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

Case 3:01-cv-02183-AVC

Document 38

Filed 03/03/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EDWARD BOGANSKI VS. CITY OF MERIDEN BOARD OF EDUCATION, ET AL. : : : : NO. 3:01CV2183(AVC)

MARCH 1, 2004

PLAINTIFF'S FIRST MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION Pursuant to Local Rule 7(b), the plaintiff, Edward Boganski, respectfully requests an extension of time of sixty (60) days, up to and including May 26, 2004, to comply with defendants' interrogatories and requests for production, dated February 27, 2004. In support of this motion, the plaintiff represents as follows: 1. He was served with defendants' interrogatories and requests for production on or about February 28, 2004. 2. Counsel is in the process of ascertaining responses to such

requests and needs the additional time to comply with defendants' requests. 3. Defendants' attorney was contacted by this office and represents

that she has no objection to the granting of this request.

Case 3:01-cv-02183-AVC

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Filed 03/03/2004

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4.

This is the plaintiff's first request for an extension of time to

respond to defendants' interrogatories and requests for production. 5. No trial date has been set in this matter.

WHEREFORE, the plaintiff respectfully requests the court grant this motion for the reasons stated above. THE PLAINTIFF

BY John R. Williams Williams and Pattis, LLC 51 Elm Street, Suite 409 New Haven, CT 06510 203.562.9931 FAX: 203.776.9494 Federal Bar No. ct00215 His Attorney

Case 3:01-cv-02183-AVC

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Filed 03/03/2004

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CERTIFICATION This is to certify that a copy of the foregoing was sent via first class mail, postage prepaid, on March 1, 2004, to the following counsel of record: Attorney Alexandria L. Voccio Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114-1190 Attorney Robert J. Murphy Attorney Michael McKeon Sullivan Schoen Campane & Connon 646 Prospect Avenue Hartford, CT 06105 Attorney Deborah L. Moore Corporation Counsel's Office 142 East Main Street, Room 240 Meriden, CT 06450 Attorney Gary Phelan Klebanoff & Phelan, P.C. 433 South Main Street, Suite 117 West Hartford, CT 06110

John R. Williams