Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:02-cv-02200-CFD

Document 108

Filed 05/03/2007

Page 1 of 4

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, v. 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. MAY 3, 2007 CIVIL ACTION NO.: 3:02 CV 02200 (CFD)

JOINT MOTION FOR CONTINUANCE OF HEARING ON THE PLAINTIFF'S MOTION IN LIMINE The parties hereby jointly move for a continuance of the May 11, 2007 hearing on the Plaintiff's Motion in Limine. In support of this motion, the parties state the following. 1. On January 22, 2007, the Court issued an order scheduling this matter for a bench

trial to begin on June 11, 2007. The Court thus set a pretrial conference thirty days beforehand, on May 11, 2007, at which time, among other things, pretrial motions would be addressed. 2. Thereafter, the Court conducted a telephonic status conference with the parties to

advise that due to scheduling conflicts created by two criminal cases, the trial of this matter would not begin as scheduled in June, and likely would not proceed until at least September 2007.

Case 3:02-cv-02200-CFD

Document 108

Filed 05/03/2007

Page 2 of 4

3.

During that telephonic status conference, the Court and the parties discussed

proceeding on May 11, 2007 with oral argument on the Motion in Limine that the Plaintiff had appended to the parties' Joint Trial Memorandum, which was filed on December 16, 2005. 4. Following that conference, the parties further discussed the Motion in Limine and

determined that to correct a miscommunication that had occurred when the Joint Trial Memorandum was filed in December 2005, the Defendants intend to submit an Amended Exhibit List and the Plaintiff intends to submit a superseding Motion in Limine and supporting Memorandum of Law. 5. The Plaintiff expects that its superseding Motion in Limine and supporting

Memorandum of Law will be filed by May 25, 2007. The Defendants expect that their Opposition Memorandum will then be filed by June 22, 2007. The Plaintiff reserves its right to file a Reply within ten days thereafter. 6. In the interests of judicial economy, the parties request that they be permitted until

June 22, 2007 to propose multiple dates in August 2007 to conduct the hearing on the Plaintiff's Motion in Limine. 7. This is the parties' first request for a continuance of this hearing.

WHEREFORE, the parties jointly move for a continuance of the May 11, 2007 hearing on the Plaintiff's Motion in Limine, and further move that they be permitted until June 22, 2007 to propose multiple dates in August 2007 to conduct the hearing on that Motion.

2

Case 3:02-cv-02200-CFD

Document 108

Filed 05/03/2007

Page 3 of 4

/s/ Robert P. Dolian ROBERT P. DOLIAN (ct04278) CUMMINGS & LOCKWOOD LLC Four Stamford Plaza, P.O. Box 120 Stamford, Connecticut 06904-0120 Ph (203)327-1700; Fax (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; Fax (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 & Seeley, 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 3

Case 3:02-cv-02200-CFD

Document 108

Filed 05/03/2007

Page 4 of 4

ORDER The foregoing motion having been presented to the Court, it is hereby ordered GRANTED/DENIED on this day of , 2007. BY THE COURT ________________________________ Judge/Clerk

4