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

Case 3:03-cv-00452-CFD

Document 50

Filed 02/05/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DAVID RURAN, Plaintiff, V. BETH EL TEMPLE OF WEST HARTFORD, INC., Defendant : : : : : : : : CIVIL ACTION NUMBER 3: 03 CV 452 (CFD)

February 5, 2007

FIRST MOTION ON CONSENT FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT'S INTERROGATORIES AND DOCUMENT REQUESTS Pursuant to the Federal Rules of Civil Procedure and Local Rule7 of this Court, Plaintiff David Ruran respectfully requests a fourteen (14) day enlargement of time in which to respond to Defendant's First Set of Interrogatories and First Requests for Production of Documents. As discussed below, this is the first such extension sought with respect to these discovery requests, and is made with the consent of Defendant. In support of this motion, Plaintiff states the following: 1. On January 12, 2007, Plaintiff was served with Defendant's First Set of Interrogatories and First Requests for Production of Documents. Therefore, under the applicable rules, Plaintiff's responses and objections would be due on or before Monday, February 12, 2007. 2. Plaintiff has begun preparing his responses and objections to said two sets of discovery, but requires an additional two weeks in order to complete said responses.

ORAL ARGUMENT IS NOT REQUESTED NOR IS TESTIMONY REQUIRED

Case 3:03-cv-00452-CFD

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Filed 02/05/2007

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3.

This is the first such extension of time sought with respect to said discovery responses.

4.

Today, February 5, 2007, by telephone and by email, the undersigned communicated with counsel for Defendant, Mark Newcity, who advised that he consents to the requested enlargement of time.

WHEREFORE, Plaintiff, on consent, hereby respectfully moves for a fourteen day enlargement of time within which to respond to Defendant's First Set of Interrogatories and First Requests for Production of Documents. With the granting of this motion, Plaintiff's responses would be due on or before Monday, February 26, 2007.

PLAINTIFF, DAVID RURAN

By:

/s/ William G. Madsen (ct09853) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave., Suite 201 Hartford, CT 06106 TEL. (860) 246-2466 FAX. (860) 246-1794 Email: [email protected]

Case 3:03-cv-00452-CFD

Document 50

Filed 02/05/2007

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on this 5th day of February, 2007, a copy of foregoing Motion On Consent to Enlarge the Scheduling Order was filed electronically [and served by mail on anyone unable to accept electronic filing]. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system [or by mail to anyone unable to accept electronic filing]. Parties may access this filing through the Court's system. By: /s/ William G. Madsen (ct09853) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave.; Suite 201 Hartford, CT 06106 Telephone: (860) 246-2466 Facsimile: (860) 246-1794 E-mail: [email protected]