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

1 Case 3:03-cv—00630—DJS Document 104 Filed 01/26/2006 Page 1 of 2 q
I I I I _..., it A 7** I
UNITED STATES DISTRICT COURT . I _ ·
DISTRICT OF CONNECTICUT
I I I ‘ I I " ·1. {ll III IIII I-, IIIII Ii
MARIOIRICHARDS, ; lil-.1n »··-> I- ~ ’ ` I
on behalf of himself and : CIVIL ACTION NO. 2
all otherssimilarly situated _: g. q 3:03 CV00630 (DJS) I ‘
‘ ‘ ‘ I I PLAINTIFFS, I : I I
COMPUTER SCIENCES CORP. January 23, 2005
DEFENDANT. . :
PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME r
RE: DISCOVERY RESPONSES q
Plaintiff Mario Richards and other plaintiffs, request pursuant to Local Rule 7
(b) that the court grant an enlargement of time to February 28 , 2006 to respond or object ,
to interrogatory production requests dated December 22, 2005. ( M_ - .
Procedural Bacjground
The plaintiff] Mario Richards, commenced this action on April 7, 2003 pursuant
to the Fair Labor Standards Act, 29 U.S.C. 201 et seq. (FLSA), claiming wages for
overtime hours worked in excess of forty hours per week.
Reason for Reguest .
On December 22, 2005 Defendant served seven (7) interrogatory requests and N
seven (7) production requests containing eleven (11) interrogatories and seven (7) (
production requests. Previously, on December 10, 2005 Defendant served approximately
seventy—one (71) interrogatory requests containing eleven (11) interrogatories each and
seventy—one (71) production requests containing seven (7) requests each on seventy—one
plaintiffs.

—— 77 ei‘”Zi""‘"·";tm
-— — mr

Case 3:03-cv—OO630—DJS Document 104 Filed O1/26/2006 Page 2 of 2 L
i l
Additional time is required in order to compile the vast amount of documents and \
infomation requested and to determine and draft objections. Considering the large i
number of plaintiffs in this case counsel is attempting to communicate and obtain the
requested information in the most efficient manner.
Opposing Counsel \
Counsel for the parties have discussed the requests and plaintiffs’ objections. I
An understanding was reached relative to the information which shall be provided
and the manner in which plaintiffs’ counsel will efficiently gather such information. _
Plaintiffs,
Mario Richards and other plaintiffs
E
By . 4 · I
Michael J. ell
Fed. Bar No. c 7841 \
143 Oneco Avenue #4
New London, CT 06320 l
Tel: (860) 447-1990 _
CERTIFICATION
I hereby certify that a copy ofthe foregoing was mailed on /F,-Mgjg
Tasos C. Paindiris, Esq. i
William Anthony, Esq. `
90 State House Sq.
Hartford, Ct 06103 4
Micha l J. e y
_..........;.l