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

1 Case 3:02-cv-02237-MRK Document 26 Filed 12/23/2003 Page 1 of 2 i
UNITED STATES DISTRICT COURT P, { E ___ _ l
orsrruor or comiscrrcor ii; li.}
TRILEGIA T CORPORATION, : Civil Action No.: I
Plaimiffl Lit i
VS. :
BP PRODU TS NORTH AMERICA INC. E
Defendant.
: DECEMBER 19, 2003 .
JOINT MOTION TO EXTEND SCHEDULING ORDER
Plai tiff Trilegiant Corporation ("Trilegiant") and defendant BP Products North America
Inc. (“BP") espectfully move the Court for an Order extending all of the deadlines contained in
the Schedul` g Order of October 29, 2003, as follows: y
Disc osure of plaintiffs amended expert report — January 15, 2004 g
Disc osure of defendant’s expert and expert reports —— February 15, 2004
Dep sition of defendant’s expert -~ March 15, 2004
Com letion of all discovery — March 15, 2004
Filin of dispositive motions — April 15, 2004
Joint Trial Memorandum if no dispositive motions are filed — May 15, 2004
Trial Ready if no dispositive motions are filed — May 15, 2004
Exte sion of the current Scheduling Order is necessary to enable Trilegiant to complete
an amended xpert report and supporting documentation, and therafter to afford BP adequate
time to resp nd to the amended report with its own expert witness. Subsequent to the October
27, 2003 de osition of plaintiff s expert, BP served a set of supplemental discovery requests,
principally med at the grounds for some of the opinions offerred by the expert. In tum,

I n Case 3:02-cv-02237-MRK Document 26 Filed 12/23/2003 Page 2 of 2
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plaintiff de ided to amend its expert report and opinions. The parties have agreed that Trilegiant I
will serve it amended expert report and responses to the defendant’s supplemental document I
requests on r before January 15, 2004. Accordingly, the Scheduling Order needs to be modified I
to allow Tri egiant adequate time to amend its report and complete document production. At that
point, BP w ll complete the engagement with its expert, and make prompt dislosure of its expert I
report. The circumstances leading to the parties’ request for an extension of the Scheduling I
Order were ot reasonably foreseeable at the time of the recent status conference, and the
extensions r quested are necessary in order to provide the parties with a reasonable amount of
time to com lete expert witness discovery.
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WH REFORE, the parties jointly request that the Court extend the scheduling order
deadlines as described above. I
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PLAINTIF DEFENDANT,
TRILEGIAIIIT CORPORATION BP PRODUCTS NORTH AMERICA INC. I
F _; I: I
fi L r//' V I I
By: I U “ By¤ y
Robert . D lian. (ct0427S) Steven M, Greensp (ct00380) .
Kareh L. Al ison (ct2l 849) Brian D. Porch, Jr. (ct236500)
Four Stamf d Plaza One Canterbury Green
107 Elm Str et Stamford, CT 06901-2047
Stamford, C 06902 (203) 977-7300 I
(203) 327-I 00 Its Attorneys I
Its Attorney

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