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Case 3:13-cv-00146-RNC Document 51 Filed 01/21/14 Page 1 of 3

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

LYNN ANDRUS, (cid:9)

Plaintiff,

V.

DOONEY & BOURKE, INC. and
PETER DOONEY

Defendants.

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

JANUARY 21, 2014

JOINT MOTION TO EXTEND DISCOVERY
AND DISPOSITIVE MOTION DEADLINES

Plaintiff, Lynn Andrus ("Ms. Andrus") and Defendants, Dooney & Bourke, Inc.

("Dooney & Bourke") and Peter Dooney ("Mr. Dooney") (collectively, the "Defendants"),

jointly request that this Court extend the discovery period in this matter for three (3) months

from the currently scheduled deadline set forth in the Court's Scheduling Order (Dkt. #23) of

January 31, 2014 to April 30, 2014. In addition, Plaintiff and Defendants (collectively, the

"Parties") jointly request that this Court also extend the date for filing dispositive motions in this

matter for three (3) months from on or before March 14, 2014 to on or before June 13, 2014. In

support of their motion, the Parties state as follows:

1. (cid:9)

The Parties have conducted significant discovery to date. The Parties have

exchanged and responded to each other's initial set of interrogatories and requests for production

of documents. During such discovery, the Parties have exchanged over twenty-five thousand

pages of documents.

2. (cid:9)

Counsel for Defendants took Plaintiff's deposition on October 24, 2013.

72191985.2

Case 3:13-cv-00146-RNC Document 51 Filed 01/21/14 Page 2 of 3

3. (cid:9)

Counsel for Plaintiff took the deposition of Defendant Peter Dooney on January 9,

2014.

4.

The Parties have scheduled two additional depositions during the week of January

27-31, 2014.

5.

Good cause exists for the granting of this motion because the Parties need

_

additional time to schedule and take the depositions of multiple third-party witnesses. Plaintiff

intends to depose approximately four (4) additional fact witnesses in this matter, several of whom

are third-party witnesses that reside outside of the State of Connecticut. Defendants intend to

depose approximately two (2) additional fact witnesses in this matter, both of whom are third-

party witnesses that reside outside of the State of Connecticut. In order to find mutually

convenient dates to accommodate the schedule of these third-party witnesses and the three

attorneys representing the Parties in this case, the Parties jointly request an additional three (3)

months to complete discovery.

6.

The Parties also jointly are filing on this date a motion to postpone the settlement

conference in this matter from its currently scheduled date of February 4, 2014 until a date on or

after May 1, 2014. The Parties jointly believe that the additional discovery described herein is

needed prior to a settlement conference in this matter.

7.

The Parties' request to extend the discovery and dispositive motion deadlines set

forth above will not prejudice any party as the Parties have assented to it.

8.

This is the Parties' first request for an extension of discovery and dispositive

motion deadlines in this matter.

72191935 2 (cid:9)

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Case 3:13-cv-00146-RNC Document 51 Filed 01/21/14 Page 3 of 3

WHEREFORE, the Parties respectfully request that their Joint Motion to Extend

Discovery and Dispositive Motion Deadlines be granted.

Respectfully Submitted,

PLAINTIFF: LYNN ANDRUS

By: /s/ Timothy J. McGuire

Timothy J. McGuire (ct28049)
Halloran & Sage, LLP
315 Post Road West
Westport, CT 06880
Tel. (203) 227-2855
[email protected]

Attorney for Plaintiff

DEFENDANTS: DOONEY AND BOURKE,
INC. AND PETER DOONEY

By: /s/ Daniel L. Schwartz

Daniel L. Schwartz (ct 09862)
Day Pitney LLP
One Canterbury Green-
Stamford, CT 06901
Tel. (203) 977-7300
Fax (203) 977-7301
[email protected]

By: /s/ Thomas J. McAndrew
Thomas J. McAndrew, Esq.
Thomas J. McAndrew, Esq. & Associates
One Turks Head Place, Suite 205
Providence RI 02903
Telephone: (401) 455-0350
Facsimile: (401) 455-0882
[email protected]
ADMITTED PRO HAG VICE

Attorneys for Defendants

72191985.2 (cid:9)

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