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V Case 3:02-cv-01718-RNC Document 93 Filed 11/O4/2004 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT _
Joseph A. Schiavone Corporation Civil Action
Michael Schiavone, 2 No. 302 CV-1718 (RNC)
Plaintiffs
v.
Philip Kasdcn,
Northeast Utilities Service Company, and :
Connecticut Light and Power Company, :
Defendants : November 3, 2004
Plaintiffs’ Objection and Counter Proposal
to
NUSCO and CL&P’s Motion to Continue Scheduling Order
Plaintiffs Michael Schiavone and the Joseph A. Schiavone Corporation respectfully object
to the Defendants NUSCO and CL&P ’s Motion to Continue Scheduling Order dated November l,
2004, (the "Motion to Continue") to the extent that it seeks a continuance of all deadlines in this
matter for a period of three months from the deadlines established in the Scheduling Order of
September 2, 2004.*
Plaintiffs wish a speedy recovery to Charles Nicol, Esq. who underwent emergency heart
bypass surgery on November l, 2004. However, plaintiffs do not believe that this matter should be
' By motion dated October I5, 2004 the parties filed The Parties ’JointMotion to Modmz the
Order on Pretrial Deadlines in which the parties sought to extend the pretrial deadlines for a period
of seven days from the deadlines established in the Order of September 2, 2004.

i Case 3:02-cv-01718-RNC Document 93 Filed 11/O4/2004 Page 2 of 4
stayed or delayed until Mr. Nicol has recovered, since it is difficult to know when he will be able to
return to full active-duty in any capacity as attorney defending this matter. We recall that when our
partner had a similar operation he returned to duty in three months, but was not at full capacity for
a period of time thereafter.
Plaintiffs should not have this case delayed any longer than is necessary for other appearing
counsel for NUSCO and CL&P to come up to speed in representing the interests of NUSCO and
CL&P.
Plaintiffs have already re-noticed the deposition of Ms. Muriel Robinette for November 17,
2004 and, in advance of the scheduling conference call on November 16, 2004, propose the
following new deadlines:
Deadline Date Proposed on New Proposed
October 15, 2004 Date
Completion of All Discovery May 3, 2005 June 3, 2005
Depositions of Defendants’ Experts November 2, 2004 November 17,
2004
Plaintiffs ’ Rebuttal Expert Disclosure and Reports November 30, December 17,
2004 2004
Depositions of P1aintiffs’ Rebuttal Experts January 26, 2005 February 25,
2005
Defendants’ Rebuttal Expert Disclosure and Reports February 25, 2005 March 28, 2005
Deposition of Defendants’ Rebuttal Experts April 26, 2005 May 27, 2005
Joint Trial Memorandum May 27, 2005 June 20, 2005
Trial ready list June 2005 August 2005
Mediation Session November 3, 2004 December 21,
2004
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I Case 3:02-cv-01718-RNC Document 93 Filed 11/O4/2004 Page 3 of 4
If one includes the Motion to Continue, this is the seventh request to extend the pretrial
deadlines in this case. This schedule has not been discussed with counsel for NUSCO and CL&P.
Respectfully submitted,
Joseph A. Schiavone Corporation, and
Michael Schiavone
Plaintiffs
pclbié/L 'E ¢4·a.L..?
Nicholas J. Harding E
Federal Bar No. ct063 87
Kosloff & Harding gb
Their Attomeys
28 North Main Street
West Hartford, CT 06107
Tel; (860)52l—7004
Fax: (860) 521-3352
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_ Case 3:02-cv-01718-RNC Document 93 Filed 11/O4/2004 Page 4 of 4
Certificate of Service
I hereby certify that a copy ofthe above was mailed or delivered in hand on November 3,
2004 to all counsel and pro se parties of record as follows:
Connecticut Light and Power Company Charles J. Nicol, Esq.
Angela L. Ruggiero, Esq.
Northeast Utilities Service Company
P.O. Box 270
Hartford, CT 06141-0270
Tel: 665-3431 /665-3495
Fax: 665-5504
Northeast Utilities Service Company Charles J. Nicol, Esq.
Angela L. Ruggiero, Esq.
Duncan Ross MacKay, Esq.
Northeast Utilities Service Company
P.O. Box 270
Hartford, CT 06141 -0270
Tel: 665-3431 /665-3495
Fax: 665-5504
l lg/Le Z »/4a LQ
7
Nicholas J. Harding <
E)
Filing Location:
Office of the Clerk
U.S. District Court
450 Main Street
Hartford, CT 06103
F \WPDOCS\Schi¤vone\PCB 2057 l l\Fcd Plcadings\ObjccLion to Motion to Continue wpd
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