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

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Case 3:O3—cv—OO369-DJS Document 34 Filed O3/23/2004 Page 1 cf 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
LYNN B. KANIOS, :
: CIVIL ACTION NO.:
Plaintiff, : 303 CV 369 (DJS)
v. Z
UST, INC. and MARK ULIASZ,
: MARCH 22, 2004
Defendants. :
PLAINTIFF’S MOTION FOR EXTENSION OF
DISCOVERY DEADLINE VIS A VIS PLAINTIFF’S SECOND REQUEST
FOR PRODUCTION AND SECOND SET OF INTERROGATORIES
Plaintiff hereby requests an extension ofthe current discovery deadline of April 5, 2004
to and including April 15, 2004 for the sole purpose of allowing defendants to respond to
plaintiffs Second Request for Production of Documents and Second Set of Interrogatories
(attached hereto as A and E respectively) which were served on defendants on March 16, 2004
and are directed toward defendants’ newly-asserted defenses to plaintiffs Amended Complaint.
Specifically, these interrogatories and docurnent requests target det`endants’ afiinnative defenses
to the Eighth Count of plaintiffs Amended Complaint asserting breach of the Family Medical
Leave Act.
As indicated by the correspondence attached hereto as Exhibit C from opposing counsel,
Mary A. Garnbardella, defendants have taken the position that they need not respond to these
interrogatories and document requests under the current scheduling order. Specifically,
defendants have articulated that the interrogatories and document requests were not propounded
on a date sufficient to allow their response within the discovery deadline (ie., the response
deadline falls outside the discovery deadline by 10 days).

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Case 3:O3—cv—OO369;DJS Document 34 Filed O3/23/2004 Page 2 0f 3
The purpose of this Motion is to seek extension of the discovery deadline in order to allay
defendants’ concerns regarding same and to require responses to said discovery. As indicated by
the attached letter (Exhibit C), opposing counsel objects to this Motion, evidently asserting once
again that plaintiff has been guilty of untoward delay, despite the fact this is but a 10-day
discrepancy and plaintiff has proceeded with discovery as expeditiously as possible after
defendants unilaterally haired same as indicated in the recently-decided motion for protective
order and opposition thereto.
This is the tirst niotion to extend the discovery deadlines requested solely by plaintiff
WHEREFORE, plaintiff respectfully requests that this Motion be granted.
/
E H; -· ‘
.»•_i•""”" ‘ ucas (CT00517)
Michel Bayonne (CT24628)
Attornsysfor Lynn B. Kanim
Martin Lucas & Chiofii, LLP
177 Broad Street
Stamford, CT 06901
Phone: (203) 973-5200
Fair: (203) 973-5250
slucas@nilc—law.corn
[email protected]
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Case 3:O3—cv—OO369¥DJS Document 34 Filed O3/23/2004 Page 3 0f 3
CERTIFICATE OF SERVICE
This is to certify t.hat on this 22nd day of March .2004, the foregoing was mailed, first
class, postage prepaid, to:
Steven J. Yotures, Esq.
Mary A. Garnbardella, Esq.
Epstein, Becker Sc Green, P.C.
One Landmark Square
Stamford, Connecticut O69()1~2681 .
Phone: (203) 348-3737 K
Scott R cas
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