Arredondo v. Arredondo, et alMOTION for Extension of Time until 11/21/05 to file Joint Trial MemorandumD. Conn.November 7, 2005IN 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. CIVIL ACTION FILE NO. 3:02 CV 2200 (CFD) 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. November 7, 2005 PLAINTIFF’S UNOPPOSED MOTION TO EXTEND THE TIME TO SUBMIT THE JOINT TRIAL MEMORANDUM Pursuant to Fed. R. Civ. P. 6(b)(1), Plaintiff respectfully move the Court for an extension of time up to and including November 21, 2005, for the parties to file their joint Trial Memorandum. The Trial Memorandum is currently due on November 7, 2005. This deadline has not been previously extended, and the fourteen (14) additional days requested will not affect any other deadlines in this case. Defendant has been consulted, and they consent to the proposed extension. Plaintiff submits that the additional time requested herein is needed to prepare a full and complete response to the Court’s order. This request is not submitted for the purpose of delay, but rather so that justice may be served. The requested enlargement of time will not unduly delay the Court’s judgment in this matter. Case 3:02-cv-02200-CFD Document 88 Filed 11/07/2005 Page 1 of 3 - 2 - ATL01/12072965v1 Additionally, a consent motion was filed on November 2, 2005, notifying the Court that Plaintiff did not believe there were any issues triable by jury in this case. Because the format of the Trial Memorandum required by the Court differs in jury and non-jury trials, Plaintiff also requests the additional time to address these changes in the joint Trial Memorandum. Accordingly, Plaintiff respectfully requests the Court to enter and Order extending the parties’ time to file their joint Trial Memorandum up to and including November 21, 2005. ROBERT P. DOLIAN (ct04278) CUMMINGS & LOCKWOOD LLC Attorney for the Plaintiff Four Stamford Plaza, P.O. Box 120 Stamford, Connecticut 06904-0120 Ph (203)327-1700; Fx (203) 708-5647 MARTIN J. ELGISON (ct24759) DAVID J. STEWART (ct24757) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309-3424 Ph (404) 881-7000; Fx (404) 881-7777 Counsel for Plaintiff Case 3:02-cv-02200-CFD Document 88 Filed 11/07/2005 Page 2 of 3 - 3 - ATL01/12072965v1 CERTIFICATE OF SERVICE I certify that on this 7th day of November, 2005, a true and correct copy of the foregoing PLAINTIFF’S UNOPPOSED MOTION TO EXTEND THE TIME TO SUBMIT THE JOINT TRIAL MEMORANDUM was served by first class mail upon counsel for Defendants, by the manner indicated, addressed as follows: Craig A. Raabe ROBINSON & COLE LLP 280 Trumbull Street Hartford, CT 06103 ______________________________ Robert P. Dolian Plaintiff's Unopposed Motion To Extend The Time To Submit The Joint Trial Memorandum.doc 11/7/2005 Case 3:02-cv-02200-CFD Document 88 Filed 11/07/2005 Page 3 of 3
