On May 27, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Ironhorse Auto, Llc, D B A Central Hyundai,
and
Brent Mattson,
for T90 - Torts - All other
in the District Court of Windham County.
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DOCKET NO.: WWM-CV-21-6022016-S : SUPERIOR COURT
:
IRONHORSE AUTO, LLC d/b/a :
CENTRAL HYUNDAI : J. D. OF WINDHAM
:
vs. : AT PUTNAM
:
BRENT MATTSON : DECEMBER 13, 2021
PLAINTIFF’S SECOND MOTION FOR EXTENSION OF TIME
TO RESPOND TO DISCOVERY
The Plaintiff in the above-captioned case, Ironhorse Auto, LLC d/b/a Central
Hyundai respectfully moves for an extension of time of Thirty (30) days, from December
20, 2021 to, through and including January 18, 2022, within which to object to and/or
otherwise respond Defendant’s Interrogatories and Requests for Production dated September
21, 2021.
Counsel for the Plaintiff requires this additional time due to the following factors,
which include the effects of the Coronavirus Pandemic in Connecticut:
1. The Plaintiff has been traveling out of state for several weeks, and therefore,
counsel for the Plaintiff hasn’t been able to confer with his client in order to fully and
accurately respond to and/or object to the Defendant’s First Set of Interrogatories and
Requests for Production.
2. The Defendant has propounded 44 Interrogatories and 25 Document Requests,
which is a large discovery request.
3. Due to the large size of the document request, and other factors set forth
herein, Plaintiff’s counsel requires additional time to object to and/or otherwise respond to
the Defendant’s Interrogatories and Requests for Production.
4. The Plaintiff is currently disputing the Defendant’s Motion to Strike, which
the Plaintiff strenuously opposes. This Court has scheduled oral argument on the
Defendant’s motion for January 10, 2022, and the Court will have 120 days after that date to
issue a written memorandum of decision.
5. The Plaintiff is unsure as to what claims will be viable after the Defendant’s
Motion to Strike is heard, and accordingly, that decision will impact the discovery in this
case. Based on the scheduled date for the oral argument on the Defendant’s motion, the
uncertainty regarding the status of the Plaintiff’s Complaint may not be resolved for several
months.
6. Due to the pandemic, the firm is currently without a litigation paralegal.
7. The press of business has become more extensive as this year draws to a close,
requiring Plaintiff’s counsel to seek more time to object to and/or otherwise respond to the
Defendant’s Interrogatories and Requests for Production.
8. This is the Plaintiff’s Second (2nd) request for an extension of time to object
to and/or otherwise respond to discovery.
9. This request for an extension of time will not prejudice any party to this case,
2
and will not affect the trial of this matter. The Plaintiff has not filed a certificate of closed
pleadings, and this Court has not scheduled this case for trial.
CONCLUSION
WHEREFORE, for all of the foregoing reasons, the Plaintiff respectfully moves for
an extension of time of Thirty (30) days from December 20, 2021 to, through, and including
January 18, 2022, within which to object to and/or otherwise respond to Defendant’s
Interrogatories and Requests for Production dated September 21, 2021.
THE PLAINTIFF -
IRONHORSE AUTO, LLC d/b/a
CENTRAL HYUNDAI
By: //s// 103001
John M. Wolfson, Esq.
Benjamin M. Wattenmaker, Esq.
FEINER WOLFSON LLC
One Constitution Plaza - Suite 900
Hartford, CT 06103
Tel. (860) 713-8900
Fax. (860) 713-8905
Juris No. 415049
jwolfson@feinerwolfson.com
bwattenmaker@feinerwolfson.com
3
CERTIFICATION
I certify that a copy of the above was or will immediately be mailed or delivered
electronically or non-electronically on December 13, 2021 to all counsel and self-represented
parties of record and that written consent for electronic delivery was received from all counsel and
self-represented parties of record who were or will immediately be electronically served:
William J. O’Sullivan, Esq.
