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

Case 3:03-cv-01040-PCD Document 15 Filed O3/O9/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
J OSEPHINE SULLIVAN CIVIL ACTION NO.
: 3 :03CVl 040 (PCD)
Plaintiff, :
v.
CARSON PRODUCT DEVELOPMENT,
INC., L’OREAL USA PRODUCTS, INC., :
& SALLY BEAUTY CO., INC. :
Defendants. March 9, 2004
MOTION FOR EXTENSION OF TIME TO SERVE RESPONSES
TO DISCOVERY REQ QUESTS
Defendants respectfully move, pursuant to Federal Rule of Civil Procedure 6 (b) and
Local Rule 7(b)(l)(b), for an extension of time, through and including March 29, 2004, to
answer Plaintiffs interrogatories and document requests. In support of this motion, Defendants
state the following:
l. Defendants’ answers and interrogatories are presently due on March 11, 2004;
2. That the Defendants have inquired of counsel for the Plaintiff, who consents to this
extension request;
3. That this is the Defendants’ first motion for extension of time; and

Case 3:03-cv-01040-PCD Document 15 Filed O3/O9/2004 Page 2 of 3
4. That there is good cause for this extension, in that counsel for Defendants needs
additional time to consult with his clients and prepare an adequate response.
DEFENDANTS V
SALON PRODUCTS, INC., L’OREAL USA
PRODUCTS, INC., SALLY BEAUTY CO., INC.,
j /
By: Q
Jeremy Zimmermann (ct04l54)
Daniel Kalish (ct24350)
Wiggin and Dana, LLP
One Century Tower
- New Haven, CT 06508
(203) 498-4400

Case 3:03-cv-01040-PCD Document 15 Filed O3/O9/2004 Page 3 of 3
CERTIFICATION
This is to certify that a true copy of the foregoing was served via certified mail, return
receipt requested, this 9th day of March 2004, to the following counsel of record:
Lorenzo J . Cicchiello, Esq.
Cicchiello & Cicchiello
582 West Main St.
Norwich, CT 06360