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

Case 3:0 -cv—OO3E5_9—DJS Document 20 Filed O1/13/2004 Paget of3 {
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LYNN B. KANI S : Civil Action Nld] Rl
Plaintiff, E
vs. I
UST INC. and M RK ULIASZ,
Defendants. January 12, 2004
MOTIO FOR EXTENSION OF TIME FOR DISCOVERY SCHEDULE
PLEASE AKE NOTICE that pursuant to Federal Rules of Civil Procedure Rule 6(b)
and Local Rules f Civil Procedure Rule 9(b)3, counsel for the Defendants in this matter hereby I
respectfully mov to extend the time period for completion of discovery by thirty (30) days, or I
until March 3, 2 O4, and to correspondingly extend the deadline for filing any dispositive
motions to April 5, 2004. In support of good cause for the granting of this motion, counsel
submits the follo `ng:
1. W ile a significant amount of discovery has already been completed in this
matter, the additi nal time is needed to take the deposition of several additional witnesses, y
including the con inued deposition of the Plaintiff and, potentially, those of medical providers
from whom Plain iff sought treatment.
2. De endants have, through duly served discovery requests, sought production of
Plaintiffs medic records and/or execution of authorizations to obtain such records. To date,
while some recor s have been produced by Plaintiff, some remain outstanding.
3. Th additional time will allow Defendants an opportunity to obtain such records
which are critical to Plaintiff s claims for damages. Moreover, the additional time will enable
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Defendants an op ortunity to complete any depositions necessary which may be occasioned by C
the production of he medical records in question.
4. Sc tt R. Lucas, Esq., counsel for Plaintiff, consents to the granting of this request.
5. Th s is the second extension of time requested as to these time limitations.
WHERE ORE, counsel for the Defendants request that this Court extend the deadlines p
as set forth herein
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EPSTEIN BECKER & GREEN, P.C.
Attorneys for Defendants ;
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Mary . G mb ella, Esq.
Federa Ba N0. 05386
Epstein Bec er reen, P.C.
One Land ark Square, Suite 1800
Stamford, CT 06901
(203) 348-3737
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CERTIFICATION
The under igned hereby certifies that a copy of the foregoing Motion for Extension of Time
for Discovery Sch dule was sent via first class mail, postage prepaid, this 12th day of January, 2004
to counsel of recor for the plaintiff as follows:
Scott R. Lucas, Esq.
Martin, Lucas & Chiofii, LLP
177 Broad Street
Stamford, CT 06901
Steven J. Younes
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