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

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N . · Case 3:03-cv-0096% IG Document 24 Filed 10/30/2003 Page 1 of 3 _
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N UNITED STATES DISTRICT COURT-,?;..N£5-ii¢§i-NU gt N
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N DISTRICT OF CONNECTICUT N
N THOMAS MATYASOVSZKY on behalf : N
N of himself and all other :
similarly situated : N
Plaintiff CIVIL ACTION NO. 3:03 CV 968 (RNC) N
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HOUSING AUTHORITY OF THE CITY
OF BRIDGEPORT, ET AL. ;
Defendants.
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAlNTIFF’S SECOND
REQUESTS FOR PRODUCTION
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The undersigned Defendants, Housing Authority of the City of Bridgeport, Collin Vice, N
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and Jonas DeGuzman, respectfully move this Court, pursuant to Fed. R. Civ. P. Rule 34 and
D. Conn. Loc. R. Civ. Rule 7 for a thirty day extension of time to respond to the Plaintiffs
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Second Requests for Production. The Plaintiffs Second Requests for Production was seived on
the Defendants on October I4, 2003 and consists of forty-one production requests. The
additional time is required to gather and review the requested information. The documents
requested by the Plaintiff are likely to be voluminous given that Plaintiff is seeking documents
I dating back to October 1999.
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J I U Case 3:03-cv—OO968€Vy IG Document 24 Filed 10/30<2303 Page 2 of 3
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In support of this motion, the undersigned represents that on October 28, 2003, he spoke, Q
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K via telephone, with Attorney Jennifer Vickeiy, cotmsel for the Plaintiff Attorney Vickery i
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indicated that she objects to an extension of time. This is the first motion for extension of time
the Defendants have tiled regarding the Plaintiff s Second Requests for Production dated October I
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14, 2003. i
WHEREFORE, the Defendants respectfully move that the Court allow an additional ’
thirty days to Monday, December 15, 2003 for the Defendants to respond to the Plaintiffs ‘
Second Requests for Production. I
THE DEFENDAN TS,
HOUSING AUTHORITY OF THE CITY OF I
BRIDGEPORT
James A. Mahar, Esq., (CT 21854)
Ryan, Ryan, Johnson & Deluca, LLP
80 Fourth Street, P.O. Box 3057
Stamford, CT 06905 |
Juris No. 52525
Phone No. 203-3 57-9200
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1 " ` I ` Case 3:03-cv—0096$?W IG Document 24 Filed 10/3062003 Page 3 of 3
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1 CERTIFICATE OF SERVICE ‘
J I hereby certify that on October , 2003, a copy of the above was mailed to the I
following counsel and pro se parties of record:
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Alan Rosner, Esq.
Law Offices of Alan Rosner
1115 Main Street, Suite 415 l
Bridgeport, CT 06604 1
Attorney for Plaintiff] Thomas Matyasovszky l
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Jennifer Vickery, Esq.
Law Offices of Alan Rosner
1115 Main Street, Suite 415 i
Bridgeport, CT 06604
Attorney for Plaintiff] Thomas Matyasovszky l
James A. Mahar, Esq.-
£:\Procuses\1'»'42.00'»'\m0txtdtinne102S03.»xqJd ,
1742,007
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