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

Case 3:03-cv-01003-AWT

Document 31

Filed 06/17/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT VALENTINE BUCKNOR Plaintiff, v. C&S WHOLESALE GROCERS, INC. Defendant. : : : : : : : : :

CIVIL ACTION NO.: 3:03CV01003 (AWT)

JUNE 17, 2004

MOTION FOR EXTENSION OF TIME The defendant C&S Wholesale Grocers, Inc. ("C&S") hereby moves, pursuant to Local Rule 7(b), for an extension of time of thirty (30) days, up to and including July 17, 2004 in which to answer, object or otherwise respond to the Plaintiff's First Set of Interrogatories and Requests for Production dated April 18, 2004. The additional time is necessary because the Human Resources Manager with whom counsel had been coordinating C&S' responses no longer works for C&S. C&S requires additional time for someone else to become acquainted with Plaintiff's claims and discovery requests, and to coordinate with counsel to prepare C&S' responses. This is the second motion for extension of time filed with respect to a response to plaintiff's discovery requests. Despite diligent effort, the undersigned has been unable to ascertain opposing counsel's position with respect to this extension of time.

Case 3:03-cv-01003-AWT

Document 31

Filed 06/17/2004

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DEFENDANT - C&S WHOLESALE GROCERS, INC.

By

/s/Derek T. Werner Lissa J. Paris ­ ct04251 Derek T. Werner ­ ct23419

Murtha Cullina LLP CityPlace I - 185 Asylum Street Hartford, Connecticut 06103-3469 Telephone: (860) 240-6000 Facsimile: (860) 240-6150 Email: [email protected] [email protected] Their Attorneys

-2-

Case 3:03-cv-01003-AWT

Document 31

Filed 06/17/2004

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CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Motion for Extension of Time was mailed first-class, postage prepaid, on this 17th day of June, 2004 to:

Kenneth I. Friedman, Esq. 2389 Main Street Glastonbury, Connecticut 06033

/s/Derek T. Werner Derek T. Werner ­ ct23419