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

- ‘ Case 3:02-cv-01718-RNC Document 76 Filed 05/21@OO4 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
Joseph A. Schiavone Corporation Civil Action
Michael Schiavone, : No. 302 CV—1718 (RNC)
Plaintiffs
Philip Kasden
Northeast Utilities Service Company, :
Connecticut Light and Power Company :
Defendants May 20, 2004
Motion For Extension Of Time In Which To File:
Stipulation Of Fact In Resolution of Discovery Dispute
Oral argument on plaintiff s Motion For Order Compelling Discovery from the defendant
CL&P was held before the Honorable Donna F. Martinez on May 3, 2003. In the course of oral
argument it was agreed that Interrogatory #1 and Production Requests #2 and #4 are withdrawn
without prejudice to allow counsel to discuss a stipulation of fact that would resolve the dispute over
those requests. A deadline of May 21, 2004 was set for submission of the stipulation. Due mainly
to a trial schedule in another matter (which has run on longer than anticipated), counsel were not able
to discuss and agree on a stipulation.
Therefore, counsel for the plaintiffs, with the agreement of defendants’ counsel, respectfully

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requests an additional two weeks, up to and including June 3'd, 2004, in which to file the stipulation.
Respectfully submitted,
Joseph A. Schiavone Corporation, and
Michael Schiavone
Plaintiffs
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Nicholas J. Harding
Federal Bar No. ct06387
Kos1off& Harding
Their Attorneys
28 North Main Street
West Hartford, CT 06107
Tel: (860)52l-7004
Fax: (860) 521-3352
F:\WPDOCS\Schiavone\P(`B 2057 1 l\Fed P1eadings\MotiunForExtRcDiscove1yStip.wpd
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Certificate 0f Service
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I hereby certify that a copy of the above was mailed or delivered in hand on May }¢€ 2004
to all counsel and pro se parties of record as follows:
Connecticut Light and Power Company Charles J. Nicol, Esq.
Northeast Utilities Service Company 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
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T/gpx; 3-/LDL.
Nicholas J. Harding 5
Filing Location:
Office of the Clerk
U.S. District Court
450 Main Street
Hartford, CT 06103