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

Case 3:03-cv-00703-CFD Document 38 Filed O1/16/2004 Paget of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CENTRIX, INC.,
: Civil Actien Ne. 3:l}3 CV TD3 [CFD)
Plaintiff :
ANDON BRUSH COM PANV, INC.,
Defendant. JANUARY I5, 2l}tl·¢i-
SECOND MOTION FOR EXTENSION OF TIIIHIE TO RESPOND TO
PLAINTIFF CENTRIX [NCIS DISCOVERY REQUESTS
Defendant Anden Brush Cenrpany, Inc. ("Anden"), hy its undersigned eeunsei, hereby
metres this Ceurt fer an extensien threugh and including January 31, ZUD4 fer Anden te respend
te Plaintiff Centrix lnc.’s diseeyery requests as set ferth helew. In suppert ef its rnetien Anden
states as fellews:
I. Defendant Anden was recently required te change ceunsel in this aetien when its
eriginal ceunsel, lvlcflarter and English, develeped a eenflict ef interest (by reasen ef the
acquisitien ef a pertien ef Cummings 5; Leelcweed}, which required theni te withdraw frein this
aetien.
2. Anden ehtained new eeunscl en apprexiniately lfeveniher 21, EUG}, when they
engaged Carella, Byrne, Bain, Oiltlllan, Cecchi, Stewart Ec Olstein as its lead eeunscl. Shertly

Case 3:03-cv-00703-CFD Document 38 Filed O1/16/2004 Page 2 of 4
thereafter, Matthew C. Mason of Gregory and Adams, PC was retained as local counsel and on
December 3, 2003, Attorney Mason entered his appearance on behalf of the defendant Andon.
3. Cin December 3, 2003, a settlement conference in this matter was held before the
I-Ionorable Williatn I. Garfinlcle, U.S.M.Ql. The December 3, 2003 settlement conference
concluded with a settlement proposal being outstanding. Since that time the parties have been
negotiating in an attempt to settle the matter and have exchanged numerous letters and proposed
settlement agreements under the ultitnate supervision of Magistrate Judge Gartinkle.
5. The following discovery requestsfdemands are outstanding:
a. Plaintiff Centrix, l.nc.`s First Set of htterrogatories to Defendant Andon Brush
Company, lnc. (served by fax and mail on November T, 2003];
b. Plaintiff Centrix, Lnc.'s Second Set of interrogatories to Defendant Andon Brush
Company, Inc. (served by fax and mail on November 24, 2003};
e. Plaintiff Centrix, l.ne.'s Request For Production Df Documents And Things (First
Set} Directed to Defendant Andon Bmsh Company, l.nc. [served by fax and mail on November 7,
2003}, and
d. Plaintiff, Conlrix, lnc.'s Request For Admissions {First Set) To Defendant, Andon
Brush Company, Inc. (served by far. and mail on November 24, 2003).
6. Defendant Pmdon respectfully requests that it have an extension of time until
January 31, 2004 to respond to Plaintiffs Discovery Requests.
7. In accordance with Local Rule ?(b] the undersigned represents that this is
Defendant Andon’s second request for an extension of time relative to the subject discovery.
The first request was made by tnotion filed on or about December 24, 2003. The instant motion
represents a request for an additional 14 days to respond to the discovery requests, during which
time the parties are hopeful that a tlnal settlement agreement can be reached.

Case 3:03-cv-00703-CFD Document 38 Filed O1/16/2004 Page 3 of 4
S. Plaintiffs eeunsel neither ehjeets te ner eensents te the metien fer additienai
time.
Respectfully submitted,
By. * 1i""'·~a·.1|Cd*·°-<·\" f. r¥”‘¤v1·-
Matthew C. Masen (et 1529l)
GREGORY AND ADAMS, RC.
Attenieys fer Defendant
IQU Gld Ridgefield Read
Witten, Cemieetieut DEER?
Fhene: 203 ?e2-QGUU
Fax: ECI} S34-1623
Email: rnrnasen@g;regeq*andadams.eem

Case 3:03-cv-00703-CFD Document 38 Filed O1/16/2004 Page 4 of 4
CERTIFICATE DF SERVICE
I hereby eertify that, on Ja.n1.1arj,·* 15, EIJG4, a true and eorreet eopy ofthe foregoing was
served by first class mail, postage prepaid, upon the Ibllowing:
Arthur T. Fattilzine, Esq.
Fattibene Ss Fattibene
2430 Post Road
Southport, CT {$5490
2iJ3—255—44i}U
Matthew C. Mason