UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
DOONEY & BOURKE, INC. and
CIVIL ACTION NO.
SEPTEMBER 12, 2013
DEFENDANTS’ MOTION FOR EXTENSION OF TIME UPON CONSENT TO
RESPOND TO PLAINTIFF’S FIRST SET OF INTERROGATORIES AND
REQUEST FOR PRODUCTION OF DOCUMENTS
Pursuant to Local Rule 7(b)(1), Defendants Dooney & Bourke, Inc. and Peter Dooney
(collectively “Defendants”) move this Court for an extension of time of thirty (30) days up to and
including October 14, 2013 to respond to the First Set of Interrogatories and Request for
Production of Documents served by the Plaintiff, Lynn Andrus (“Plaintiff”) on August 14, 2013.
The current deadline for Defendants to respond to Plaintiff’s First Set of Interrogatories and
Request for Production of Documents is September 14, 2013. Good cause exists for granting
this motion as Defendants need additional time to gather the information and documents
responsive to Plaintiff’s discovery requests.
This is Defendants’ first request for an extension of time to respond to Plaintiff’s First Set
of Interrogatories and Request for Production of Documents and Plaintiff’s counsel, Thomas J.
McGuire of Halloran & Sage LLP, has indicated that Plaintiff consents to the requested
extension of time.
By: /s/ Daniel L. Schwartz
Daniel L. Schwartz, Esq. (ct09862)
Day Pitney LLP
One Canterbury Green
Stamford, CT 06901
Telephone: (203) 977-7300
Facsimile: (203) 977-7301
Attorney for Defendants
CERTIFICATE OF ELECTRONIC FILING
I certify that on September 12, 2013, a copy of the foregoing Consented to Motion for
Extension of Time was filed electronically and served by mail on anyone unable to accept
electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the
Court’s electronic filing system or by mail to anyone unable to accept electronic filing as
indicated on the Notice of Electronic Filing. Parties may access this filing through the Court’s
/s/ Daniel L. Schwartz
Daniel L. Schwartz