Schieffelin et al v. QVC, Inc

Filing 9

Joint MOTION for Extension of Time until June 5, 2007 and June 15, 2007 respectively to Hold Rule 26(f) conference and file Form 26(f) by Stacey Schieffelin, David Schieffelin, Models Prefer Ltd, QVC, Inc. (Dubitsky, Doug)

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Schieffelin et al v. QVC, Inc Doc. 9 Case 3:07-cv-00445-VLB Document 9 Filed 05/01/2007 Page 1 of 3 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT STACEY AND DAVID SCHIEFFELIN and MODELS PREFER, LTD., Plaintiffs, v. QVC, INC, Defendant. ) ) ) ) ) ) ) ) ) Civil Action No. 07cv00445 (SRU) MAY 1, 2007 JOINT MOTION FOR EXTENSION OF TIME TO HOLD RULE 26(F) CONFERENCE AND FILE FORM 26(F) Plaintiffs, Stacey and David Schieffelin and Models Prefer, LTD. ("Plaintiffs"), and Defendant, QVC, Inc, ("Defendant") hereby jointly move for an extension of time of thirty (30) days, to and including June 5, 2007, to confer pursuant to Fed. R. Civ. P. Rule 26(f), and a concomitant extension of time of thirty (30) days, to and including June 15, 2007, to file their report on Form 26(f). In support of this Motion, counsel for the Plaintiffs and the Defendant state that the Defendant has waived service of process pursuant to Fed. R. Civ. P. 4(d), and that pursuant to the Court's Order on Pretrial Deadlines, the Defendant's Motion to Dismiss is due on June 21, 2007. The parties do not anticipate the need to commence discovery before the Defendant's Motion to Dismiss is filed, and the parties need the additional time to consult with 470340 Dockets.Justia.com Case 3:07-cv-00445-VLB Document 9 Filed 05/01/2007 Page 2 of 3 counsel as to the best and most efficient way to advance this litigation.. This is the first motion for extension of time filed by the parties with regard to this deadline. Respectfully submitted, PLAINTIFFS, STACEY AND DAVID SCHIEFFELIN and MODELS PREFER, LTD By:__/S/_ Eliot B. Gersten __ ELIOT B. GERSTEN, ESQ. Federal Bar No. ct05213 GERSTEN CLIFFORD & ROME , LLP 214 Main Street Hartford, CT 06106-188 Tel. 860-527-7044 Fax 860-527-4968 egersten@gcrlaw.net DEFENDANT, QVC, INC. By:__/S/_Doug Dubitsky__ DOUG DUBITSKY, ESQ. Federal Bar No. ct21558 UPDIKE, KELLY & SPELLACY, PC One State Street, P.O. Box 231277 Hartford, CT 06123-1277 Tel. 860-548-2600 Fax 860-548-2680 ddubitsky@uks.com 470340 Case 3:07-cv-00445-VLB Document 9 Filed 05/01/2007 Page 3 of 3 THIS IS TO CERTIFY that on May 1, 2007 a copy of the foregoing Motion was electronically filed. Notice of this filing will be sent via email to all parties by operation of the Court's electronic filing system. The undersigned did cause to be sent, by U.S. Mail, first-class, postage prepaid, a copy of the foregoing to all counsel and pro-se parties that do not have access to the Court's electronic filing system. _/S/_Doug Dubitsky Doug Dubitsky, Esq. Updike, Kelly & Spellacy, P.C. 470340

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