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

Case 3:03-cv-00630-DJS Document 130 Filed 12/26/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OP CONNECTICUTT
MARIO RICHARDS,
: CWIL ACTION NO:
Plaintiff, :
v. 3:03 CV 00630 (DIS)
COMPUTER SCEENCES CORPORATION,
: DECEMBER 26, 2006
Defendant. :
DEFENDANTS MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFF’S MO'I`I.ON FOR PERMISSION
TO ALLOW PARTIES TO OPT IN TO THE CLASS
Pursuant to the Federal Rules of Civil Procedure and the Local Rules of
this Court Defendant, Computer Sciences Corporation, hereby respectfully moves for a
twenty-one (2l) clay extension of time, until January 16, 2007, to respond to Piaiiitiffs
Motion for Permission to Allow Parties to Opt In to the Class.
In support of this Motion, Defendant states as follows:
1. On December 4, 2006, Plaintiff filed a Motion for Permission to Allow
Parties to Opt In to the Ciass.
2. Plaintiffs Motion seeks to allow three (.3) individuals who claim to have
worlted overtime without pay participate in this case even though the deadline for opting
in has passed. Plaintiff claims that the names of these individuais were not on the list of
potential class nieinlners provided by Defendant.

Case 3:03-cv-00630-DJS Document 130 Filed 12/26/2006 Page 2 of 3
3, Defendant has reason to believe these individuals were not included on the
list because they worked after the Help Desk Analyst position was reciassilled in
November 2004 and their only claims would therefore involve alleged ‘°off—the—clock"
time. If so, Plaintiff’s Motion for Permission would be rendered moot by this Court’s
recent ruling denying Plaintit`f’ s efforts to expand the class in this case to include claims
for "off¥the-clock" time.
4. Defendant requires additional time to research the employment history and
status of these individuals to detennine whether they are part of the class
WHEREFORE, Defeiidaiit requests that the deadline for responding to Plaintiff’ s
Motion for Permission to Allow Parties to Opt In to the Class be extended by twenty one
(21) days until January i6, 2007.
DEFENDANT,
COMPUTER SCIENCES CORPORATION
By: /s/ T ams C. Pcziudiris
Tasos C. Paindiris, Esq. (ct 16739)
Jackson Lewis LLP
90 State House Square, S"` Floor
Hartford, CT 06103
Tel: 860—522—0404
Fax: 860—.247—l.330
E—niail: paindirt@jacksonlewiscom
2

Case 3:03-cv-00630-DJS Document 130 Filed 12/26/2006 Page 3 of 3
CERTIFICATION OF SERVICE
I hereby ceitify that on December 26, 2006, a copy of the foregoing
Motion for Extension of Time was filed electronically and setved by mail on anyone
unable to accept electronic filing. Notice oft this filing will be sent by e-mail to all parties
by operation of the Conrt’s electronic tiling system and by mai} to anyone unable to
accept electronic tiling as indicated on the Notice of Electronic Filing, Parties may
access this tiling tlirougli the Cour‘t’s CMECF System.
/.s/ Tasos C. Pczirzdiris
Tasos C. Paindiris