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


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Date: April 30, 2004
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State: Connecticut
Category: District Court of Connecticut
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Case 3:03-cv-00712-WWE Document 46 Filed O4/30/2004 Page 1 of 3 y
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UNITED STATES DISTRICT COURT F ‘ L E D
DISTRICT OF CONNECTICUT .
Zllllil APR 30 A I0= I0
U.§.[Dl§ERICT Cflillil
GERTRUDE BAYONNE, : B:.l..lL:n| GRT. |Z0i‘u¤ \
Plaintiff, I
: Civ. Action N0. I
3:03CV0712(WWE)
v. : r
JURY TRIAL DEMANDED
PITNEY BOWES, INC. & 2
THE PITNEY BOWES, INC. ,
LONG TERM DISABILITY PLAN, : . J
THE PITNEY BOWES, INC. LONG a
TERM DISABILITY PLAN :
ADMINISTRATOR AND THE
PITNEY BOWES, INC. :
DISABILITY DEPARTMENT,
Defendants. : APRIL 29, 2004
PLAINTIFFS’ MOTION FOR EXTENSION
OF TIME TO COMPLETE DISCOVERY AND MOTION REQUESTING
ALL DEPOSITIONS BE CONDUCTED AT THE COURTHOUSE
Plaintiff Gertrude Bayonne hereby respectfully requests an extension of time to §
complete discovery inthe instant case. The current discovery deadline is June 1, 2004.
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Plaintiff requests an additional two months in which to complete discovery, up to and i
including September 1, 2004.
Plaintiff asserts that good cause exists for granting the instant motion: (1)
Defendants recently served their first discovery request on April 28, 2004 and the `
undersigned requires additional time to review and respond to the request; (2) Defendants i
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED
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Case 3:03-cv-00712-WWE Document 46 Filed O4/30/2004 Page 2 of 3
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also noticed the Deposition of Plaintiff for May 28, 2004, and the undersigned is
uncertain that he or the Plaintiff] who resides near Buffalo, New York can attend on the
date noticed; (3) the undersigned is currently working on Plaintiff’s Partial Motion for I
Summary Judgment on her ERISA benefits claim to be filed next week; (4) the I
undersigned is simultaneously also working on two other summary judgment motions in I
the D.Conn. (due by May 15, 2004) and S.D.N.Y. (due in June); (5) Plaintiff recently I
received Defendants Answer to the Revised Amended Complaint on March 26, 2004 and I
the undersigned is determining what discovery to serve on the Defendants in this
combined ADA/ERISA action. I
Counsel for Plaintiff contacted counsel for the Defendants on April 29, 2004, who
refused to consent to a thirty or sixty day extension of time to complete discovery. In
same conversation, Defendants were also notified that Plaintiff was going to file her I
Partial Motion for Summary Judgment on the ERISA benefits claim by early next week. I
This is Plaintiffs second request for an extension of time to extend the discovery
deadline.
Plaintiff also requests permission to conduct all depositions of fact witnesses in
the United States Courthouse in Bridgeport, Connecticut. The purposes of the request is
avoid unnecessary deposition disputes if any and to provide a neutral forum to conduct
the depositions.
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Case 3:03-cv-00712-WWE Document 46 Filed O4/30/2004 Page 3 of 3 I
PLAINTIFF,
GERT UDE BAYONNE . l
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By: y gi I V, i
1 Mark @(,-17828) 1
Carey J · ssoc1ates, P.C. l
Attorneys At Law
71 Old Post Road, Suite One
Southport, CT 06490
(203) 255-4150 tel.
(203) 255··038O fax.
[email protected]
I-Ier Attorney
1
CERTIFICATE OF SERVICE i
THIS IS TO CERTIFY, that the foregoing was delivered via facsimile and first i
class mail, postage prepaid, this the 29th day of April, 2004 to:
I
Theodore J. Tucci
Robinson & Cole, LLP i
280 Trumbull Street i
Hartford, CT 06103 y
Nicole A. Diller
Sonnenschein, Nath & Rosenthal, LLP ”
685 Market Street, 6m Floor ;
San Francisco, CA 94105 j
Attorneys for Defendants \ _
Ma P. Carey I I