O’Sullivan McCormack Jensen & Bliss PC
180 Glastonbury Boulevard, Suite 210
Glastonbury, CT 06033
Phone: (860) 258-1993
Fax: (860) 258-1991
Email: wosullivan@omjblaw.com
/s/ 103001
John M. Wolfson
4
Document Filed Date
December 13, 2021
Case Filing Date
May 27, 2021
Category
T90 - Torts - All other
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DOCKET NO.: WWM-CV-21-6022016-S : SUPERIOR COURT : IRONHORSE AUTO, LLC d/b/a : CENTRAL HYUNDAI : J. D. OF WINDHAM : vs. : AT PUTNAM : BRENT MATTSON : DECEMBER 13, 2021 PLAINTIFF’S SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY The Plaintiff in the above-captioned case, Ironhorse Auto, LLC d/b/a Central Hyundai respectfully moves for an extension of time of Thirty (30) days, from December 20, 2021 to, through and including January 18, 2022, within which to object to and/or otherwise respond Defendant’s Interrogatories and Requests for Production dated September 21, 2021. Counsel for the Plaintiff requires this additional time due to the following factors, which include the effects of the Coronavirus Pandemic in Connecticut: 1. The Plaintiff has been traveling out of state for several weeks, and therefore, counsel for the Plaintiff hasn’t been able to confer with his client in order to fully and accurately respond to and/or object to the Defendant’s First Set of Interrogatories and Requests for Production. 2. The Defendant has propounded 44 Interrogatories and 25 Document Requests, which is a large discovery request. 3. Due to the large size of the document request, and other factors set forth herein, Plaintiff’s counsel requires additional time to object to and/or otherwise respond to the Defendant’s Interrogatories and Requests for Production. 4. The Plaintiff is currently disputing the Defendant’s Motion to Strike, which the Plaintiff strenuously opposes. This Court has scheduled oral argument on the Defendant’s motion for January 10, 2022, and the Court will have 120 days after that date to issue a written memorandum of decision. 5. The Plaintiff is unsure as to what claims will be viable after the Defendant’s Motion to Strike is heard, and accordingly, that decision will impact the discovery in this case. Based on the scheduled date for the oral argument on the Defendant’s motion, the uncertainty regarding the status of the Plaintiff’s Complaint may not be resolved for several months. 6. Due to the pandemic, the firm is currently without a litigation paralegal. 7. The press of business has become more extensive as this year draws to a close, requiring Plaintiff’s counsel to seek more time to object to and/or otherwise respond to the Defendant’s Interrogatories and Requests for Production. 8. This is the Plaintiff’s Second (2nd) request for an extension of time to object to and/or otherwise respond to discovery. 9. This request for an extension of time will not prejudice any party to this case, 2 and will not affect the trial of this matter. The Plaintiff has not filed a certificate of closed pleadings, and this Court has not scheduled this case for trial. CONCLUSION WHEREFORE, for all of the foregoing reasons, the Plaintiff respectfully moves for an extension of time of Thirty (30) days from December 20, 2021 to, through, and including January 18, 2022, within which to object to and/or otherwise respond to Defendant’s Interrogatories and Requests for Production dated September 21, 2021. THE PLAINTIFF - IRONHORSE AUTO, LLC d/b/a CENTRAL HYUNDAI By: //s// 103001 John M. Wolfson, Esq. Benjamin M. Wattenmaker, Esq. FEINER WOLFSON LLC One Constitution Plaza - Suite 900 Hartford, CT 06103 Tel. (860) 713-8900 Fax. (860) 713-8905 Juris No. 415049 jwolfson@feinerwolfson.com bwattenmaker@feinerwolfson.com 3 CERTIFICATION I certify that a copy of the above was or will immediately be mailed or delivered electronically or non-electronically on December 13, 2021 to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were or will immediately be electronically served: William J. O’Sullivan, Esq. O’Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: (860) 258-1993 Fax: (860) 258-1991 Email: wosullivan@omjblaw.com /s/ 103001 John M. Wolfson 4