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Joseph A. Hirsch, Esq.

Atty. Id. No. 66640

HIRSCH & HIRSCH

110 Bala Avenue

Third Floor

Bala Cynwyd, Pennsylvania 19004

Telephone (610) 660-9955 Attorney for Plaintiff

 

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LAURIE E. SWEIGARD :

Plaintiff : CIVIL ACTION NO.

: 02-2755

V. :

:

CHOICE SERVICES INTERNATIONAL, :

INC., ET AL :

Defendants :

MOTION FOR EXTENSION OF TIME

FOR DISCOVERY AND RELATED DEADLINES

1. Plaintiff filed her Complaint herein on May 8, 2002.

2. Defendants’ Answer was filed on or about May 30, 2002.

3. The Plaintiff served her discovery requests on Defendants or

about June 20, 2002.

4. Defendants’ served their discovery requests on Plaintiff on

or about June 28, 2002.

5. Plaintiff’s responses to Defendants’ discovery requests were

served on or about July 25, 2002.

6. On September 6, 2002, Plaintiff filed a Motion to Compel

Answers to Interrogatories and Production of Documents, and

said motion was granted on September 10, 2002.

Case 2:02-cv-02755-JCJ Document 12 Filed 10/09/2002 Page 1 of 7
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7. On September 9, 2002, Plaintiff received Defendants’

objections and partial responses to her interrogatories and

document requests.

8. Thereafter the Defendants have provided some additional

documents and responses, and have agreed to search for and

provide additional documents.

9. On September 26, 2002, the Plaintiff filed a Second Motion

to Compel Production of Documents and for Attorneys Fees and

Costs concerning certain disputed documents being withheld

by Defendants under a claim of privilege. On October 3,

2002, Defendants reconsidered their position and produced

the remaining documents that were the subject of Plaintiff’s

Second Motion to Compel. Said Motion remains outstanding as

to the issue of attorneys fees and costs.

10. The Defendants are continuing to produce certain other

documents, and have agreed to continue to cooperate with

Plaintiff’s requests. (Exhibits A and B).

11. Despite the aforementioned discovery disputes and the

resultant delays, the parties have taken six (6)

depositions, and three additional depositions are currently

scheduled.

12. Plaintiff just received discovery responses concerning the

benefits provided to certain classes of employees of

Defendants for purposes of preparing an expert report on

economic losses. Certain wage data was provided on

Case 2:02-cv-02755-JCJ Document 12 Filed 10/09/2002 Page 2 of 7
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September 23, 2002, and Defendants agreed to provide

supplemental information on benefits.

13. Plaintiff is now in the process of forwarding this

information to her economic expert for analysis and the

preparation of a report. It is anticipated that additional

time will be required to prepare this report.

14. Plaintiff also requires additional time to receive and

review the documents still being produced by Defendants and

determine whether or not additional depositions are

warranted.

15. Based upon information learned in discovery, Plaintiff has

served a supplemental request for production of documents,

and the response to said request is not yet due.

16. The Plaintiff’s efforts to promptly prepare this matter for

trial have been hampered by the delay in receiving responses

to discovery requests. Additional delay resulted from

Plaintiff’s preparation for trial in a case before Judge

Clarence C. Newcomer of this Court in September 2002.

17. As a result of the foregoing, the Plaintiff requires an

extension of the discovery deadline and the related

deadlines set forth in this Court’s scheduling order dated

July 9, 2002. 

18. Plaintiff’s counsel hereby certifies that this motion is

uncontested.

WHEREFORE, the Plaintiff respectfully requests this

Case 2:02-cv-02755-JCJ Document 12 Filed 10/09/2002 Page 3 of 7
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Honorable Court to grant her Motion, and extend by forty-five

(45) days the discovery deadline and related deadlines set forth

in the Scheduling Order dated July 9, 2002.

Date: October 7, 2002 

JOSEPH A. HIRSCH, ESQ.

Attorney for Plaintiff

Case 2:02-cv-02755-JCJ Document 12 Filed 10/09/2002 Page 4 of 7
Joseph A. Hirsch, Esq.

Atty. Id. No. 66640

HIRSCH & HIRSCH

110 Bala Avenue

Third Floor

Bala Cynwyd, Pennsylvania 19004

Telephone (610) 660-9955 Attorney for Plaintiff

 

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LAURIE E. SWEIGARD :

Plaintiff : CIVIL ACTION NO.

: 02-2755

V. :

:

CHOICE SERVICES INTERNATIONAL, :

INC., ET AL :

Defendants :

Certificate of Service

I, Joseph A. Hirsch, Esq., hereby certify that on this date,

I served a true and correct copy of the Plaintiff’s Motion for

Extension of Time for Discovery and Related Deadlines upon Peter

D. Bludman, Esq., counsel for Defendants, at Margolis Edelstein,

The Curtis Center, 4th Floor, Independence Square West,

Philadelphia, PA 19106-3304, via first fax (215-922-1772) and

first class mail, postage prepaid.

Date: 

JOSEPH A. HIRSCH, ESQUIRE

Case 2:02-cv-02755-JCJ Document 12 Filed 10/09/2002 Page 5 of 7
Joseph A. Hirsch, Esq.

Atty. Id. No. 66640

HIRSCH & HIRSCH

110 Bala Avenue

Third Floor

Bala Cynwyd, Pennsylvania 19004

Telephone (610) 660-9955 Attorney for Plaintiff

 

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LAURIE E. SWEIGARD :

Plaintiff : CIVIL ACTION NO.

: 02-2755

V. :

:

CHOICE SERVICES INTERNATIONAL, :

INC., ET AL :

Defendants :

O R D E R

AND NOW, this day of , 2002,

upon consideration of the Plaintiff’s Motion for Extension of

Time for Discovery and Related Deadlines, and it appearing that

said Motion is not opposed, it is hereby ORDERED that the

Plaintiff's motion is GRANTED, and the deadlines set forth in

this Court’s order dated July 9, 2002 are hereby extended by

forty-five (45) days.

BY THE COURT

 

, J.

Case 2:02-cv-02755-JCJ Document 12 Filed 10/09/2002 Page 6 of 7
Joseph A. Hirsch, Esq.

Atty. Id. No. 66640

HIRSCH & HIRSCH

110 Bala Avenue

Third Floor

Bala Cynwyd, Pennsylvania 19004

Telephone (610) 660-9955 Attorney for Plaintiff

 

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LAURIE E. SWEIGARD :

Plaintiff : CIVIL ACTION NO.

: 02-2755

V. :

:

CHOICE SERVICES INTERNATIONAL, :

INC., ET AL :

Defendants :

CERTIFICATION PURSUANT TO LOCAL RULE 7.1(b)

I, Joseph A. Hirsch, Esq., hereby certify that the foregoing

Motion for Extension of Time is uncontested.

Date: 

JOSEPH A. HIRSCH, ESQUIRE

Case 2:02-cv-02755-JCJ Document 12 Filed 10/09/2002 Page 7 of 7