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

· Case 3:03-cv—0O378—%S Document 23 Filed 10/21 /2033 Page 1 of 3 {

IN THE UNITED STATES DISTRICT COURT p 2, gu I
FOR THE DISTRICT OF CONNECTICUT mg] UU 2i
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DONNA OWEN, )
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Plaintiff, ) CIVIL ACTION NO. p
) 3:03 CV 378 (DJS)
vs. ) i
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GEORGIA—PACIF IC CORPORATION, )
)
Defendant. ) October 21, 2003
DEFENDANT’S MOTION FOR EXTENSION OF TIME
TO FILE MOTION TO COMPEL I
Defendant, Georgia-Pacific Corporation (°‘Georgia—Pacitic" and/or “Defendant"), by its
undersigned counsel, moves the Court for an additional extension of time of 20 days to file a
Motion to Compel regarding Plaintiffs Responses to Defendant’s First Set of Interrogatories and
First Requests for Production of Documents. In support of this Motion, Defendant states:
l. Plaintiff has served responses to Defendant’s First Set of Interrogatories and First
Requests for Production of Documents, which Defendant initially found unsatisfactory. The
parties have met and conferred regarding the responses and believe that they have resolved all
outstanding issues.
2. Defendant previously sought two extensions of time to tile a Motion to Compel to
allow the parties to try to resolve their disputes and to allow Plaintiff time to obtain and produce
responsive documents and the Court granted those requests through and including October 22,
2003. Plaintiff has produced additional documents but needs additional time to obtain and I
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1 ` Case 3:03-cv—0O378—IEd§ Document 23 Filed 10/21 /26903 Page 2 of 3
f produce others, and Defendant therefore requests that the Court extend the time to file a Motion
l to Compel through and including November 10, 2003. i
3. Counsel for Plaintiff does not oppose to the requested extension of time for
Georgia-Pacific to file a Motion to Compel. The requested extension will not prejudice either I
party or result in a delay in these proceedings. {
WHEREFORE, for the foregoing reasons and for good cause shown, Georgia-Pacific i
respectfully moves the Court for a 20-day extension of time — through and including `
November 10, 2003 — to file a Motion to Compel regarding Plaintiffs Responses to Defendant’s
First Set of Interrogatories and First Requests for Production of Documents. K
f- z
Respectfully submitted this J! 5 day of October, 2003. l
GEORGIA-PACIFIC CORPORATION
By: ·‘ an
Gregor B. o s (CT06095)
McCARTER & ENGLISH, LLP
CityPlacel, 185 Asylum Street
Hartford, CT 06103-3495 I
(860) 275-6700
Randall D. Avram (CT24717)
Richard D. Haygood (CT247l S)
KILPATRICK STOCKTON LLP
3737 Glenwood Avenue, Suite 400
Raleigh, North Carolina 27612
(919) 420-1700
(919) 510-6107 (facsimile) i
Attorneys for Defendant i
Georgia-Pacific Corporation
1
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[ ` Case 3:03-cv—OO378—[%J% Document 23 Filed 10/21/28055 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that I have this date served DEFENDANT’S MOTION FOR
EXTENSION OF TIME TO FILE MOTION TO COMPEL by depositing a true and correct copy I
I of same in the United States mail with adequate first-class postage affixed thereon, addressed as
follows:
Stephen P. Horner, Esq.
Law Office of Stephen P. Horner I
2183 Boston Post Rd.
Darien, CT 06820 I
or I
This 6I/ day of October, 2003.
4h£.4/.111 ` ___ I
Greg y I/ • es i
1»1ARTFo11D; 601114.01 I
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