Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-009305CFD Document 34 Filed 12/03/2003 Paget of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
(HARTFORD)
civil. Action No.;
: 3:03CV930(CFD)
i=>i.Air~mi=i=, Z
HARTFORD PARKING AUTHORITY, ET AL;
DEFENDANTS December 3, 2003
OBJECTION TO NON-PARTY’S
MOTION FOR EXTENSION OF TIME
Plaintiff submits this objection to the motion for an extension of time filed by the
non-party Connecticut Parking Services to file its memorandum to support the
objection, motion to quash and motion for costs filed September 25, 2003. The non-
party’s motion for extension of time is only a continuation of its efforts to preclude any
discovery taking place.
Counsel for the parties have exchanged correspondence since the filing of the
initial objection and the non-party has failed to supply any justification for its position
and furthermore rejected all efforts to make the process less "cumbersome and
harassing". Instead, the non-party insists that it need not to produce any documents j
and continues its efforts to delay production, forcing the plaintiff to file the pending
motion to compel and contempt in an effort to enforce the outstanding subpoena duces ·

Case 3:03-cv-00930-CFD Document 34 Filed 12/03/2003 Page 2 of 4
tecum. The current motion for an extension only substantiates this perception by
seeking an open ended extension, without explanation or reasons why the extension is ·
needed and without first seeking consent of the plaintiff.
Moreover, even after notifying plaintiff of the pending motion, plaintiff extended
P yet another courtesy to the non-party (see attached), which has gone without response.
(Other than another phone cll indicating the non-party has refused to produce most of
the documents.) Plaintiff submits that the time to resolve this discovery abuse has
come and objects to the extension sought and seeks the relief set forth in its motion for ’
contempt.
Respectfully submitted,
_ THE PLAINTIFF
ROBE/RTQEARKER
W gb
By: ._ { l
Eliot B. Gersten, Esq. (ct05213)
GERSTEN & CLIFFORD
214 Main Street .
Hartford, CT 06106
Tel: 860-527-7044
Fax: 860-527-4968
E-Mail: [email protected]
His Attorneys

Case 3:03-cv-00930-CFD Document 34 Filed 12/03/2003 Page 3 of 4
CERTIFICATION
I hereby certify that a copy of the foregoing was sent via U.S. Mail, first class,
postage prepaid or hand delivered on this 3"’ day of December, 2003, to:
Jill Hartley, Esq. (ct10570) g
Michael G. Albano (ct21440)
Sabia & Hartley, LLC
190 Trumbull Street, Suite 202
Hartford, CT 06103
Tel: 860-541-2077
Fax: 860-713-8944
Jonathan L. Gould, Esq. (ct 05237)
Law Offices of Jonathan L. Gould
214 Main Street
Hartford, CT 06106
Tel: 860-278-91 15
Fax: 860-278-9124
Stanley Cohen, Esq. (ct 00014)
Cohen, Auger, Burns & Hard
39 Grand Street /,/`)
Hartford, CT 06106 7/ —,{
Tel: 860-549-4740 fg
F :8 -47- 12 ` ‘"l: ·
ax 60 2 2 6 {
Eliot B. Gersten

Case 3:03-cv-00930-CFD Document 34 Filed 12/03/2003 Page 4 of 4
P
GERSTEN & CLIFFORD
. ATTORNEYS AT LAW
214 Main Street
Hartford, CT 06106-1881
Telephone (860) 527-7044
Telecopier (860) 527-4968
(E-mail: EliotG@gersten·clifford.com)
Euor B. GERSTEN, Esouuus
December 2 2003
Our File No. 3756-001
Stanley Cohen, Esq.
Cohen Auger Bums & Hard
39 Grand Street
Hartford, CT 06106
Re: Robert T. Parker v. Hartford Parking Authorig, et al.
Dear Stanley:
I received your voice mail today and reviewed your motion for extension of time. Based
upon my understanding of the voice mail, it appears that you simply reiterated your position that
plaintiff is not entitled to compliance with the outstanding subpoenas.
I plan on filing an objection to your motion for extension of time because I have been
trying to obtain cooperation and have offered compromises to you several times since October
N 14th, and we have made no progress. Indeed I had to file a motion seeking contempt.
\\Mwp
I will wait to file the objection until tomorrow in the event that I failed to understand your
voice mail correctly , and that you can articulate what documents you will produce, and when. If
the proposed production meets most of what I asked for then we can avoid any more work being
done in motion practice. Even absent complete compliance, if there is a meaningful step forward
by your client, then we can represent to the court that we have made some progress and can avoid
or postpone intervention. If you have no intention to comply with the subpoenas, then you
should file your opposition to the contempt motion to supplement that on file and we can allow
the court to proceed. My point is only that the time to proceed in some fashion has arrived.
Let me know what you want to do.
Very truly yours,
GERSTEN & CLIFFORD