Free Motion for Order - District Court of Connecticut - Connecticut

Case 3:02-cv-02200-CFD

Document 110

Filed 05/25/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT CARLOS A. ARREDONDO, in his capacity as Trustee of The 2000 Trust for the Grandchildren of Carlos A. Arredondo and Mari V. Arredondo, General Partner of Arredondo Properties Limited Partnership, Plaintiff, CIVIL ACTION FILE v. NO. 3:02 CV 2200 (CFD) CAESAR A. ARREDONDO, individually and in his capacity as Trustee of The 2000 Trust for the Grandchildren of Caesar A. Arredondo and Carolyn Abad Arredondo; THE 2000 TRUST FOR THE GRANDCHILDREN OF CAESAR A. ARREDONDO AND CAROLYN ABAD ARREDONDO, in its capacity as General Partner of Arredondo Properties Limited Partnership; and ARREDONDO & CO., LLC, Defendants. JOINT MOTION TO FILE DEFENDANTS' AMENDED EXHIBIT LIST AND PLAINTIFF'S AMENDED MOTION IN LIMINE Pursuant to the Court's May 9, 2007 Order granting the parties' joint motion to continue the hearing on the plaintiff's motion in limine, the parties hereby jointly move for an order allowing (1) Defendants to file Defendants' Amended Exhibit List and (2) Plaintiff to file Plaintiff's Amended Motion in Limine and Memorandum of Law in Support Thereof. In support of this motion, the parties state the following: 1. On December 16, 2005, the parties submitted their Joint Trial Memorandum in May 25, 2007

accordance with the Trial Memorandum Order entered by the Court. ORAL ARGUMENT NOT REQUESTED

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2.

After filing the Joint Trial Memorandum, the parties realized that, due to a

miscommunication between counsel, the Defendants' Exhibit List and objections thereto submitted with the Joint Trial Memorandum was an incorrect version that omitted several of the Defendants' proposed exhibits and included the wrong number for others. 3. Accordingly, the Plaintiff's Motion In Limine that was submitted as part of the

Joint Trial Memorandum contained references to exhibit numbers from the incorrect Exhibit List. 4. On May 3, 2007, the parties jointly moved for a continuance of the May 11

hearing on the Plaintiff's Motion in Limine. By that motion, the parties also sought permission for the Plaintiff to submit an Amended Motion in Limine and the Defendants to submit an Amended Defendants' Exhibit List by May 25, 2007, and the Defendants' to submit an Opposition Memorandum by June 22, 2007. 5. The parties have now rectified the mistakes in the Defendant's Exhibit List and in

the Plaintiff's Motion In Limine, and hereby request that they be allowed to file (1) Defendant's Amended Exhibit List and (2) Plaintiff's Amended Motion In Limine and Memorandum in Support Thereof, copies of which are attached hereto as Exhibit A and B, respectively. WHEREFORE, the parties jointly move for an order allowing Defendant to file Defendant's Amended Exhibit List and Plaintiff to file Plaintiff's Amended Motion in Limine and Memorandum in Support Thereof. Respectfully submitted, this 25th day of May, 2007.

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Filed 05/25/2007

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/s/ Martin J. Elgison ROBERT P. DOLIAN (ct04278) CUMMINGS & LOCKWOOD LLC Four Stamford Plaza, P.O. Box 120 Stamford, Connecticut 06904-0120 Ph (203)327-1700; Fx (203) 708-5647 MARTIN J. ELGISON (ct24759) DAVID J. STEWART (ct24757) JASON D. ROSENBERG (phv01770) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309-3424 Ph (404) 881-7000; Fx (404) 881-7777 Counsel for Plaintiff /s/ Edward J. Heath CRAIG A. RAABE (CT04116) EDWARD J. HEATH (CT20292) Robinson & Cole, LLP 280 Trumbull Street Hartford, CT 06103 Phone: (860) 275-8200 Facsimile: (860) 275-8299 [email protected] [email protected] HUBERT J. SANTOS (CT00069) Santos & Steeley, P.C. 51 Russ Street Hartford, CT 06106 Phone: (860) 249-6548 DAVID M. KELLY, pro hac vice Finnegan, Henderson, Farabow, Garrett & Dunner, LLP 1300 I Street, NW Washington, DC 20005-3315 Phone: (202) 408-4000 Counsel for Defendants

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