You're viewing Docket Item 30 from the case Andrus v. Dooney & Bourke, Inc. et al. View the full docket and case details.

Download this document:






UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT







Plaintiff,

LYNN ANDRUS,


v.

DOONEY & BOURKE, INC. and
PETER DOONEY






Defendants.

























:
:
:
:
:
:
:
:
:







CIVIL ACTION NO.
3:13-CV-00146 (RNC)






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.




72112758.1



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
[email protected]
Attorney for Defendants












72112758.1

-2-





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

CM/ECF System.

.






/s/ Daniel L. Schwartz
Daniel L. Schwartz




72112758.1

-3-