Subject: Connecticut — Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order Dear [Recipient's Name], I hope this letter finds you in good health. I am writing to submit a joint motion for the entry of a second amended scheduling order in the matter of [Case Name/Number]. In order to ensure smooth proceedings, we kindly request your cooperation and prompt action on this matter. As you are aware, the original scheduling order was established on [date] to set the timeline and deadlines for various stages of the litigation process. However, unforeseen circumstances have arisen that necessitate modifications to the existing order. This joint motion seeks to amend the scheduling order to reflect the changes required to accommodate both parties' schedules and ensure a fair and efficient resolution of the case. Attached to this letter, you will find a proposed second amended scheduling order that outlines the revised timeline and deadlines for the case. Our intention is to present an equitable and reasonable plan that takes into consideration the needs and constraints of both parties, and the court's availability and constraints. The proposed second amended scheduling order includes, but is not limited to: 1. Revised discovery deadlines: This outlines the revised dates for all discovery-related activities, such as the completion of written interrogatories, document production, and depositions for both plaintiff and defendant. 2. Expert witness deadlines: This section stipulates the dates by which each party must disclose their expert witnesses, exchange reports, and complete any related depositions or examinations. 3. Motion filing and hearing deadlines: We have adjusted the deadlines for filing any motions, briefs, or responses, as well as proposed dates for hearings and court appearances. 4. Pretrial conference and trial dates: Given the requested modifications, we have proposed new dates for the pretrial conference and the trial itself, considering the availability of all parties involved. It is essential that both parties promptly review the proposed second amended scheduling order and provide any necessary feedback or changes within [specified time frame], preferably through mutual consultation and negotiation. Our goal is to finalize the revised plan at the earliest convenience, avoiding unnecessary delays in the case. Please consider the importance of this matter and communicate your response by [deadline date]. We are confident that through collaboration and cooperation, we can achieve a mutually agreeable amended scheduling order that meets the needs of all parties involved. Thank you for your attention and prompt action in this regard. Should you have any questions or require further clarification, please do not hesitate to contact me directly at [your contact information]. Yours faithfully, [Your Name] [Your Title/Organization]
Connecticut Sample Letter for Joint Motion of Entry of Second Amended Scheduling Order
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FAQ
Rule 1.7 - Conflict of Interest: General Rule (a) Except as provided in paragraph (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest.
Motions for orders of compliance (or motions to compel, as they are frequently called) are governed by Section 13-14 of the Connecticut Practice Book. As in many jurisdictions, judges in Connecticut generally prefer that parties and their counsel resolve discovery disputes without the need for judicial intervention.
Rule 4.2 of the Rules of Professional Conduct provides that ?[i]n representing a client, a lawyer shall not communicate about the subject of the representation with a party the lawyer knows to be represented by another lawyer in the matter, unless the lawyer has the consent of the other lawyer or is authorized by law ...
Rule 1.10 - Imputation of Conflicts of Interest: General Rule (a) While lawyers are associated in a firm, none of them shall knowingly represent a client when any one of them practicing alone would be prohibited from doing so by Rules 1.7, 1.8(c), or 1.9, unless the prohibition is based on a personal interest of the ...
Rule 8.4(7) defines ?professional misconduct? by a Connecticut attorney as including speech that the lawyer knows or reasonably should know ?is harassment or discrimination on the basis of? any of 15 listed characteristics?among them race, sex, religion, disability, sexual orientation, and gender identity.
Rule 7.1. A lawyer shall not make a false or misleading communication about the lawyer or the lawyer's services.
Although it is prohibited to mix lawyer funds with client funds, Rule 1.15 of the Connecticut Rules of Professional Conduct permits a lawyer's own funds to be placed in a trust account for the sole purposes of paying financial institution service charges on the account or to obtain a waiver of fees and service charges ...
Regulatory Scheme: Connecticut Rule of Professional Conduct 7.4A permits attorneys to state or imply that they are certified specialists where certification is granted "by a board or other entity which is approved by the Rules Committee of the Superior Court." [Rule 7.4A].
