Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00118-MRK

Document 98

Filed 05/24/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT NEW HAVEN DIVISION LORI RAYMOND, et al. Plaintiffs, Individually and as representatives of all persons similarly situated, VS. JOHN ROWLAND, Governor of Connecticut, and PATRICIA WILSON-COKER, Commissioner of the Connecticut Department of Social Services, in their official capacities, Defendants. : : : : : : : : : : : : : CIVIL ACTION NO. 303CV0118 (MRK)

May 24, 2004

MOTION FOR EXTENSION OF TIMETO RESPOND TO DEFENDANTS' MOTION TO QUASH SUBPOENAS Pursuant to Local Rule of Civil Procedure 7(b), plaintiffs hereby move for a fourteen day extension of time until June 7, 2004 to respond to Defendants' Motion to Quash Subpoenas, dated May 3, 2004. In support of this motion plaintiffs state the following: 1. Counsel for defendants are in agreement with this requested extension. 2. Good cause exists for this extension request in that the parties are actively working to resolve a significant portion of the disputed request for materials. Counsel conferred on the phone on May 14, 2004. Plaintiffs' counsel followed up on this conversation with a letter confirming the substance of the conversation on May 19. (Copy of letter attached.) 3. On late Friday afternoon, May 21, 2004, defendants' counsel Hugh Barber indicated by a facsimiled letter that defendant DSS will provide a number of the disputed documents by early in the week of May 31st. The letter indicated that defendants are following up on other requests

Case 3:03-cv-00118-MRK

Document 98

Filed 05/24/2004

Page 2 of 3

in a less specific time frame. (Copy of letter attached.) Defendants' counsel specifically requested that plaintiffs' counsel delay in filing a Motion to Compel at least until May 28 th. 4. Plaintiffs originally intended to file today with the Court a combined opposition to Defendants' Motion to Quash Subpoenas and a Plaintiffs' Motion to Compel Responses to Plaintiffs' Second Request for Production of Documents to Defendant Patricia Wilson-Coker. There is a substantial overlap of document production issues between the Motion to Quash and the planned Motion to Compel. 5. The parties are meeting on June 2, 2004, to discuss proposed regulations that the defendants have promulgated to address some of the issues in this litigation. 6. Allowance of this fourteen day extension will permit the parties to resolve some of their disagreements and reduce the issues for the Court to resolve. 7. This is plaintiffs' first motion for extension of time to respond to Defendants' Motion to Quash Subpoenas. PLAINTIFFS LORI RAYMOND, et al. _____________________ Joanne Gibau (ct05730) New Haven Legal Assistance Assoc. 426 State Street New Haven, CT 06510-2018 Phone: 203.946.4811 Fax: 203.498-9271 E-Mail: [email protected] Their Attorney

Case 3:03-cv-00118-MRK

Document 98

Filed 05/24/2004

Page 3 of 3

CERTIFICATION I hereby certify that the foregoing Motion for Extension of Time was served in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 24th day of May 2004, by U.S. mail, first class, postage pre- paid and addressed to: Hugh Barber, Esq. Peter Brown, Esq. Richard J. Lynch, Esq. Assistant Attorneys General Office of the Attorney General 55 Elm St., P.O. Box 120 Hartford, CT 06141-0120 ____________________________ Joanne Gibau