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

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I " Case 3:00-cv-00706—€BU Document 80 Filed 10/10/2003 Page 1 of 3
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I UNITED STATES DISTRICT counr t? f>: r JOY I g ~ I ly
I DISTRICT OF CONNECTICUT H I
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I BROADWAY THEATRE CORP. ) iqji 9 -- _
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I V. ) CIVIL ACTION NO: 300—CV00706 (SRU)
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BUENA VISTA PICTURES )
DISTRIBUTION, ET AL. ) OCTOBER 10, 2003
MOTION TO EXTEND TIME FOR DISCOVERY I
The Plaintiff; Broadway Theatre Corporation, respectfully asks this Court to extend the I
time limit for the Plaintiff to pursue discovery with requests for answers to interrogatories I
and requests for the production of documents. i
The closing date for discovery of these matters was May 31, 2001. A single request I
for the production of documents, with document dates no later than January 31, 2001 ,
was served on the 12 Defendants. No interrogatories have been answered beyond 14
questions posed on March 01, 2001. There has been minimal burden, and no continuing
burden, for the production of evidence placed upon the 12 Defendants or their counsel.
More than two and one-half years have passed since the closing date. Many deadlines
have been extended, far beyond the trial readiness schedule anticipated in 2000. Many
new questions have been raised, and many new facts and actions have transpired. The



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. Case 3:00-cv-00706—§Fi)U Document 80 Filed 10/10/6033 Page 2 of 3
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i information sought by the Plaintiff was suiiicient within the 2001 time frame, but is now
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l necessarily out of date. `
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This Court may have recognized these needs in the June 25, 2003, REVISED FORM '
26 F REPORT OF PARTIES PLANNING MEETING order. The Court stipulated: i
"Al1 discovery shall be completed by November 14, 2003.” This Motion, if granted, 1
therefore satisiies both the Order of this Court, and the requirement of Rule 33 of the \
Federal Rules of Civil Procedure that the Defendants will have, at minimum, thirty days to
serve their answers or objections.
No discovery by interrogatory is contemplated by the plaintiff beyond the single set of i
25 interrogatories. The interrogatories are identical for each ofthe 12 Defendants. The T
intended request for production of documents will present no surprise to the Defendants; I
it is precisely the same single request made in 2001, but updated from the January 31, -
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2001 closing date.
The Plaintiff respectfully asks this Court to grant this Motion. 1
THE PLAINTIFF I
Broadway Theatre Corporation '
By I U UL"
Peter spodick (ci www QJ 5*1 I
592 Central Avenue
New Haven, Connecticut 065 I5
203 387 5714
203 389 5732 (fax)

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I . Case 3:00-cv-00706-8RIU Document 80 Filed 10/10/69513 Page 3 of 3
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I CERTIFICATION OF SERVICE
The defendant certifies that a copy of this Motion was sent this day, October 10, 2003, I
postpaid, by iirst-class mail,t0 the Defendants: I
Richard Bowerman, Esq. I
205 Church Street
New Haven, Connecticut I
06510 I
The pantie
By; U uc my 4;. I
Peter C. Spodick I
592 Central Avenue _
New Haven, I
Connecticut
06515
203 387 5714 I
203 389 5732 (fax)
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