Arredondo v. Arredondo, et al

MOTION for Extension of Time until 7/30/04 to respond to discovery

D. Conn.July 1, 2004

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT CARLOS A. ARREDONDO, in his capacity as Trustee of The 2000 Trust for the Grandchildren of Carlos A. Arredondo and Mari V. Arredondo, General Partner of Arredondo Properties Limited Partnership, Plaintiff, CIVIL ACTION NO.: v. 3:02 CV 02200 (CFD) CAESAR A. ARREDONDO, individually and in his capacity as Trustee of The 2000 Trust for the Grandchildren of Caesar A. Arredondo and Carolyn Abad Arredondo; THE 2000 TRUST FOR THE GRANDCHILDREN OF CAESAR A. ARREDONDO AND CAROLYN ABAD ARREDONDO, in its capacity as General Partner of Arredondo Properties Limited Partnership; and ARREDONDO & CO., LLC, Defendants. JUNE 30, 2004 DEFENDANT ARREDONDO & CO., LLC’S FIRST MOTION FOR EXTENSION OF TIME TO OBJECT AND RESPOND TO THE PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS DIRECTED TO DEFENDANT ARREDONDO & CO., LLC Pursuant to Fed. R. Civ. P. 6(b) and D. Conn. L. Civ. R. 7(b), the defendant, Arredondo & Co., LLC, hereby moves for an initial extension of time of thirty (30) days to object and/or respond to the plaintiff’s Second Request For Production Of Documents And Things Directed To Defendant Arredondo & Co., LLC, dated May 31, 2004. Defendant’s responses and objections would be due on June 30, 2004, and by this motion it is seeking an extension up to and including July 30, 2004 to serve its objections and responses. This is the defendant’s first motion for an extension concerning ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED Case 3:02-cv-02200-CFD Document 56 Filed 07/01/2004 Page 1 of 4 2 the set of discovery. The undersigned has inquired of opposing counsel, Attorney David Stewart, who does not object to this motion. WHEREFORE, the defendant respectfully moves for an additional extension of time to object and respond to the Plaintiff’s Second Request For Production Of Documents And Things Directed To Defendant Arredondo & Co., LLC. DEFENDANTS, CAESAR A. ARREDONDO, et al. By /s/ Edward J. Heath Craig A. Raabe (ct 04116) E-mail: craabe@rc.com Edward J. Heath (ct20992) E-mail: eheath@rc.com Robin P. Keller (ct23564) E-mail : rkeller@rc.com Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103 Tel.: (860) 275-8200 Fax: (860) 275-8299 Case 3:02-cv-02200-CFD Document 56 Filed 07/01/2004 Page 2 of 4 3 ORDER The foregoing motion having been presented to the Court, it is hereby ordered GRANTED/DENIED on this day of , 2004. BY THE COURT ________________________________ Judge/Clerk Case 3:02-cv-02200-CFD Document 56 Filed 07/01/2004 Page 3 of 4 4 CERTIFICATION This is to certify that a copy of the foregoing was sent first class mail, postage prepaid on this 30th day of June, 2004, to: Robert P. Dolian, Esq. Cummings & Lockwood LLC 107 Elm Street Stamford, Connecticut 06902 Martin J. Elgison, Esq. David J. Stewart, Esq. Dana Marty Haas, Esq. Alston & Bird LLP One Atlantic Center 1201 West Peachtree Street Atlanta, Georgia 30309-3424 /s/ Edward J. Heath Edward J. Heath Case 3:02-cv-02200-CFD Document 56 Filed 07/01/2004 Page 4 of 4