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

Case 3:03-cv-01045-WWE

Document 10

Filed 02/12/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WILLIAM LAPUT Plaintiff, v. LARKIN ENTERPRISES INC. Defendant. : : : : : : : : :

CIVIL ACTION NO. 3:03CV1045(WWE)

FEBRUARY 10, 2004

MOTION FOR EXTENSION OF TIME

The Plaintiff, William Laput, ("Plaintiff Laput"), pursuant to Local Rule of Civil Procedure 7(b) hereby requests an extension of time of two (2) weeks from February 14, 2004 up to and including March 1, 2004, to respond to the Defendant, Larkin Enterprises, Inc.'s ("Defendant Larkin") Second Set of Interrogatories dated January 14, 2004 and Second Request for Production dated January 14, 2004. In support hereof Plaintiff Laput represents as follows: 1. On February 9, 2004 Plaintiff's counsel Michael Satti underwent a spinal fusion and removal of a cervical disc and will be unable to work for approximately two (2) weeks and is prohibited from driving for one (1) month. 2. As a result of the undersigned is attempting to cover both Attorney Satti's and her files in his absence and this extension is necessary to enable her to properly respond to the discovery requests. ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-01045-WWE

Document 10

Filed 02/12/2004

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3. On February 9, 2004, the office of the Plaintiff's counsel contacted Attorney Jacques, counsel for Defendant Larkin who stated that he consents to the requested extensions of time in light of the aforementioned surgery and post surgery recuperation. 4. Plaintiff's counsel has not sought any prior extension of time to respond to the Second Set of Interrogatories and Requests for Production. WHEREFORE, the Plaintiff, William Laput, respectfully requests an additional extension up to and including March 1, 2004, to respond to the Defendant's Second Set of Interrogatories and Defendant's Second Requests for Production.

THE PLAINTIFF, WILLIAM LAPUT

By:________________________ Holly Quackenbush Darin Michael E. Satti Satti & Satti, P.C. 225 State Street, Suite 200 New London, CT 06320 (860) 447-8975 Juris No. 418059 -His AttorneysCERTIFICATION The undersigned hereby certifies that the foregoing has been mailed first class postage prepaid, this 10th day of February, 2003 to all counsel and pro se parties of record as listed below: Bernard E. Jacques Pepe & Hazard, LLP 225 Asylum Street Hartford, CT 06103-4302 ______________________ Holly Quackenbush Darin

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Case 3:03-cv-01045-WWE

Document 10

Filed 02/12/2004

Page 3 of 3

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