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

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l g Case 3:03-cv-00958-MRK Document 25 Filed O1/05/2004 Page 1 of 2
i UNITED STATES DISTRICT COURT ___ '
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coNArs CORPORATION, ; lm 5 5*: lil slit P
: Civil Action No. 303 0953
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EURASIA CONCEPTS, INC. : J
d.b.a. BIO IONIC, INC., : ‘ I
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PLAINTIFF’S MOTION FOR AN EXTENSION OF TIME T0 ANSWER ]
DEFENDANT’S DISCOVERY REQUESTS I
AND ORDER THEREON i
Plaintiff Conair Corporation (hereinafter "Conair”) moves the Court for an extension of
time to answer Defendant’s outstanding discovery requests until January l3, 2004. In support of . _
its motion, Plaintiff states as follows:
l. Plaintiffs responses to Defendant’s discovery requests are due today, December 29, l
2003. I i
I 2. Plaintiff attempted to contact counsel for Defendant to seek a two week extension to K
answer the discovery requests, however, there was no answer at counsel’s office. It appears that I
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there may be a problem with the phone line of counsel for Defendant as the phone repeatedly
rang and no voicemail or other answering machine picked up.
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3. Plaintiff seeks an extension of time because counsel for Plaintiff recently had surgery p
on his right wrist after a slip and fall accident earlier this month and is tmable to write or handle l
documents and, as a result, counsel for Plaintiff was delayed in working on the responses. I
4. Plaintiff hereby moves the Court for an extension of time until January 13, 2003 to
answer the Defendant’s discovery requests. i
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· i Case 3:03-cv-00958-MRK Document 25 Filed O1/05/2004 Page 2 of 2 i
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5. This motion is being made for good cause and not for purposes of delay. I
Dated: December 29, 2003 Respectfully submitted, X
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Anthony H. Handal (Ct Fed. # 03837)
Kirkpatrick & Lockhart, LLP
599 Lexington Avenue
New York, New York 10022
212-536-3900 ph l
212-536-3901 fax ·
Attorneys for Plaintiff
IT IS SO ORDERED:
Dated: l
u.s.o.J. l
` CERTIFICATE OF SERVICE |
I I I, Catherine R. Keenan, an associate with Kirkpatrick & Lockhart, LLP, counsel for Plaintiff, .
Conair Corporation, hereby certify that a copy of the foregoing Plaintiff’ s Motion for an Extension of
_ time to answer Defendant’s discovery requests and Order Thereon was served today, December 29, 2003, . i
upon all parties by placing a copy of same in first class mail, postage prepaid, addressed as follows: I
Brian T. Foley, Esq.
McGovern & Associates
. One Lafayette Place
Greenwich, CT 06830 p
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Dated: December 29, 2003 B . ‘ [gr if @,0; gc E
Catherine R. Keenan I