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

E Case 3:02-cv-02187-WWE Document 41 Filed O1/12/(ZOBJ4 Page 1 of 3
I FILED
il Zlltlit JAN I 2 ID I2= L1 1
{ UNITED STATES DISTRICT COURT USBg:gg§;;CO1iR OCUTR T
1 DISTRICT OF CONNECTICUT i
In CAROL TRELOAR, ADMX OF THE
ESTATE OF KENNETH TRELOAR, i
i PLAINTIFF CIVIL ACTION
i NO: 3:02CV2187(WWE)
VS
EUCLID-HITACHI HEAVY EQUIPMENT,
` DEFENDANT IANUARY 9, 2004
i MOTION FOR ENLARGEMENT OF TIME
Pursuant to Rule 6 of the Federal Rule of Civil Procedure and Rule 9(b) of the Local Rule \
of Civil Procedure, the plaintiff, Carol Treloar, Administratrix of the Estate of Kenneth Treloar, i
hereby moves this court for an extension of time up to and including March I0, 2004 within
which to disclose an additional expert.
The reason for this motion is that the plaintiff, despite due diligence, requires additional
time to retain an additional expert. On September 30, 2003, the plaintiff previously disclosed [
Douglas M. Brooks. P.C. as her expert. It was anticipated that Mr. Brooks would be the sole
expert for the plaintiff. However, Mr. Brooks was deposed by the defendant on October 23,
2003 and as a result of that testimony it became necessary for the plaintiff to retain a
biomechanical engineer in addition to the expertise of Mr. Brooks, a physical engineer. Such an g
expert has been retained and is currently reviewing all relevant materials in this action. A
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· Case 3:02-cv-02187-WWE Document 41 Filed O1/12é®4 Page 2 of 3 I I
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biomechanical engineer expert is necessary to the plaintiff in this complicated wrongful death
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; action which was filed with this Court on December 11, 2002. 1
I The undersigned has contacted Attorney Carl Picks of Halloran & Sage, attorney for {
l Tilcon the intervening plaintiff, who indicated that he has no objection to this motion. I
Q The undersigned has contacted Attorney Iason Kuselias of Robinson & Cole, attorney for
l the defendant, Euclid-Hitachi Heav E ui ment, Inc., who indicated that he ob`ects to this
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motion. y
PLAINTIFF, CA L TRELOAR {
BY
bert Carocci A
Fed Bar No 05041 l
DONALD G. WALSH, P.C. ¤
169 Olive Street
New Haven, CT 06511
Tel. (203) '7'72-3230
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- Case.3:O2-cv-02187-WWE Document 41 Filed O1/12/@@4 Page 3 of 3
This is to certify that on Ianuary 9, 2004 a copy of the foregoing was mailed to: 1
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5 Attorney Iason Kuselias l
l ROBINSON & COLE
I 280 Trumbull Street
Hartford, CT 06103—3597
Attorney Brien P. Horan
1 ` ROBINSON & COLE
280 Trumbull Street
Hartford, CT 06103-3597
Attorney Carl Picks, ]r.
HALLORAN & SAGE
One Goodwin Square y
225 Asylum Street |
Hartford, CT 06103.
J
Albert Carocci l
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