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

I Case 3:03-cv—00612—RNC Document 10 Filed 10/1U2003 Page 1 of 3
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i UNITED STATES DISTRICT COURTQY li I . I. . r. 1..
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DISTRICT OF CONNECTICUT (Ski Wil I I ‘" i‘ I" \
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ROBERT R. CARLSON, ;
Plaintift : CIVIL N0. 30sCv0612 (RNC) I
HARTFORD FINANCIAL SERVICES
GROUP, INC. ; 7 I
Defendant. : October 17, 2003
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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 l
Court, the Defendant, Hartford Financial Services Group, Inc., respectfully requests a thirty (30)
day extension of time, up to and including November 17, 2003 in which to respond andfor obj ect j
to Plaintiffs First Request for Interrogatories and Production dated September 18, 2003. In i
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support of this Motion, the Defendant provides the following:
1. Pursuant to the Cou1t’s Case Management Plan dated July 2, 2003, the i
deadline for Discovery is March 15, 2004. x
2. The Plaintiffs First Set of Interrogatories are comprised of fourteen (14)
interrogatories and Plaintiffs Request for Production of Documents is comprised of thirty one
(31) requests for document production.
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ORAL ARGUMENT NOT REQUESTED
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l _ _ . Case 3:03-cv—0061(2—§lNC Document 10 Filed 10/?J§003 Page 2 of 3
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3. As this case involves complex issues, Defendant needs additional time in K
which to gather information necessary to respond and/or object to Plaintiffs Interrogatories and j
Plaintiffs Request for Production of Documents. i
4. Defendant seeks additional time, up to and including November 17, 2003
in which to respond and/or object to the Plaintiffs Interrogatories and Plaintiffs Request for
Production of Documents. *
5. Plaintiffs counsel, Judith Meyer, was contacted on October 16, 2003, i
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regarding this motion and she stated she does not obj ect to the granting of this motion. `
6. This is Defendant’s first motion for extension of time to respond and/or {
obj ect to Plaintiffs Interrogatories and Plaintiff' s Request for Production of Documents. j
WHEREFORE, the Defendant respectfully moves for an extension of time, up to J
and including November 17, 2003 in which to respond and/or object to Plaintiffs First Request
for Interrogatories and Production dated September 18, 2003.
DEFENDANT,
HARTFORD FINANCIAL SERVICES
GROUP, mc. N
By: {
William J. Anthony, Esq. (ct 1 865)
Jackson Lewis LLP l
55 Farmington Avenue, Suite 1200
Hartford, CT 06105
(860) 522-0404
[email protected]
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A Case 3:03-cv—OO616RNC Document 10 Filed 10/1/Z%OO3 Page 3 of 3
I CERTIFICATION OF SERVICE
This is to certify that a copy of the foregoing was sent by regular mail,
i postage prepaid, on this 17m day of October, 2003, to the following counsel of record:
Judith D. Meyer, Esq.
152 Simsbury Road
P.O. Box 451 y
Avon, CT 06001
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Tasos C. Paindiris
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