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

Case 2:91 —cv-001 80-RNC Document 562 Filed 06/13/2008 Page 1 of 3
UNITED STATES DISTRICT COURT I
DISTRICT OF CONNECTICUT
P.J., et al., : CIVIL NO.
Plaintiffs, : 291CV00180 (RNC)
v. :
STATE OF CONNECTICUT, et al.
Defendants. : JUNE 12, 2008
MOTION FOR ENLARGEMENT OF TIME
The Plaintiffs request an enlargement of time from June 18, 2008 to July 15, 2008 to file
a motion that describes each type of discovery Plaintiffs’ seek in support of their Motion to
Enforce the Settlement Agreement as ordered on June 2, 2008 [Doc. #561]. In support of this
request, the Plaintiffs represent the following:
1. On June 2, 2008, the Court entered an Order that required Plaintiffs to confer with
Defendants in a good faith attempt to resolve discovery disputes and file a motion by no later
than June 18, 2008 that sets forth with particularity each type of discovery sought and the
authority for granting the discovery request. [Doc. #561]
2. On June 12, 2008, Plaintiffs served a Motion for Disclosure and Production and
Notices of Deposition on the Defendants.
3. The Motion for Disclosure and Production requests that the Defendants identify the
persons most knowledgeable about Defendants’ efforts to monitor and oversee the
implementation of the Settlement Agreement, and seeks to have two of Plaintiffs’ experts

Case 2:91-cv-00180-RNC Document 562 Filed 06/13/2008 Page 2 of 3
interview CSDE employees and contractors responsible for monitoring and oversight of the
implementation of the Settlement Agreement.
4. Plaintiffs have also served Notices of Deposition on Defendants.
5. While it is unclear when Defendants will respond to the Notices of Deposition and
Motion for Disclosure and Production, Plaintiffs’ motion seeking orders from the Court cannot
be completed by June 18, 2008.
6. Plaintiffs therefore request an enlargement of time until July 15, 2008 to comply with
the Court Order dated June 2, 2008.
7. Despite good faith efforts, counsel was unable to determine Attorney Cunningham’s
position on this request.
8. This is the first enlargement of time requested with respect to this time limitation.
WHEREFORE, the Plaintiffs request that the time within which their discovery motion
under Court Order dated June 2, 2008 is due be enlarged from June 18, 2008 to July 15, 2008.
PLAINT;E»lfS, /,
By {
David C. Shaw, Esq.
The Law Offices of David C. Shaw, LLC
Fed. Bar No. ct05239
34 Jerome Ave., Suite 210
Bloomfield, CT 06002
Tel. (860) 242-1238
Fax. (860) 242-1507
Email: [email protected]
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Case 2:91-cv-00180-RNC Document 562 Filed 06/13/2008 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing was mailed first class, postage prepaid to
counsel of record on June 12, 2008:
Darren P. Cunningham
Assistant Attorney General
State of Connecticut
P.O. Box 120
Hartford, CT 06141
, 17
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David C. Shaw, Esq.
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