Free Motion to Compel - District Court of Connecticut - Connecticut

' Case 3:03-cv-00232-DFM Document 50-4 Filed 04/24/2006 Page 1 of 3 1
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UNITED STATES DISTRICT COURT 1
DISTRICT OF CONNECTICUT
BRISTOUT BOURGUIGNON : PRISONER ‘
.A.». -· plczintm : CIVIL NO. 3:03C\/`232(RNC). 1
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ARMSTRONG, ar AL
Defendants : FEBRUARY, 17, 2006
MOTION FOR EXTENSTION OF TIME TO PROVIDE DISCOVERY I
The undersigned counsel for the defendants respectfully moves, pursuant to Rule 7(b) of 1
the Federal Rules of Civil Procedure, for a forty—five day extension of time to provide responses
to the plaintiff s Request for Production of Documents, Admissions and Interrogatories, all dated
January 24, 2006.
The plaintiff recently directed the undersigned by letter to disregard his earlier discovery
requests and instead, substitute them for the new requests dated January 24, 2006. Although the
plaintiff makes the same error he had in earlier requests, that is, directing his requests to two 1
individuals in the same request, rather than individually as required, the undersigned, in the . 1
interests of efficiency given the age of this case, will nevertheless provide responses as written.
This is not the defendant’s first request for an extension of time to respond to discovery,
but the number of requests to date have been minimal. However, because of the age of this case
and the large number of requests, the defendants will need additional time to provide the plaintiff 1
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` Case 3:03-cv-00232-DFM Document 50-4 Filed 04/24/2006 Page 2 of 3 Q
with his responses. lf this request is denied, it will be severely prejudicial to the defendants, but I
if granted, will not unduly prejudice the plaintiff. The plaintiff is an incarcerated individual in
the custody of the Department of Correction and thus his position with respect to this Motion is I
unknown. I
Wl-IEREFORE, for the foregoing reasons, the defendants respectfully request that their I
motion for a forty—five day extension of time to provide responses to the plaintiff requests for
discovery be granted.
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Case 3:03-cv-00232-DFM Document 50-4 Filed 04/24/2006 Page 3 of 3 l
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DEFENDANTS A
John Armstrong, Et A1
RICHARD BLUMENTHAL J
ATT RNE GEI>IB£:zr1:7` 2
BY:
Robert b. Fis e, III
Assistant Attorney General
Federal Bar No. 17831
110 Sherman Street
Hartford, CT 06105
Tel: (860) 808-5450
Fax: (860) 808-5451
e-mail: [email protected]
` CERTIFICATION
I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b) of
the Federal Rules of Civil Procedure on this, the 17th day of F ebmary, 2006, first class postage
prepaid to:
Inmate Bristout Bourguignon, #265860
Osborn Correctional Institution
P.O. Box 100
Somers, CT 06071 { (" `\
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Robert B. Fis e, III
Assistant Attorney General
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