This is not legal advice
A party will try sometimes to hurry matters up and cause some sort of error. The other party can ask the Court for more time.
COMMONWEALTH OF MASACHUSETTS
WORCESTER, SS
SUPERIOR COURT
C.A.
No. 1685CV00217 D
********************************
GORDON T. DAVIS, Plaintiff
Vs.
TURTLEBOY SPORTS INC.,
AIDEN KEARNEY,
*
Defendants
********************************
PLAINTIFF’S MOTION FOR LONGER
RESPONSE TIME FOR
Background
1. The Plaintiff has filed this
Complaint against the Defendants for defamation. (Exhibit 1)
2. After filing the Complaint Defendant
continued to defame the Plaintiff in their publications and the Complaint was
amended to include the additional defamation. ( Exhibit 2)
3. The Defendants moved for dismissal
for which there is a Hearing on April 19, 2016. (Exhibit 3)
4. The Defendants sent to the Plaintiff
Request for Production of Documents and
interrogatories on March 8, 2016. (Exhibit 4)
5. The Plaintiff sent the Defendant a
Motion for a Protective Order on March 21, 2016 (Exhibit 5)
6. The Defendants on March 28, 2016 sent
the Plaintiff a revised Request for Documents. (Exhibit 6)
Motion
The Plaintiff respectfully asks the Court
to allow a longer time to respond to the discovery requests than is routinely
allowed in Rules 34 and 33. Rule 34 and Rule 33 permit the Court to change the
time to respond to discovery. The Plaintiff respectfully moves to extend
discovery to 45 day after the ruling on the Motion for Protective Order.
Argument
7. The Court’s ruling on the Defendants’
Motion to Dismiss might make discovery a moot issue.
8. Some of the information demanded by
the Defendants is confidential, privileged, and private. The Defendants and
their attorney have a history of using such information to harass, oppress, and
annoy other parties including private person. (Exhibit 7)
The Protective Order would prevent the misuse of such information and
prevent it dissemination to the public.
9. Much of the information and many of
the documents are not held by the Plaintiff, such as information regarding the
MCAD. This information or documents cannot be obtained in the normal time
limits of Rule 34.
10. The complaint is only six weeks old. The
discovery can go on for 24 months; there
is no urgency preventing the enlargement of time of the response.
Conclusion
Given the evidence and arguments above,
there is good cause to allow an enlargement of time to respond to Rules 33 and
34 to 45 days after the ruling on the Protective Order.
Respectfully
submitted,
Gordon T.
Davis Pro
se Plaintiff
Worcester
MA 01604
CERTIFICATE OF
SERVICE
I, Gordon T.
Davis, pro se Plaintiff do here by certify that I have served the a copy of the
Motion to Enlargement time to respond to Defendants’ Requests for
Interrogatories and Production of Documents by mean of first class mail to
their attorney at
Margaret M. Melican, Esq.
2 Foster St.
Worcester MA 01608
__________ ________
Gordon T.
Davis
Date
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