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

Case 3:03-cv-00973-DJS

Document 23

Filed 02/18/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT LISA TILUM Plaintiff, VS. STATE OF CONNECTICUT, DEPARTMENT OF TRANSPORTATION Defendant : : : : : : : CIVIL NO. 3:03CV0973(DJS)

February 18, 2004

DEFENDANT'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO PLAINTIFF'S REQUESTS FOR ADMISSION COMES NOW the defendant State of Connecticut, Department of Transportation, and pursuant to Local Rule 7(b), hereby request permission to request an enlargement of time up to and including March 31, 2003, in which to file its responses to plaintiff's First Set of Requests for Admission. In support of this motion, the defendant represents as follows: 1. 2. Plaintiff filed her Requests for Admission on or about December 30, 2003. The undersigned forwarded the requests to a representative at the defendant

Department of Transportation on or about December 31, 2003. 3. Plaintiff's requests for admission include 53 paragraphs which deal with many

complex issues and additional time and resources are required to research the matters in order to properly respond.

Case 3:03-cv-00973-DJS

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Filed 02/18/2004

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4.

The undersigned has accepted a position as Labor and Employment Attorney with

Central Connecticut State University and his last day with the Office of the Attorney General's Employment Rights Department is Thursday, February 19, 2004. 5. The above-captioned matter has yet to be reassigned within the Employment

Rights Department and whichever counsel is assigned is going to require time in which to become familiar with the particulars in this case. 6. Pursuant to Local Rule 7(b), the undersigned attempted to contact plaintiff's

counsel, Kathleen Eldergill, Esq., by leaving an e-mail message. Upon information and belief, plaintiff's counsel is away from office and consequently the undersigned could not ascertain her position to this motion. 7. responses. WHEREFORE, the defendant respectfully requests permission to file its responses up to and including March 31, 2004 to plaintiff's First Set of Requests for Admission. This is the defendant's first request for additional time in which to file its

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Case 3:03-cv-00973-DJS

Document 23

Filed 02/18/2004

Page 3 of 3

DEFENDANT, STATE OF CONNECTICUT, DEPARTMENT OF TRANSPORTATION RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:________________________________ Stephen J. Courtney Assistant Attorney General Federal Bar No. ct11650 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel.: (860) 808-5340 Fax.: (860) 808-5383 E-mail: [email protected]

CERTIFICATION I hereby certify that a copy of the foregoing Motion for Enlargement of Time to File Responses to Plaintiff's Requests for Admission was sent by United States first class mail, postage prepaid, this 18th day of February, 2004, to: Kathleen Eldergill, Esq. Beck & Eldergill, P.C. 447 Center Street Manchester, CT 06040 Tel.: (860) 646-5606

____________________________________ Stephen J. Courtney Assistant Attorney General

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