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

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. Case SZO3-CV-OO63Q®DJS Document 70 Filed 03/055004 Page 1 of 3 {
UNITED STATES DISTRICT COURT i
DISTRICT OF CONNECTICUT _
MARIO RICHARDS, :
on behalf of himself and : CIVIL ACTION NO.
all others similarly situated : 3:03 CV00630 (DJS);_,;
PLAINTIFFS, : ; ~ » _
: is -0 .r
COMPUTER SCIENCES : tj
CORPORATION : MARCH 8, _,;. =Z.Q..J
DEFENDANT. Z 3*
PLAIN'l`IFF’S MOTION FOR ENLARGEMENT OF TIME TO COMPLETE
DISCOVERY AND MODIFICATION OF SCEDULING ORDER
Plaintiii Mario Richards, requests pursuant to Local Rule 7 (b) that the court
grant an enlargement of time to May 9, 2004 within which to complete discovery in this
matter. This is the second request for enlargement of discovery in this matter. The court
previously extended discovery to March 9, 2004, pursuant to the defendant’s request. I
Procedural Background
The plaintiiii Mario Richards, commenced this action on April 7, 2003 pursuant l
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to the Fair Labor Standards Act, 29 U.S.C. 201 et seq. (FLSA), claiming wages for
overtime hours worked in excess of forty hours per week. The parties filed a Rule 26 (i)
report and a scheduling order was entered by the court (D. Squatrito, J .). Discovery was
previously extended from January 7, 2004 to March 9, 2004 in this matter.
Reason for Reguest
Counsel for the parties each have motions to compel pending pertaining to
discovery requests. Plaintiff would like an opportunity to review discovery compliance


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N . Case 3:03-cv—0O63 CERTIFICATION
I hereby certiiy that a copy ofthe foregoing was mailed on V0 7
To:
- Tasos C. Paindiris, Esq.
William Anthony, Esq.
Jackson Lewis
55 Farmington Avenue
Suite 1200
I-Iartfrod, Ct 06105 Z {
Michael . MeI§
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Case 3:03-cv—0O63Qi|3/US Document 70 Filed 03/qglgf)04 Page 3 of 3 {
, and seek additional information and materials which are shown to exist as a result of
future discovery compliance by the defendant, which may be ordered by the court.
Further, plaintiff` maintains that there is infomnation and materials outstanding relative to
a second request for production served on the defendant. Plaintiff would like an
opportunity to receive and review r·esponse(s) to such discovery requests.
Opposing Counsel Takes No Positipg
Opposing counsel, Tasos Paindiris, does not take a position regarding this request.
Plaintiff;
Mario Richards
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Michael J. Me
Fed. Bar No. l784l -
143 Oneco enue # 4 L
Tel: (860) 47-1990 F
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