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

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Case 3:03-cv-00986-JCH Document 21 Filed 12/31/2003 Page 1 of 3 I
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UNITED STATES DISTRICT COURT . . t 1 A \
DISTRICT OF CONNECTICUT E
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SUSAN E. WOOD, CIVIL ACTION NO,
3:03-CV-986 (JCHj‘ Q
Plaintiff I
— against- -
SEMPRA ENERGY TRADING i
C()RpORATION_ December 30, 2003 V I
Defendant. i
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DEFENDANT’S SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO
‘ PLAINTIFF’S FIRST SET OF DISCOVERY RE UESTS
Pursuant to Local Rule of Civil Procedure 7(b), Defendant hereby moves for a nine (9)
day extension of time, up to and including January 9, 2004, within which to serve its responses to
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Plaintiffs First Set of Interrogatories and Requests for Production of Documents. Defendant
requests this extension in order to gather information required to address each of Plaintiffs
discovery requests. Despite diligent efforts, Defendant has been unable to complete its responses
to Plaintiffs discovery requests, primarily as a result of the winter holidays and the vacation
schedules of pertinent witnesses.
On December 30, 2003, Plaintiffs counsel, Brendan O’Rourke, consented to the ‘
requested extension of time. This is Defendant’s second request to extend the time within which
to respond to Plaintiffs First Set of Interrogatories and Requests for Production of Documents.
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ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED `
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__ Case 3:03-cv-009553JCH Document 21 Filed 12/%*:3003 Page 2 of 3 I
WHEREFORE, Defendant respectfully requests that this Motion for Extension of Time i
to Respond to Plaintiff s First Set of Interrogatories and Requests for Production of Documents,
up to and including January 9, 2004, be granted.
DATED: December 30, 2003 Respectfully submitted, *
DEFENDANT SEMPRA ENERGY TRADING
CORPORATION
By: , Og i
Mary C. Dollarhide (ct12251
Peter M. Schultz (ctl9425)
Paul, Hastings, Janofsky & Walker, LLP
1055 Washington Boulevard {
Stamford, CT 06901-2217 ’
Telephone: (203) 961-7400
Facsimile: (203) 359-3031
[email protected] l
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, Case 3:03-cv-OO9(86iJCH Document 21 Filed 12/?1vS2003 Page 3 of 3 I
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CERTIFICATE OF SERVICE I
This is to certify that on this 30th day of December 2003, a copy of the foregoing
was forwarded via facsimile and regular mail to counsel for the Plaintiff at the following address: I
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Brendan J. O’Rourke, Esq. |
0’ROURKE & ASSOCIATES, LLC
27 Pine Street |
New Canaan, CT 06840
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Peter M. Schu ta
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