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

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I Case 3:03-cv—01049—BNC Document 22 Filed 05/26/2005 Page 1 of 2
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l UNITED STATES DISTRICT COURT, __ F [N ;
f ` DISTRICT OF CONNECTICUT ‘ E il , il y
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, DENISE CORREA : CIVIL ACTIO »,,- . V . _ n
{ . NO.3:03CV104mRliiC)2 b A EU 515 l
H Joan E. POTTER · ; MAY 23, 2005 ` ` l ‘ i”"*"'l “‘ it y
l POSTMASTER, U.S. `
POSTAL SERVICE
PLAINTIFFS MOTION FOR EXTENSION

Plaintiff hereby moves this Court for an extension of thirty (30) days within
which to depose the Defendanfs Keeper of Records, and a Ms. Vera Wright
employed by the Defendant, and possibly those witnesses interviewed by Ms.
Wright with respect to Plaintiffs EEO Complaint filed in this matter. In support
of this motion Plaintiffs Counsel represents: ·
` 1. " ,Defendant`Has denied that Plaintiff ever exhausted the l
l administrative EEO/ EEOC requirements prior to filing suit I
in this matter. ne K , 1
2. Plaintiff maintains that she timely filed an EEO / EEOC
Complaint in this matter and that the matter was
i investigated by the Defendanfs Vera Wright, who ‘
interviewed the Plaintiff and other witnesses. i
` 3. Upon information and belief, Ms. Wright functioned as the
Defendanfs EEO/ EEOC Investigating Officer and - · l L
_ { conducted the requisite investigation ofthe Plaintiffs ‘
e Chaigééji interviewed witnesses, including Plaintiffs
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erstwhile supervisor, Ron DeMaida.
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l Case 3:03-cv—O104(£%]§NC Document 22 Filed 05/26/2005 Page 2 of 2
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4. To date, the Plaintiff has never received any report, or `
reports, of the investigation conducted by the Defendant,
despite her several requests for copies of that report.
5. Plaintiff’s Counsel has noticed the deposition of the
Defendant's Keeper- of Records and Ms. Wright for p
Thursday, ]une 2, 2005, in order to obtain all reports of any
and all EEO/ EEOC investigations conducted by the l
Defendant in this matter. · I
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6. Plaintiff’s Counsel has attempted to contact opposing E
counsel, and but was unable to ascertain the position of
counsel as of _the time of this motion.
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_ 7. I _This extension prejudices neither party.
I ` ~ PLAINTIF
DE ISE COR A
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By; `7 ‘·"·*-· l l
e M. Pilgrim \
1404 Vxiliallcy Avenue
New l-Iaven, Connecticut 06516
Fed. Bar N o. ct 14857 l
- Tel: (203) 387-2524
CERTIFICATION E
Pursuant to Fed. R. Civ. P. Rule 5(b), I hereby certify that a copy of the above was
mailed on May 2, 2005 to Anna V. Crawford, ` States Postal Service, 8
Griffin Road North, Windsor, cr 06006-0 g_ I Q —· , J
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