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Case 3:13-cv-00146-RNC Document 34 Filed 09/20/13 Page 1 of 3

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

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

LYNN ANDRUS

Plaintiff,

V.

DOONEY & BOURKE, INC. AND PETER DOONEY

Defendants.

SEPTEMBER 20, 2013

PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO DESIGNATE ALL TRIAL

EXPERTS

Pursuant to Local Rule 7(b), Plaintiff Lynn Andrus ("Plaintiff') moves this Court

for an extension of time up to and including October 28, 2013 to designate her trial

experts and to provide opposing counsel with reports of the retained experts pursuant to

Fed. R. Civ. P. 26(a)(2). Good cause exists for granting this motion as Plaintiff needs

additional time to review the Defendants' responses to her First Set of Interrogatories

and Request for Production. The Court granted the Defendants Motion for Extension of

Time to Respond to the Plaintiff's First Set of Interrogatories and Request for Production

until October 14, 2013.

This is Plaintiff's first request for an extension of time to respond to designate her

trial experts and to provide opposing counsel with reports of the retained experts

pursuant to Fed. R. Civ. P. 26(a)(2) and Defendants' counsel, Daniel L. Schwartz of Day

Pitney LLP, has indicated that the Defendants consent to the requested extension of

time.

315 Post Road West
Westport-, CT 06880

HALLORAN

SAGE LI ,

Phone (203) 227-2855
Fax (203 2276992
Juris No. 412195

Case 3:13-cv-00146-RNC Document 34 Filed 09/20/13 Page 2 of 3

THE PLAINTIFF
LYNN ANDRUS

By /s/ Timothy J. McGuire
Timothy J. McGuire of
HALLORAN & SAGE LLP
315 Post Road West
Westport, CT 06880
Fed. Bar #ct28049
Phone:203-222-4304
Fax: 203-227-6992
[email protected]
Attorney for Plaintiff

315 Post Road West
Westport-, CT 06880

- 2 -

HALLORAN

SAGE T, ,

Phone (203) 227-2855
Fax (203 2276992
Juris No. 412195

Case 3:13-cv-00146-RNC Document 34 Filed 09/20/13 Page 3 of 3

CERTIFICATION

This is to certify that on this 20th day of September, 2013, a copy of the

foregoing 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/ Timothy J. McGuire
Timothy J. McGuire

3039174v. 1

315 Post Road West
Westport, CT 06880

- 3 -

HALLORAN

SAGE LI ,

Phone (203) 227-2855
Fax (203 2276992
Juris No. 412195