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

Case 3:03-cv-00977-CFD

Document 29

Filed 07/27/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WENDELL HARP and ARCHITECTS ENVIRONMENTAL COLLABORATIVE INTERNATIONAL, P.C., Plaintiffs, v. JOHN DeSTEFANO, CITY OF NEW HAVEN and NEW HAVEN BOARD OF EDUCATION, Defendants. : : : : : : : : : : : : : :

CASE NO: 3:03CV977(CFD)

JULY 26, 2005

MOTION BY CONSENT FOR ENLARGEMENT OF TIME Defendants John DeStefano, City of New Haven and New Haven Board of Education through their counsel hereby move for enlargement of time to respond to Plaintiffs' Interrogatories to all Defendants and Plaintiffs' Requests for Production dated July 4, 2005. In support of this motion, Defendants represent as follows: 1. On July 4, 2005, Plaintiffs served upon Defendants' counsel by email Plaintiffs' Interrogatories to all Defendants and Plaintiffs' Requests for Production (collectively "Plaintiffs' Discovery Requests"). 2. 3. The responses to Plaintiffs' Discovery Requests are currently due on August 6, 2005. Plaintiffs' Discovery Requests request extensive information, including information about every architect, engineer, contractor, subcontractor, and construction manager contract in excess of $100,000 for each New Haven school construction project over the last fifteen years. In addition, Plaintiffs' Interrogatories and Requests for

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Case 3:03-cv-00977-CFD

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Production request extensive information about all political contributions to Defendant DeStefano's campaigns over a 15-year period. 4. Defendants require additional time to respond to Plaintiffs' Interrogatories and Requests for Production because of the extensive nature of such requests and because certain personnel of Defendants will be on vacation or have other responsibilities with respect to the opening of new schools in the upcoming weeks. 5. This is the first request for an enlargement of time to respond to Plaintiffs' Discovery Requests requested by Defendants. 6. Defendants counsel has contacted Plaintiffs' counsel to determine Plaintiffs' position with respect to this motion for enlargement of time and Plaintiffs' counsel has no objection to the granting of this motion. WHEREFORE, Defendants request an enlargement of time of thirty days up to and including September 5, 2005 to respond to Plaintiffs' Discovery Requests.

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Case 3:03-cv-00977-CFD

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DEFENDANTS, JOHN DESTEFANO, CITY OF NEW HAVEN and NEW HAVEN BOARD OF EDUCATION By: /s/ Carolyn W. Kone Carolyn W. Kone (ct 06207) Rowena A. Moffett (ct19811) BRENNER, SALTZMAN & WALLMAN LLP Their Attorneys 271 Whitney Avenue New Haven, CT 06511 Tel. (203) 772-2600 Fax (203) 772-4008 Email: [email protected] Email: [email protected]

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Case 3:03-cv-00977-CFD

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CERTIFICATE OF SERVICE I hereby certify that the original of the foregoing was served this 26th day of July, 2005, by U.S. first class mail, postage prepaid, upon:

John R. Williams Law Offices of John Williams & Associates 51 Elm St., Ste. 409 New Haven, CT 06510 Rodger W. Lehr Deputy Corporation Counsel City of New Haven 165 Church Street New Haven, CT 06510 /s/ Carolyn W. Kone Carolyn W. Kone (ct 06207)

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