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

Case 3:02-cv-02266-AVC

Document 96

Filed 11/16/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ************************************************ JP MORGAN CHASE BANK, : Plaintiff : : v. : : RIDGEFIELD PROPERTIES, LLC and : THE STOP & SHOP SUPERMARKET CO., LLC : Defendants : ************************************************

Civil Action No. 3:02-CV-2266 (AVC)

November 15, 2005

JOINT MOTION TO AMEND SCHEDULING ORDER By this motion, the parties to this action, JP Morgan Chase Bank, The Stop & Shop Supermarket Company, LLC, Ridgefield Properties, LLC and Samuels & Associates Management LLC hereby move to amend the Scheduling Order entered in this action. The parties seek to extend the deadlines (1) for designating all trial experts from November 30, 2005 to January 3, 2006; (2) to complete all discovery including depositions of experts from December 31, 2005 to January 31, 2006; and (3) to file dispositive motions from January 31, 2006 to March 2, 2006. The reason for this request is as follows. The parties have, at this point, engaged in extensive paper discovery including numerous interrogatories and the production of a large number of documents. In addition, numerous depositions have been taken. Given the extensive exchange of information, the parties have determined to again try to reach an amicable resolution

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Case 3:02-cv-02266-AVC

Document 96

Filed 11/16/2005

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of this controversy. The parties believe that such settlement efforts will be more productive if discovery can be held in abeyance for a short period of time. The requested extension of approximately 30 days of the remaining deadlines will enable the parties to delay the completion of discovery while settlement negotiations proceed. Moreover, if these efforts are successful, the requested extension will have enabled the parties to save the considerable time, effort and expense of completing discovery which would otherwise have been necessary. Counsel for JP Morgan Chase Bank, Ridgefield Properties, LLC and Samuels & Associates Management LLC have indicated that they join in this motion. This is the first motion to amend the Scheduling Order in this matter.

RESPECTFULLY SUBMITTED, THE DEFENDANT, THE STOP & SHOP SUPERMARKET COMPANY, LLC

By:

/s/ Lewis K. Wise [ct05716] ROGIN, NASSAU, CAPLAN, LASSMAN & HIRTLE, LLC CityPlace I, 22nd Floor 185 Asylum Street Hartford, CT 06103-3460 Tel. No. (860) 278-7480 Fax No. (860) 278-2179 Email [email protected]

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Case 3:02-cv-02266-AVC

Document 96

Filed 11/16/2005

Page 3 of 3

CERTIFICATION

This is to certify that a copy of the foregoing Joint Motion has been mailed via first-class mail, postage prepaid, on this 15th day of November, 2005 to the following:

Timothy S. Fisher, Esq. Jason C. Welch, Esq. McCarter & English LLP CityPlace I, 185 Asylum Street Hartford, CT 06103 Jeffrey J. Mirman, Esq. Levy & Droney PC 74 Batterson Park Road P. O. Box 887 Farmington, CT 06034-0887 John C. La Liberte, Esq. Sherin and Lodgen LLP 101 Federal Street Boston, MA 02110

/s/ Lewis K. Wise

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