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

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` . }{y¤O21965AWT Document 36 Filed 05/18f2005 Page 1 of 4
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I I g UNITED STATES DISTRICT COURT » =` ‘-
_ DISTRICT OF CONNECTICUT E
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FRANK C. SOMOHANO, SR. : CIVIL NO.: 3:02cv02196(B·%) l
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i PLAINTIFF ; I
» vs. S
UNITED STATES OF AMERICA Q
, : MAY 17, 2005
DEFENDANT :
I MOTION FOR EXTENSION OF TIME TO COMPLETE DISCOVERY
1. The plaintiff, Frank C. Somohano, Sr. hereby moves for an extension of time
to and including August 16, 2005 to complete Discovery for the following reasons.
2. ln August, 2004, counselfor the parties jointly requested the Court to assign
the case for mediation and since they have engaged in only limited discovery.
3. On February 3, 2005 the Court granted a previous extension of time until
April 15, 2005 to complete Discovery, which motion was consented by the {
government. At that time the parties were still engaged in mediation.
4. On April 25, 2005 a final mediation session was held but was unsuccessful in
settling the case.
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S ase 3:02-cv-O219€—»%WT Document 36 Filed 05/1 E3/$005 Page 2 of 4
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[ 5. The Plaintiff has recently engaged two medical expert witnesses and needs /
[ additional time to disclose said expert witness is as well as to pose additional [
interrogatories, in response to documents recently provided by the government. i
6. The government, through its attorney, Lauren Nash, does not consent.
THE PLAINTIFF,
FRANK C. SOIVIOHANO, SR.
Kenneth E. Lenz, Hi orney
Federal Bar #: ct064‘l9 y
The Lenz Law Firm, L.L.C. ,
35 Old Tavern Rd., P.O. Box 965
Orange, CT 06477-0965
Tel.: (203) 891-9800
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I ase 3:02-cv-02196-AWT Document 36 Filed 05/18/2)OO5 Page 3 of 4 j
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l ‘ - CERTIFICATION OF SERVICE l {
I The foregoing was served this 17"‘ day of May, 2005 upon the following via T
I first class mail:
Lauren Nash
Assistant U.S. Attorney
Connecticut Financial Center
` 157 Church Street
P.O. Box 1824
New Haven, CT 06508
Attorney Cynthia L. Tyler
Dept. of Veterans Affairs y
555 Willard Avenue
Newington, CT 06111 _
Ke th E. Lenz - {
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4 ase 3*02-cv-O2196=AWT Document 36 Filed 05/1{8/QOO5 Page 4 of 4
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/ - UNlTED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
4 FRANK C. SOMOHANO, SR. : CIVIL NO.: 3:02cv02196(GLG)
i=·i.Am·rn=i= 2
vs. E 4
UNITED STATES OF AMERICA 4
: MAY 17, 2005
DEFENDANT ; I
- ORDER RE: LEAVE TO F'|LE MOTION FOR EXTENSION OF TIME
TO RESPOND TO COMPLETE DISCOVERY
The plaintiffs motion for extension of time to complete discovery to August 4
16, 2005 having come before this court after due service upon the United States
and cause having been shown, it is accordingly, ORDERED:
The motion is hereby GRANTED / DENIED
4 BY THE COURT
Alvin W. Thompson, Judge
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