Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00944-RNC

Document 35-2

Filed 09/13/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PRISONER CIVIL NO. 3:03CV00944(RNC)

JAMES MCKINNON, Plaintiff v. YVONNE, ET AL., Defendants

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SEPTEMBER 8, 2004

AFFIDAVIT OF ASSISTANT ATTORNEY GENERAL KATHLEEN A. KEATING I, Kathleen A. Keating , being duly sworn, state that: 1. 2. 3. 4. I am over 18 years of age, and believe in the obligation of an oath. I am an assistant attorney general for the State of Connecticut. On August 12, 2004, I was assigned the above captioned case and filed an appearance. On August 12, 2004, the court issued a scheduling order directing that answers be filed

on October 16, 2004, that discovery be completed by February 16, 2005, and that dispositive motions be filed by March 16, 2005. 5. 6. On August 17, 2004, the plaintiff filed a notice of service of summons on defendants. I cannot by affidavit present facts essential to justify the defendants' opposition to the

plaintiff's motion for summary judgment, because additional time is necessary to permit affidavits to be obtained, depositions to be taken, and discovery to be had.

Case 3:03-cv-00944-RNC

Document 35-2

Filed 09/13/2004

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I have read the foregoing affidavit, and it is true and accurate to the best of my knowledge and belief.

__/s/_______________________________________ Kathleen A. Keating Subscribed and sworn to before me this _____ day of September 2004.

__/s/_______________________________________ Commissioner of the Superior Court / Notary Public

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