SANDLER v. CALCAGNI et al

Filing 45

Unopposed MOTION to Extend Time through September 24, 2007 for Initial Disclosure by RALPH CALCAGNI, MAUREEN CALCAGNI, MIA CALCAGNI.Responses due by 9/28/2007. (CHAIKEN, PAUL)

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SANDLER v. CALCAGNI et al Doc. 4 UNITED STATES DISTRICT COURT DISTRICT OF MAINE SHANA SANDLER, Plaintiff v. MIA CALCAGNI, RALPH CALCAGNI, MAUREEN CALCAGNI, PETER MARS, and BOOKSURGE, LLC, Defendants ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07-CV-00029-GZS DEFENDANTS RALPH CALCAGNI, MAUREEN CALCAGNI AND MIA CALCAGNI'S MOTION TO ENLARGE DEADLINE TO SUBMIT INITIAL DISCLOSURE Paul W. Chaiken, Esq., on behalf of Bruce C. Mallonee, Esq., counsel for Defendants Ralph Calcagni, Maureen Calcagni, and Mia Calcagni, moves for an enlargement of time for these Defendants to submit their initial disclosure. The present deadline is September 11, 2007. Mr. Mallonee has been the only attorney working on his case. He was called out of town on September 5, 2007 for a family medical emergency. He does not expect to return to the office until September 14, 2007, although that is extremely tentative. Upon his return, he will have to review documents recently received from the client, and then prepare the initial disclosure as required by F.Civ.P.26(a)(1). I have alerted counsel for the other parties to this request. None object. {R0394314.1 49252-053567} Dockets.Justia.com WHEREFORE, an order is sought enlarging the time for Defendants Calcagni to submit their initial disclosure to September 24, 2007. Dated: September 7, 2007 /s/ Paul W. Chaiken Paul W. Chaiken, Esq. RUDMAN & WINCHELL Attorney for Defendants Mia Calcagni, Ralph Calcagni, and Maureen Calcagni 84 Harlow Street, P.O. Box 1401 Bangor, Maine 04402-1401 Telephone: (207) 947-4501 pchaiken@rudman-winchell.com CERTIFICATE OF SERVICE I, Paul W. Chaiken, Esq., hereby certify that on September 7, 2007, I filed the foregoing Motion for Enlargement of Deadline to File Initial Disclosure with the Clerk of the United States District Court using the CM/ECF system , which will send notification electronically to the registered participants as identified on the Notice of Electronic Filing (NEF). /s/ Paul W. Chaiken Paul W. Chaiken, Esq. RUDMAN & WINCHELL Attorney for Defendants Mia Calcagni, Ralph Calcagni, and Maureen Calcagni 84 Harlow Street, P.O. Box 1401 Bangor, Maine 04402-1401 Telephone: (207) 947-4501 pchaiken@rudman-winchell.com {R0394314.1 49252-053567}