rick Follman hereby
request that the deadline for the filing of motions for summary judgment be extended. The
present deadline for the filing of motions for summary judgment is January 15, 2004; the l
defendants ask that this deadline be extended until February 15, 2004. This amendment of the 1
scheduling order is necessitated by the press of legal business of the undersigned counsel, I
including the need to prepare and tile several other motions for summary judgment and post-
ORAL ARGUMENT IS NOT REQUIRED.
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LAWOFFICES • SULLIVAN, SCHOEN, CAMPANE&GONNON, LLC • 646 PFIOSPECTAVENUE · HARTFORD, CONNECTICUT 061054286 • (B60)233-2141 l
JURIS NO. 62326

i { `Case 3:O2—cv-O17(77iAHN Document 28 Filed O1/Q,8L2004 Page 2 of 3 l
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arbitration/administrative hearing briefs, and the need to prepare for and participate as lead
counsel in a lengthy jury trial in the Connecticut Superior Court that is currently scheduled to I
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commence on January 20, 2004. In addition, while the summary judgment materials are
significantly completed, the defendants still need to assembly and complete the necessary
supporting papers, exhibits, and affidavits; this task has been made more difficult bythe recent
death of one ofthe defendants, Louis LaBosco. The requested extension of time would permit
the defendants to complete and file their motion for summary judgment. This is the undersigned
defendants’ second request for an amendment of the court’s pre-trial scheduling order with
regard to the filing of motions for summary judgment; the first such extension of time was (
requested by motion dated August 28, 2003 and granted by this court. Counsel for the
defendants has contacted counsel for the plaintiff, Cynthia R. Jennings, Esq., who indicates that
she has no objection to this motion.
DEFENDANTS— RWALK BOARD OF
EDUCAT L (
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By
Mar J. So ruga (ct09865)
Sulhvan, Schoen, Campane & Connon, LLC
646 Prospect Avenue
Hartford, CT 06105
Tel: (860)-233-2141
Fax: (860)-233-0516
email: [email protected]
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rawomcrs · suunvau.scuo¤u,c2w=AuEaconnon,1.1.1; · 646 1=aos1=rctAvE11ur · Hmtono, CONNECT|CUT061U5-4286 · (am; 233-2141 l
JURIS NO. 62326

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N Case 3:02-cv-0175-7§AHN Document 28 Filed O1/O<8/§OO4 Page 3 of 3
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QEEILEIQAILQE N
This is to certify that a copy ofthe foregoing was mailed via U. S. Mail, postage prepaid,
to Cynthia R. Jennings, Esq., The Barrister Law Group, LLC, 211 State Street, Bridgeport, CT
06604, thiéi Q day of January, 2004. _
Mark J. s mam N
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LAWOFFICES · SULLIVAN, SCHOEN. CAMPANE&CONNON, LLC • E46 PROSPECTAVENUE • HAFITFOFID, CONNECTICUT 05105-4286 • (BSO) 233-2141
JUFEIS NO. 62326
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