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

Case 3:02-cv-02101-AVC

Document 25

Filed 02/20/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : Plaintiff, : : vs. : : PETER O'MEARA THE COMMISSIONER OF : THE DEPARTMENT OF MENTAL : RETARDATION FOR THE STATE OF : CONNECTICUT, : Defendant : _____________________________________ CYNTHIA WELFARE, CIVIL ACTION NO. 3:02CV2101(AVC)

February 19, 2004 :

PLAINTIFF'S UNOPPOSED MOTION FOR MORE TIME TO RESPOND TO DEFENDANT'S WRITTEN DISCOVERY On January 20, 2004, the Defendant served a first set of written discovery on the Plaintiff. The Plaintiff now moves the Court for an additional thirty (30) days in which to serve her objections and responses on the Defendant. Plaintiff's objections and responses would be due by March 22, 2004. This is the Plaintiff's first request for more time to respond to Defendant's written discovery requests. The Defendant has indicated that it does not object to this motion. RESPECTFULLY SUBMITTED THE PLAINTIFF,

By:

______________________________ Peter Goselin ct16074 Livingston, Adler, Pulda, Meiklejohn & Kelly, P.C. 557 Prospect Avenue Hartford, CT 06105-2922

Case 3:02-cv-02101-AVC

Document 25

Filed 02/20/2004

Page 2 of 2

(860) 233-9821 CERTIFICATE OF SERVICE This hereby certifies that the Plaintiff's Unopposed Motion for More Time To Respond to Defendant's Written Discovery has been mailed, first class mail, postage pre-paid, on this day of February 2004 to all counsel of record as follows: Thomas M. Fiorentino Assistant Attorney General 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Peter Goselin