Plaintiffs' Second Motion for Extension of Time to Respond to Defendants' First Set of Interrogatories
Public Court Documents
January 30, 1991
4 pages
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Case Files, Sheff v. O'Neill Hardbacks. Plaintiffs' Second Motion for Extension of Time to Respond to Defendants' First Set of Interrogatories, 1991. 1c808fc5-a346-f011-8779-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/dedbaa63-eefd-476d-aee9-421a8adcffd0/plaintiffs-second-motion-for-extension-of-time-to-respond-to-defendants-first-set-of-interrogatories. Accessed November 02, 2025.
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Cv89-0360977S
MILO SHEFF, et al. SUPERIOR COURT
Plaintiffs
v. JUDICIAL DISTRICT OF
HARTFORD/NEW BRITAIN
WILLIAM A. O'NEILL, et al. AT HARTFORD
Defendants JANUARY 30, 1991
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PLAINTIFFS' SECOND MOTION FOR EXTENSION OF TIME TO RESPOND
TO DEFENDANTS' FIRST SET OF INTERROGATORIES
Plaintiffs respectfully request an extension of time until
February 19, 1991 in which to respond to Defendants’ First Set of
Interrogatories. In support of this motion, plaintiffs state the
following:
1. Plaintiffs served their responses to Defendants’ First
Set of Interrogatories on October 31, 1990.
2. After consultation with defendants, and in an effort to
resolve potential discovery disputes, plaintiffs agreed to
respond in more detail to certain interrogatories or to amend
certain interrogatory responses to clarify the issues in dispute.
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED
3. On December 3, 1990, the parties filed a Joint Motion
for Extension of Time to Disclose Expert Witnesses Pursuant to
Practice Book Section 220 (D), requiring initial identification
of experts to take place on January 15, 1991. Without waiving
any claims plaintiffs may have to seek a more complete response,
both parties have complied with the deadline set out in said
Joint Motion.
4, On December 10, 1990, plaintiffs filed a Motion for
Extension of Time to Respond to Defendants’ First Set of
Interrogatories, requesting until January 30, 1991 to respond
more fully to Defendants’ First Set of Interrogatories. The
present motion would seek to extend the January 30 deadline for
an additional 20 days.
5. The plaintiffs have been working diligently to respond to
Defendants’ First Set of Interrogatories, and need additional
time to complete their response and to coordinate the work of
several attorneys. The present motion is also needed, in part,
to make an initial evaluation of discovery materials, including
certain computer tapes, provided by defendants on January 24.
6. This is plaintiffs’ second motion for extension of time
to respond to Defendants’ First Set of Interrogatcries.
7. Defendants have been contacted and have no objection to
the granting of this Motion.
Wesley W. Horton
Moller, Horton, & Fineberg
90 Gillett Street
Hartford, CT 06105
Julius L. Chambers
Marianne Lado
Ron Ellis
NAACP Legal Defense &
Educational Fund, Inc.
99 Hudson Street
New York, NY 10013
Helen Hershkoff
John A. Powell
Adam Cohen
American Civil Liberties
Union Foundation
132 West 43rd Street
New York, NY 10036
Respectfully Submitted,
/</
Philip D. Tegeler
Martha Stone
Connecticut Civil Liberties
Union Foundation
32 Grand Street
Hartford, CT 06106
Wilfred Rodriguez
Hispanic Advocacy Project
Neighborhood Legal Services
1229 Albany Avenue
Hartford, CT 06112
John Brittain
University of Connecticut
School of Law
65 Elizabeth Street
Hartford, CT 06105
Jenny Rivera
Puerto Rican Legal Defense
and Education Fund
99 Hudson Street
New York, NY 10013
CERTIFICATE OF SERVICE |
This is to certify that one copy of the foregoing has been
mailed postage prepaid to John R. Whelan and Diane W. Whitney,
Assistant Attorney Generals, MacKenzie Hall, 110 Sherman Street,
Hartford, eT 06105 this 30th day of January, 1991.
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Philip D. Tegeler