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

Case 3:03-cv-OO9_32—SRU Document 22 Filed O1/13/2004 Paget of 3
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- UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT Zllllll JAN lb P I2= Bl-I
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PETER SYM : CIVIL ACTION CASE NO.
: 303 CV 00932 SRU
Plaintiff, :
V. JANUARY 8, 2004
ATLAS FENCE COMPANY
D.B.A. ATLAS OUTDOOR ; I
: FEDERAL BAR NO. CT04095 I
Defendant. : .
MOTION FOR ENLARGEMENT OF TIME TO ANSWER I
PLAINTIFF’S INTERROGATORIES AND REQUEST FOR PRODUCTION I
The Defendant, denominated ATLAS FENCE COMPANY d.b.a. ATLAS
OUTDOOR in the above-entitled action, respectfully requests that the Court
grant a thirty (30) day extension of time, from January 8, 2004 to February 7, I
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2004 within which to respond to Plaintiffs First Set of interrogatories and
Request for Production dated December 8, 2003. The additional time is needed
to more fully investigate the issues involved. We have been unable to confer I
adequately with our clients over the holiday season.
ORAL ARGUMENT NOT REQUESTED I
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Case 3:03-cv-OO<9$2—SRU Document 22 Filed Of}/53/2004 Page 2 of 3
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· Pursuant to Rule 9(b)(2) ofthe Local Rules of Civil Procedure, counsel for
the Defendant has conferred with Counsel for the Plaintiff, who has no objection i
to this request. Q
This is the Defendant ATLAS FENCE COMPANY's first request for an
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extension of time with respect to this time limitation.
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VVHEREFORE, the Defendant ATLAS FENCE COMPANY requests that
the deadline within which it may respond to PIaintiff's First Set of interrogatories
and Request for Production be extended up to and including February 7, 2004. ,
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THE DEFENDANT
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By:
MICHAEL P. DEVLIN, ESQ. g
Berchem, Moses & Devlin, P.C.
75 Broad Street
Milford, Connecticut 06460 t
(203) 783-l2OO
Federal Bar No. Ct 04095
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Case 3:03-cv-OO(932—SRU Document 22 Filed Oj!13/2004 Page 3 of 3 E
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° This is to certify that a copy of the foregoing motion for extension of time to
respond to the Plaintiff’s interrogatories and Production Requests was mailed this
date, first class mail, postage prepaid, to the following:
Eugene N. Axelrod, Esq.
The Employment Law Group, LLC
8 Lunar Drive l
Woodbridge, CT 06525 i
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iyiicnrxet P. oevu , Esc. ·‘ ‘l’n ,
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