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

Case 3:03-cv-00611-RNC

Document 36

Filed 08/06/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

PHILIP M. ANDREWS Plaintiff V. REGINALD ALLEN Defendant

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CIVIL ACTION NO. 3:03CV611 (RNC)

AUGUST 5, 2004

MOTION FOR ENLARGEMENT OF TIME The undersigned, on behalf of the defendant, Reginald Allen, respectfully requests an enlargement of time of sixty (60) days from August 4, 2004 to and including October 3, 2004 in which to respond and/or object to the plaintiff's first set of Interrogatories and Requests for Production. On July 8, 2004, defendant's counsel received a voluminous packet from the pro se plaintiff, Philip M. Andrews. This packet appeared to be responsive to defendant's pending Request for Production served on the plaintiff on December 8, 2003. On August 4, 2004, counsel for the undersigned was reviewing the packet of materials when it was found to contain multiple motions and what appeared to be Interrogatories and Requests for Production from the plaintiff. These Interrogatories and Requests for Production were contained within transcripts, medical records and other miscellaneous documents. The document entitled "Plaitniff's Interrogatories and Requests for Production" was dated June 10, 2004 and contained no certification page as to the date of service on the defendant. The motion entitled "Plaintiff's Motion/Requests for

Case 3:03-cv-00611-RNC

Document 36

Filed 08/06/2004

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Disclosure" was also dated June 10, 2004 and did not contain a certification page identifying the date of service on the defendant. This is defendant's first request for enlargement of time. Counsel for the defendant makes this request so that defendant may be allowed time to gather information and documents responsive to the plaintiff's discovery requests. The pro se plaintiff, Andrew P. Philips, was recently released from the custody of the Department of Corrections and is believed to be residing in New Britain, Connecticut. Attempts were made to make contact with the plaintiff utilizing various phone numbers he had provided, with negative results. Accordingly, the pro se plaintiff's position regarding this Motion is unknown at this time. WHEREFORE, the defendant requests that his Motion for Enlargment of Time to and including October 3, 2004 be granted.

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Case 3:03-cv-00611-RNC

Document 36

Filed 08/06/2004

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THE DEFENDANT REGINALD ALLEN

By _________________________ Eric P. Daigle HALLORAN & SAGE LLP Fed. Bar #ct23486 One Goodwin Square 225 Asylum Street Hartford, CT 06103 (860) 522-6103 [email protected] His Attorneys CERTIFICATION This is to certify that on this 5th day of August, 2004, a copy of the foregoing Motion for Enlargement of Time was mailed, postage prepaid, to: Philip M. Andrews 55 Spring Street Suite #304 New Britain, CT 06051-1972 (pro se plaintiff)

Eric P. Daigle
579699.1(HS-FP)

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