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

I . .... -Y_..m..s......._....;....~........_.....I - I
I I Case 3:03-cv-OO783—)CFD Document 30 Filed 12/@003 Page 1 of 4 I
I I
UNITED STATES DISTRICT COURT I
DISTRICT OF CONNECTICUT I
CENTRIX, INC., ;
: Civil Action N0. 3:03 7.03 QCIFD) ''Y`` [
Plaintiff; : 2 ? _-ii I liv jffQ_j_‘_Q§ I
- ·—.- Ei: g Qi;} g
v. ; A I l 5 · ,_I.»_eU I
I · ef /,2 _,_,. L·¢w.n"
ANDON BRUSH COMPANY, INC., : T] I
— ln
I Defendant. : DECEMBER 23, 2003 if I P I
· I
l ' E
. MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAIN TIFF CENTRIX INC.'S DISCOVERY REQUESTS I
Defendant Andon Bmsh Company, Inc. ("Andon"), by its undersigned counsel, hereby I
l moves this Court for an extension through and including January 16, 2004 for Andon to respond
to Plaintiff Centrix Inc.’s discovery requests as set forth below. In support of its motion Andon
. 1
states as follows: I
I
_ l. Defendant Andon was recently required to change icounsel in this action when its
I original counsel, McCarter and English, developed a conflict lof interest (by reason of the I
acquisition of a portion of Ctunmings & Lockwood), which required them to withdraw from this
i
action.
I
2. Andon obtained new counsel on approximately November 21, 2003, when they I
‘ engaged Carella, Byrne, Bain, Gilfillan, Cecchi, Stewart & Olstein as its lead counsel; Shortly I
I

Case 3:03-cv-OO7Q3)CFD Document 30 Filed 12/@003 Page 2 of 4
thereafter, Matthew C. Mason of Gregory and Adams, PC was retained as local counsel and on
E I
I December 3, 2003, Attorney Mason entered his appearance on behalf of the defendant Andon. I
I 3. By motion dated November 25, 2003 entered on the docket on December 3, 2001, I
Dennis F. Gleason and G. Glennon Troublefield of Carella, Byrne, Bain, Gilfillan, Cecchi, I
Stewart & Olstein moved for admission pro imc vice in this action.
I 4. On December 3, 2003, a settlement conference in this matter was held before the
_I
` Honorable William I. Garfinkle, U.S.M.J. The December 3, I 2003 settlement conference `
concluded with a settlement proposal being outstanding and which was to be responded to by I
I Andon on or before December 12, 2003. Since that time the parties have been attempting to I
I E
settle the matter. I
' 5. The following discovery requests/demands are outstanding: I
a. Plaintiff, Centrix, Inc.'s First Set of Interrogatories to Defendant Andon Bmsh I
Company, Inc. (served by fax and mail on November 7, 2003); I
I I b. Plaintiff Centrix, Inc.'s Second Set of Interrogatories to Defendant Andon Brush
I Company, Inc. (served by fax and mail on November 24, 2003); I
I
c. Plaintiff, Centrix, Inc.’s Request For Production Of Documents And Things (First
I Set) Directed to Defendant Andon Brush Company, Inc. (served by fax and mail on November 7,
·I 2003); and I
d. Plaintiff Centrix, Inc.'s Request For Admissions (First Set) To Defendant, Andon I
I Brush Company, Inc. (served by fax and mail on November 24, 2003). I
I 6. Defendant Andon respectfully requests that it have an extension of time until
I January 16, 2004 to respond to Plaintiffs Discovery Requests.
I
I I 7. In accordance with Local Rule 7(b) the undersigned represents that this is
II Defendant Andon’s first request for an extension of time relative to the subject discovery.
I
I I
I
I
I
I
. I I
I

Case 3:03-cv-OO76®CFD Document 30 Filed 12/@003 Page 3 of 4 i
_ 8. The undersigned further represents that he has diligently sought to ascertain I
T ` opposing counsel’s position on the motion but has been unable to do so (phone messages to f
l Plaintiff’ s counsel’s office havenot been returned). I
; I
Respectfully submitted, (
i
l By: *
Matthew C. Mason (ct 15291)
i GREGORY AND ADAMS, P.C.
Attorneys for Defendant
i - 190 Old Ridgefield Road
Wilton, Connecticut 06897 E
Phone: 203 762-9000 i
Fax: 203 8344628
Email: [email protected]
l
N
I i
l l
1 ‘ ‘ _
1
¤
Q l

; Case 3:O3—cv-OO7®CFD Document 30 Filed 12/@003 Page 4 of 4 ?
_ _ CERTIFICATE OF SERVICE l
I I
I hereby certify that, on December 23, 2003, a true and correct copy of the foregoing was l
served by first class mail, postage prepaid, upon the following: I
Arthur T. F attibene, Esq. I
Fattibene & Fattibene
2480 Post Road I
Southport, CT 06490
203—25 5-4400
` 'S!
"(`·vd¤KL... Cc (WM- I
Matthew C. Mason `
1