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

Case 3:03-cv-00612-RNC

Document 12

Filed 11/17/2003

Page 1 of 3

UNITED STATES DISTRICT COURT for the DISTRICT OF CONNECTICUT ________________________________________ ROBERT R. CARLSON, Plaintiff, v. HARTFORD FINANCIAL SERVICES GROUP, INC. Defendant. _______________________________________ : : : : : : : : : :

CIVIL NO. 303CV0612 (RNC)

November 17, 2003

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME IN WHICH TO RESPOND TO PLAINTIFF'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to the Federal Rules of Civil Procedure and the Local Rules of this Court, the Defendant, Hartford Financial Services Group, Inc., respectfully requests a fifteen (15) day extension of time, up to and including December 2, 2003 in which to respond and/or object to Plaintiff's First Request for Interrogatories and Production dated September 18, 2003. In support of this Motion, the Defendant provides the following: 1. Pursuant to the Court's Case Management Plan dated July 2, 2003, the

deadline for Discovery is March 15, 2004. 2. The Plaintiff's First Set of Interrogatories are comprised of fourteen (14)

interrogatories and Plaintiff's Request for Production of Documents is comprised of thirty one (31) requests for document production.

ORAL ARGUMENT NOT REQUESTED

Case 3:03-cv-00612-RNC

Document 12

Filed 11/17/2003

Page 2 of 3

3.

As Defendant provided draft responses and document's to counsel on

Friday afternoon and because counsel is preparing for a trial this week in another matter, Defendant needs additional time in which to review the information necessary to respond and/or object to Plaintiff's Interrogatories and Plaintiff's Request for Production of Documents. 4. Defendant seeks additional time, up to and including December 2, 2003 in

which to respond and/or object to the Plaintiff's Interrogatories and Plaintiff's Request for Production of Documents. 5. Plaintiff's counsel, Judith Meyer, was contacted on November 17, 2003,

regarding this motion and she stated she does not object to the granting of this motion. 6. This is Defendant's second motion for extension of time to respond and/or

object to Plaintiff's Interrogatories and Plaintiff's Request for Production of Documents. WHEREFORE, the Defendant respectfully moves for an extension of time, up to and including December 2, 2003 in which to respond and/or object to Plaintiff's First Request for Interrogatories and Production dated September 18, 2003. DEFENDANT, HARTFORD FINANCIAL SERVICES GROUP, INC.

By: William J. Anthony, Esq. (ct 17865) Jackson Lewis LLP 55 Farmington Avenue, Suite 1200 Hartford, CT 06105 (860) 522-0404 [email protected]

Case 3:03-cv-00612-RNC

Document 12

Filed 11/17/2003

Page 3 of 3

CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing was sent by regular mail, postage prepaid, on this 17th day of November, 2003, to the following counsel of record:

Judith D. Meyer, Esq. 152 Simsbury Road P.O. Box 451 Avon, CT 06001

William J. Anthony

3