UNITED STATES DISTREICT COURT I _- lb l U ··,4A *
DISTRICT OF CONNECTICUT gg q ; "-tg [ Q: tg. j,
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Plaintiff,
V. CIVIL ACTION NO.
3:02CV 1754 (CFD)
BMW FINANCIAL SERVICES, N.A.
Defendant. OCTOBER 17, 2003
PLAINTIFF’S MOTION TO AMEND PLANNING REPORT
Plaintiff requests a modification of the Report of Parties’ Planning Meeting
as set forth below:
1. Extend the time for deposition of defendant BMW Financial Services by n
45 days from the date the court grants this motion. Defendant is located in Ohio p
and that time frame is necessary to agree on date the defendant will be available,
plane reservations and serving notice of deposition. ,
2. Extend the time to file dispositive motions by 105 days from the date the l
court grants this motion.
3. Extend the trial memorandum accordingly.
Plaintiff represents that the parties tiled their first motion with consent on
April 2l, 2003. The time has expired for taking defendant’s deposition and the p
time will expire on November 14 for tiling dispositive motions. The Court ruled l
ORAL ARGUMENT NOT REQUESTED:
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Case 3:02-cv-OLY54-CFD Document 39 Filed 10/20/2003 Page 2 of 2 l
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on defendant’s Motion to Dismiss on October 3, 2003.
Plaintiff via facsimile and U.S. Mail requested that defendant’s consent to '
the above motion however, the defendant has not replied, therefore plaintiff is i
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unable to ascertain its position.
The matter is not on the trial list. §
THE PLAINTIFF
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BY }_._:*"I;:-` / J I
Bernard T. Kennedy j 2
49 Rose Street, #301 1
Branford, CT 06405
(203) 481-1322
Fed. Bar # ct00680 `
CERTIFICATE OF SERVICE 1
This is to certify a copy of the foregoing was mailed on this date via U.S.
Mail, postage prepaid to: i
Adam J. Cohen, Esq.
Sheila A. Denton, Esq.
Pullman & Comley l
Box 7006 1
Bridgeport, CT 06601-7006 I
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3/
Bernard T. Kennedy 1
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