Motion for Extension of Time of File Motions for Orders Compelling Discovery

    CV 8%-0360977S   
| MILO SHEFF, et al., - QO : SUPERIOR COURT 

| Plaintiffs, : JUDICIAL DISTRICT OF 
| : HARTFORD/NEW BRITAIN 
i ve : AT HARTFORD 

WILLIAM A, O'NEILLL, et al., : 

Defendants. 5 2 OCTOBER 1, 1992 

MOTION FOR EXTENSION OF TIME TO FILE 

MOTIONS FOR ORDERS COMPELLING DISCOVERY 
  

Pursuant to the final pretrial order entered in this matter, 

the defendants have filed a number of sets of Interrogatories and 

Requests for Production. They are also in the process of | 

deposing a number of the plaintiffs' expert witnesses. 

Currently, the defendants await responses to their Second Set Of 

Interrogatories and Second Request for Production, both dated 

September 2, 1992. The defendants also have yet to receive from | 

the plaintiffs final and responsive compliance as ordered by the 

court with the defendants' First Set of Interrogatories dated 

September 20, 

NO ORAL ARGUMENT REQUESTED 
NO TESTIMONY REQUIRED       
 



  

1990. See Defendant's Motion for Revised Pretrial Order (August 

28,:.1992) at 7-9. Moreover, depositions of the plaintiffs’   expert witnesses are currently scheduled at least until October 

21, 1892, 

Pursuant to the final pretrial order, "[a]ll motions for 

orders compelling discovery shall be filed no later than October 

| 1, 1992." Under the above noted circumstances, the defendants 

| cannot file all such motions by October 1, 1992 as required by 

the final pretrial order because discovery will continue at least 

until the end of October and more likely up until the eve of 

trial. Such continued discovery may well lead to disputes which | 

will necessitate the filing of motions for orders compelling 

discovery. Consequently, the defendants request an extension of 

time until October 31 to file all motions for orders compelling 

discovery. The defendants reserve the right to request a 

postponement of the trial date for reasons which may become 

apparent after the plaintiffs have finally responded to the 

outstanding discovery requests and after the conclusion of the 

depositions in this case. 

      
 



  

  
| WHEREFORE, for the foregoing reasons, the defendants request 

an extension of time to file all motions for orders compelling 

discovery until October 31, 1992. 

FOR THE DEFENDANTS 

RICHARD BLUMENTHAL 

ATTORNEY GENERAL 

     
By: 

   ohn R. Whelan - Juris 08 
Assistant Attorney General 
110 Sherman Street 
Hartford, Connecticut 06105 
Tel. 566-7173 

   rd 

sv: LL AT 

Assistant Attorrfey General 
110 Sherman Street 

/ Hartford, Connecticut 06105 
/ Tel. 566-7173 

      
 



  

    

For a good cause shown, 

GRANTED/DENIED. 

the foregoing motion is hereby 

By the Court, 

  

Honorable Harry Hammer 

CERTIFICATION 
  

This is to certify that on this 2nd day of October, 1992 a 

copy of the foregoing .was mailed to the following counsel of 

record: 

John Brittain, Esq. 
University of Connecticut 
School of Law 
65 Elizabeth Street 
Hartford, CT-06105 

Philip Tegeler, Esq. 
Martha Stone, Esq. 
Connecticut Civil 
Liberties Union 
32 Grand Street 

Hartford, CT 06105 

Ruben Franco, Esq. 

Jenny Rivera, Esq. 
Puerto Rican Legal Defense 
and Education Fund 
99 Hudson Street 
14th Floor 

New York, NY 10013 

Wilfred Rodriguez, Esq. 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

Wesley W. Horton, Esq. 
Moller, Horton & 

Fineberg, P.C. 
90 Gillett Street 
Hartford, CT . 06105 

Julius L. Chambers, Esq. 

Marianne Lado, Esq. 

Ronald Ellis, Esq. 
NAACP Legal Defense Fund and 
Education Fund, Inc. 
99 Hudson Street 

New York, NY 10013   
  

 



John A. Powell, Esq. 
Helen Hershkoff, Esq. 
Adam S. Cohen, Esq. - 
American Civil Liberties Union 
132 West 43rd Street 
New York, NY 10036   

YS