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

Case 3:03-cv-01010-JBA

Document 49

Filed 09/23/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CECIL YOUNG Plaintiff, v, CITY OF BRIDGEPORT HOUSING AUTHORITY, AND COLLIN VICE, IN HER OFFICIAL CAPACITY AS EXECUTIVE DIRECTOR OF THE BRIDGEPORT HOUSING AUTHORITY AND IN HER PERSONAL CAPACITY; AND THE CITY OF BRIDGEPORT Defendants. : : : : : : : : : : : : : : :

CIVIL ACTION NO. 3:03 CV 1010 (JBA)

SEPTEMBER 21, 2004

MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S INTERROGATORIES AND REQUESTS FOR PRODUCTION DATED AUGUST 25, 2004 The undersigned Defendants, City of Bridgeport Housing Authority and Collin Vice, respectfully move this Court, pursuant to Fed. R. Civ. P. Rule 34 and D. Conn. Loc. R. Civ. Rule 7 for a thirty day extension of time to respond to the Plaintiff's First Set of Interrogatories and Requests for Production. It should be noted that the plaintiff previously served requests for production to which these defendants have responded. The Plaintiff's Interrogatories and Requests for Production were served on the Defendants on August 31, 2004 and consist of 23

Case 3:03-cv-01010-JBA

Document 49

Filed 09/23/2004

Page 2 of 3

interrogatories and 20 requests for production. The additional time is required to gather and review the requested information. On September 21, 2004, the undersigned attempted to contact plaintiff's counsel, Thomas Weihing, and was informed by his partner, John Bochanis, that Attorney Weihing was out of the country on vacation until October 4, 2004 and that Attorney Bochanis was not familiar enough with the file to consent to the extension. Attorney Bochanis asked that I represent to the court that he takes no position on the motion to extend time. This is the first extension of time these defendants have sought vis-a-vis this discovery.

THE DEFENDANTS, CITY OF BRIDGEPORT HOUSING AUTHORITY AND COLLIN VICE

By: James A. Mahar, Esq., (CT 21854) Ryan, Ryan, Johnson & Deluca, LLP 80 Fourth Street, P.O. Box 3057 Stamford, CT 06905 Phone No. 203-357-9200

-2-

Case 3:03-cv-01010-JBA

Document 49

Filed 09/23/2004

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on September ___, 2004, a copy of the above was mailed to the following counsel and pro se parties of record:

Thomas J. Weihing, Esq. Daly, Weihing & Bochanis 1115 Main Street, Suite 710 Bridgeport, CT 06604 Barbara Brazzel-Massaro, Esq. City of Bridgeport Office of the City Attorney 999 Broad Street Bridgeport, CT 06604-4328

___________________________________ James A. Mahar, Esq.
I:\Procases\1742.008\motextendtime092104.wpd 1742.008

-3-