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

N Case 3:02-cv-02237-MRK Document 22 Filed 10/29/2003 Page 1 of 2 ‘
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° UNITED STATES DISTRICT COURT_ Y-· i
DISTRICT OF CONNECTICUT l»··~
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TRILEGIANT CORPORATION, : Civil r%;li0l1.‘PNo.l“3:02CN22~37 (MRK)
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Plaintiff, ; U- ,§i\{\;,¤l t tb ld if
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BP PRODUCTS NORTH AMERICA INC. i
Defendant.
: OCTOBER 28, 2003
JOINT MOTION TO EXTEND SCHEDULING ORDER
The plaintiff Trilegiant Corporation ("Trilegiant") and the defendant, BP Products North
America Inc. ("BP") respectfully move the Court for an Order extending the deadlines contained _
in the scheduling order of March 3, 2003, as follows:
Depositions of plaintiff s experts — November l, 2003
Disclosure of defendant’s experts and expert reports — December l, 2003
Depositions of defendant’s experts — January 1, 2004
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Completion of all discovery — January 1, 2004
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Filing of dispositive motions — February l, 2004
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Matter will be trial ready by — August l, 2004
Joint Trial Memorandum if no dispostive motions are filed — April 15, 2004
The parties were forced to schedule a bulk of the discovery between the months of
September and October this year because several witnesses were unavailable during July and {
August. As a result, expert discovery in this case has been delayed. The parties agreed to have i
the plaintiff disclose its expert on August 22, 2003 and the plaintiff provided a supplemental
expert report on October 6, 2003. Plaintiffs depositions of several non-party witnesses were put
on hold pending the result of a conference with H. James Pickerstein, Esq., the Special Master
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1 Case 3:02-cv-02237-MRK Document 22 Filed 10/29/2003 Page 2 of 2 N
' assigned to this case. Plaintiff is currently negotiating with the nonparty regarding the i
scheduling of these depositions. Defendant deposed plaintiff s expert on October 27, 2003.
This is the only extension of the scheduling order that the parties have sought and the
only extension that the parties expect to request.
WHEREFORE, the parties jointly request that the Court extend the scheduling order
deadlines as described above. I
PLAINTIFF, DEFENDANT,
TRILEGIANT CORPORATION BP PRODUCTS NORTH AMERICA INC.
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By: W By: &
Rob rt . Dolian. (ct04278) Steven M. Green ct00380) *
Karen L. Allison (ct21849) Brian D. Porch, Jr. (ct236500)
Four Stamford Plaza One Canterbury Green
107 Elm Street Stamford, CT 06901-2047 (
Stamford, CT 06902 (203) 977—7300
(203) 327-1700 Its Attorneys
Its Attorneys
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