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

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I · Case 3:03-cv-OO70@FD Document 57 Filed O3/2EII%OIO4 Page 1 of 4 I
IN THE UNITED STATES DISTRICT COURT I
FOR THE DISTRICT OF CONNECTICUT { I I I ” CC`"' I
At Hartford .1 rn V;} I`: 5 A I
I III ¢--`I I I
CENTRIX, INC. _ I, g
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Plaintiff/Counter-Defendant I .‘¤-` I~ZAI'I‘:IiIi·i~°"` " °' I I
v. Civil Actipn N0. " I ` I-- I ll
3:03—CV-*{03(CFD)(WIG) I
ANDON BRUSH COMPANY, INC.,
I Defendzmt/Counter-Plaintiff March 22I 2004 I
PLAINTIFF, CENTRIX, INC.’S, MOTION FOR EXT a NSION
OF TIME TO RESPOND TO DEFENDANT’S (ANDON) QUESTS I
FOR PRODUCTION OF DOCUMENTS AND INTERRO ATORIES {
AND TO FILE CENTRIX’S EXPERT’S REPORITS
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Plaintiff, Centrix, Inc. (Centrix), by its undersigned I
counsel, hereby moves: ` I
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1. For an extension of time to and including April
20, 2004, to respond to Defendant's, Andon’s, requests for I
production and interrogatories served on Centrix on or
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about January 30, 2004. I I
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The grounds for this Motion are: = I
(1) There is currently pending before the Court a I
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Centrix Rule 12 Fed.R.Civ.P. Motion for Dismissal of
“ Defendant's Counter-Claims and certain affirmadive
defenses, as well as a pending motion to enforde a
settlement agreement between the parties hereto, coupled
with a request to either stay discovery pending the
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i . E Case 3:03-cv-0070 .FD Document 57 Filed 03/2¢&20;04 Page20f4
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J resolution of the settlement motion and/or in the Q
2 alternative, to extend the discovery dates of the current !
i standing order by ninety (90) days. E i
I (2) The matter has been set down for a settlement g
I conference for April 16, 2004 by Magistrate Judge
l Garfinkel, and that settlement may occur. In such event or §
subject to the resolution of the above motions, any further E
discovery will be rendered either moot or limiied to only
those matters permitted by the Court’s resolution of the E
pending motions. I {
(3) This extension is also required to enable counsel
additional time to confer with the principals df Centrix
knowledgeable of the matters requested by Andon’s
outstanding discovery matters in the event the matter is J
not resolved. _
In accordance with Local Conn. Civil Rule-7(b), the
undersigned counsel hereby represents that this is
Centrix’s second request for an extension of time relative i

to responding to Andon's Request for Production of E
Documents and Interrogatories that were served on {
Plaintiff, Centrix, on or about January 30, 2004.
The undersigned further represents that on March 22,
2004, he attempted a telephone conference withéMr. Kenneth ?
Winters, Andon's attorney of record. Neither Mr. Winters
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A · Case 3:03-cv-OO70i%FD Document 57 Filed O3/2EI,]L_.'5OEO4 Page 3 of 4 `
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, nor his associate, Mr. Troublefield, were available, nor i
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` have I been able to discuss the substance of this motion 5
{ with them. i
It is submitted that neither party will be prejudiced l
by the requested extension. Q
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Respectfully submitted,
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Arthur T. Fattibene, CTO6916
Counsel for Plaintiff |
Fattibene and Fattibene l
2480 Post Road
Southport, CT O6§9O
Tel: 203—255—44c)0 l
Fax: 203-259-0033 i
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K Case 3:03-cv-OO703»CFD Document 57 Filed O3/24/QOIO4 Page 4 of 4
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Certificate of Service j
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I, Arthur T. Fattibene hereby certify that a copy ofPlI1intiff, Centrix,
Inc.’s Motion For Extension Of Time To Respond To Defendantis (Andon) I
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Requests For Production Of Documents And Interrogatories And To File Centrix’s I
Expert’s Reports attached hereto has been served on:
I Kenneth L. Winters
Carella, Byrne, Bain, Gilfillan, I
Cecohi, Stewart & Olstein ?
* 5 Becker Farm Road I
Roseland, NJ 07068-1739 ‘ X
Fax No. 973-994-1744
And
Attorney Matthew Mason 2
190 Old Ridgefield Road _ I
Wilton, CT 06897 . ;
Fax No. 203-834-1628 _ _ I
By Fax and First Class U.S. Mail postpaid, this Z Z day of March
2004. _ I
Arthur T. Fattibene I
2480 Post Road I
Southport, Connecticut 0§890 I
. Tel: 203-255-4400 i I
Fax: 203-259—0O33 ?
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