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

Case 3:03-cv—01045-WWE Document 18 Filed 05/28/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WILLIAM LAPUT, ) CIVIL ACTION NO.
)
Plaintiff ) 3:03CVI045 (WWE)
)
v. )
)
LARKIN ENTERPRISES, INC., ) ,
)
Defendant ) MAY 30, 2004
MOTION FOR EXTENSION OF TIME T0 RESPOND TO PLAINTIFF’S FIRST ‘ T -
SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS I _
Defendant, Larkin Enterprises, Inc., by and through the undersigned counsel, ·
hereby respectfully requests an extension of time in the amount of ten (10) days, through
and including June 10, 2004, to respond to Plaintiffs First Set of Requests for T . -
Production. As grounds for this request, Defendant states as follows:
1. The information and materials needed to respond are still being gathered, I P
and therefore, proper and adequate responses are not possible at this time. P
2. This is Defendant’s second request for an extension of time in regard to this ~
deadline. (

Case 3:03-cv—01045-WWE Document 18 Filed 05/28/2004 Page 2 of 3
3. P1aintiff’s counsel has no objection to this Motion.
WHEREFORE, Defendant respectfully requests that this motion be granted.
DEFENDANT:
LARKIN ENTERPRISES, INC.
By V
I Bernard E. Ja ques., of
Pepe & Hazard LLP · .
Federal Bar No.: ctl2293 I ‘
Its Attorneys "
. · ‘ I 225 Asylum Street I
I s E - I Hartford, CT 06103-4302 I ¥
Telephone No.: (860) 522-5175 .
Fax No.: (860) 522-2796 I
E-mail: [email protected]
2
BE]/32497R/67666OV] ‘
' osrzs/04-mm

Case 3:03-cv—01045-WWE Document 18 Filed 05/28/2004 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing has been mailed, postage prepaid,
this 28* day of May, 2004 to all counsel and parties of record as follows:
Counsel for Plaintiff:
Michael E. Satti
Holly Quackenbush Darin
_ _ Sam & Satti _
_ I 225 State Street — Suite 200 _ I · 3
g p New London, CT 06320 ` ‘ ‘ I
2 Bernard E. Jacq es
3
Bs11s2497rz/616660vi
i os/za/04-arm l