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

AV if C 1#gCCV-OO53()-[)J3 Document 101 Filed 01/10/2006 Page 1*5
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UNITED STATES DISTRICT COURT w _1 — R » 1
DISTRICT OF CONNECTICUT ` 1 1
MARIO RICHARDS, : · · -1 (_ .·, .._ .._
on behalf 0f himself and : CIVIL ACTION NO. I ` ` o 11* 1
all others similarly situated : _ 3:03 CV00630 (DJS) . _ 1
PLAINTIFFS, 5 : ` 1
1 V. Z A 1
1 COMPUTER SCIENCES
CORPORATION : December 7, 2005
DEFENDANT.
PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME
RE: DISCOVERY RESPONSES
Plaintiff Mario Richards and other plaintiffs, request pursuant to Local Rule 7
(b) that the court grant an enlargement of time to January 30 , 2006 to respond or object
to interrogatory and production requests dated December 8, 2005.
Procedural Bacljground
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
Defendant served approximately seventy—one (71) interrogatoiy requests
containing eleven (11) interrogatories each and seventy-one (71) production requests
containing seven (7) requests each on seventy—one plaintiffs on or about December 10,
2005. Additional time is required in order to compile the vast amount of documents and
infomation requested and to determine and draft objections.
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Case 3:03-cv—00630—DJS Document 101 Filed 01/1 O/2006 Page 2 of 2 `
Opposing Counsel
Counsel for the plaintiff has made attempts to ascertain the position of opposing
counsel in this matter. Plaintiffs cotmsel is unaware of opposing counse1’s position
A relative to this request.
Plaintiff
Mario Richards
By
Michael J. olly
Fed. Bar No. ct] 841
143 Oneco Ave ue
Suite 4
New London, CT 06320
Tel: (860) 447-1990
CERTIFICATION
I hereby certify that a copy of the foregoing was mailed on M
To: `
Tasos C. Paindiris, Esq.
William Anthony, Esq.
90 State House Sq. _
Hartford, Ct 06103 i
Michael . Mel