Free Motion to Stay - District Court of Connecticut - Connecticut

Case 3:00-cv-00720-JCH

Document 110

Filed 11/08/2006

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT WILLIAM CONNELLY, Plaintiff, v. DAVID COSGROVE, ET AL., Defendants. : : : : : : : : : : :

CIVIL ACTION NO. 3:00 CV 720 (JCH)

NOVEMBER 7, 2006

MOTION TO STAY Plaintiff William Connelly hereby respectfully requests a thirty (30) day stay of this action. In support of this motion, the undersigned states as follows: 1. The Court today appointed the undersigned as Pro Bono Counsel for Mr. Connelly. 2. Pending before the Court are defendants' motion for summary judgment and plaintiff's motion for leave to file a supplemental complaint. While these motions were briefed by the parties before the appearance of counsel for the plaintiff, it may be necessary or appropriate to seek to augment the record before these motions are addressed by the Court. 3. The undersigned requires a period of additional time to become more familiar with the case in order to determine whether additional discovery is necessary and whether to seek leave to augment the record with respect to either of the pending motions. 4. The undersigned has spoken today with Assistant Attorney General Robert Fiske, counsel for the defendants, who consents to the allowance of thirty (30) days for plaintiff's counsel to become familiar with the case.
ORAL ARGUMENT NOT REQUESTED
November 7, 2006 2:13 PM

Case 3:00-cv-00720-JCH

Document 110

Filed 11/08/2006

Page 2 of 2

WHEREFORE, Plaintiff William Connelly respectfully requests a brief stay of the case of thirty (30) days to allow his recently appointed Pro Bono Counsel an opportunity to become more familiar with the case. By: /s/ Jonathan B. Tropp_______________ Jonathan B. Tropp (ct11295) [email protected] Catherine Dugan O'Connor (ct22530) [email protected] William C. Mercer (ct26526) [email protected] DAY, BERRY & HOWARD, LLP One Canterbury Green Stamford, CT 06901 Tel: (203) 977-7300 Fax: (203) 977-7301

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing was mailed, by U.S. Mail, First Class Postage Prepaid on November 7, 2006, to the following:

Robert B. Fiske, III Assistant Attorney General 110 Sherman Street Hartford, CT 06105 /s/ Jonathan B. Tropp________________ Jonathan B. Tropp

71369536.1 099998-93338 November 7, 2006 2:13 PM

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