Motion for Extension of Time to Respond to Plaintiffs

    NO, CV-B9-0360977 S 

MILO SHEFF, ET AL. : SUPERIOR COURT 

: JUDICIAL DISTRICT OF 
Vv. : HARTFORD/NEW BRITAIN 

AT HARTFORD 

WILLIAM A. O'NEILL, ET AL. : August 13, 1992 

MOTION FOR EXTENSION OF TIME TO RESPOND TO 
PLAINTIFFS FIFTH REQUEST FOR PRODUCTION 

AND SECOND SET OF INTERROGATORIES 

  

  

  

On July 16, 1992, the defendants received the plaintiffs’ 

Fifth Request for Production of Documents and Second Set of 

Interrogatories in the above-captioned case. The Request for 

Production lists 75 categories of material, which the plaintiffs 

are seeking. The Interrogatories pose eleven questions, some of 

which require specially designed compilations of data. In 

addition to these Requests for Production and Interrogatories, 

the plaintiffs' attorneys have inundated defense counsel with 

ORAL ARGUMENT NOT REQUESTED 
TESTIMONY NOT REQUIRED 

| 
| 
| 
| 
{ 
i 

| 
| 

 



  

    

  

  

    

letters containing lists seeking updated responses to the 

plaintiffs' four previous sets of Request for Production and 

subpoenae duces tecum, issued in conjunction with deposition 

notices, requiring the defendants to produce boxes of documents. 

A tremendous amount of time and effort by many individuals 

is being put into the task of gathering the material requested by 

the plaintiffs. Most of the material requested by the plaintiffs 

is not catalogued in any fashion and requires extensive searches. 

Despite their best efforts, the defendants cannot answer the 

plaintiffs' Fifth Request for Production and Second Set of 

Interrogatories within the thirty (30) days provided by the 

Practice Book. An additional thirty (30) days extension of time 

is necessary to allow the defendants to gather, copy, and index 

the material requested by the plaintiffs. 

This is the defendants' first request for an extension of 

time to respond to the plaintiffs' Fifth Request for Production 

and Second Set of Interrogatories. The plaintiffs' attorneys 

object to this extension of time. 

  

  

  
 



  

    

  

  

  

      

    

i Wherefore, the defendants request an extension of time until 

{September #15, : 1992. tor respond. to plaintiffs’ Fifth Request 

| Production and Second Set of Interrogatories. 

| FOR THE DEFENDANTS 

I RICHARD BLUMENTHAL 
I ATTORNEY GENERAL 

| BY 

Assistant Attorney General 
110 Sherman Street | 
Hartford, Connegticut 06105 

| Tel. 566-7173 

| / | 
| | 

| | 

| 

| 
| 

    
 



  
  

ORDER 

For good cause shown the foregoing Motion For Extension of 

Time is hereby GRANTED/DENIED. 

  

By the Court 

CERTIFICATION 
    

This is to certify that on this 13th day of August, 1992 a 

  copy of the foregoing was mailed to the following counsel of 

record: 

John Brittain, Esq. Wilfred Rodriguez, Esq. 

University of Connecticut Hispanic Advocacy Project 

School of Law Neighborhood Legal Services 

65 Elizabeth Street 1229 Albany Avenue 

Hartford, CT 06105 Hartford, CP? 06112 

Philip Tegeler, Esq. Wesley W. Horton, Esq. 

Martha Stone, Esq. Moller, Horton & 

Connecticut Civil Fineberg, P.C. 
Liberties Union 90 Gillett Street 

32 Grand Street Hartford, CT 06105 

Hartford, CT 06105 

  

       



  

    | Ruben Franco, Esq. Julius L. Chambers, Esq. 
| Jenny Rivera, Esq. Marianne Lado, Esq. 
|| Puerto Rican Legal Defense Ronald Ellis, Esq. 
|| and Education Fund NAACP Legal Defense Fund and 
{i 99 Hudson Street Education Fund, Inc. 
| 14th Floor 99 Hudson Street 
|| New York, NY 10013 New York, NY 10013 

I John A. Powell, Esq. 
'| Helen Hershkoff, Esq. 

Adam S. Cohen, Esq. 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 10036 

    
  Ml W wats” 
Assistant TM Gene 

i 

[ |