Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:02-cv-00230-EBB

Document 190

Filed 08/01/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ROBERT F. SALATTO, JR. Plaintiff VS. : : NO. 3:02 CV 0230 (EBB) (JGM)

TOWN OF BRANFORD, ET AL. : AUGUST 1, 2006 Defendants CONSENT TO EXTEND TIME IN WHICH TO FILE SUPPLEMENTAL MEMORANDUM IN SUPPORT OF OPPOSITION TO MOTION TO VACATE DEFAULT JUDGMENTS The undersigned respectfully moves to extend the time in which to file a Supplemental Memorandum in Support of Opposition to Motion to Vacate Default Judgments to and including Friday, August 18, 2006. Memorandum is currently due Friday, August 4, 2006. There have been no prior requests for such relief. COUNSEL FOR DEFENDANTS CONSENTS PROVIDED THE TIME IN WHICH HE MUST REPLY IS EXTENDED FOR AN EQUAL PERIOD OF TIME. Reasons for granting the requested relief. 1. I recently entered an Appearance for the previously pro se plaintiff. ____________________________ This lawsuit alleges that the plaintiff was (A) subjected to unreasonable physical force, (B) denied medical treatment, (C) subjected to inadequate protective supervision while in custody resulting in his attempt to commit suicide, and (D) on a number of occasions subjected to the false and unauthorized spreading of rumors that he was HIV positive and/or suffered from AIDS. The complaint also alleges a failure of the Town of Branford to adequately train and supervise its police officers. ORAL ARGUMENT IS REQUESTED TESTIMONY IS NOT REQUIRED The Supplemental

Case 3:02-cv-00230-EBB

Document 190

Filed 08/01/2006

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2. Default Judgments have entered against three of the four defendants, i.e., the Town of Branford, David Atkinson and Patrick O'Malley. 3. Prior to this week I have had to devote substantial effort to responding to a Motion to Disqualify me from a case involving the City of New Haven based on my nearly twenty years employment with the City. Alberta Norris v. City of New Haven, 3:04-cv-00543 (MRK). The breadth and detail of the necessary response is substantial, and its importance to me is likely obviously. 3. I have obtained what I believe are all Mr. Salatto's files concerning this lawsuit, copies of more than 125 apparent pleadings (many handwritten), plus correspondence, evidentiary materials and research. I am comparing them against the Court docket entries to be sure all were filed, and I am providing a list of pleadings to defense counsel in order to be certain he and I are working from the same pleadings base. I also believe it prudent to meet with Mr. Salatto to

review the pleadings, all of which to date are his work product, and to discuss the substance of his contentions. 4. This past weekend I received word that one of my two closest friends from childhood entered a Hospice in Baltimore, Maryland. I intend to travel there ___________________________ The Court will recall that Mr. Salatto had been an absconder from a State prison half-way house when I appeared, and he had left behind at the half-way house substantial files. Subsequently, his father obtained release of those files and brought to me what I initially thought were all the documents. When I realized they were not complete I spoke with my client, by then rearrested, and he and I called his father who found more files at his home and eventually brought them to me. They include Court orders and rulings, typed pleadings of the defendants, and many hand-written pleadings, notes and correspondence of Mr. Salatto. -2-

Case 3:02-cv-00230-EBB

Document 190

Filed 08/01/2006

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Wednesday afternoon, August 2, 2006 and probably return very late Thursday or early Friday. Within days I may also have to make a second trip for his funeral, which is expected to be "sooner rather than later." 6. Today, Tuesday, August 1, I have an agency hearing in the morning,

and two depositions in the afternoon. Every Wednesday this month, including August 2, I attend a Connecticut Attorneys Title Insurance Company (CATIC) seminar in Rocky Hill. 10. Also, on August I0 and 11 I have two re-noticed depositions in Simsbury. Respectfully submitted, ____________________________/S/ MARTIN S. ECHTER Federal Bar No. ct07596 Law Office of Patricia A. Cofrancesco 89 Kimberly Avenue East Haven, CT 06512 Phone: (203) 467-6003 Fax: (203) 467-6004 Certificate of Service I, Martin S. Echter, hereby certify that I have served the foregoing by causing a copy to be FAXED and MAILED, POSTAGE PREPAID, to: Attorney John J. Radshaw, III Howd & Ludorf, LLC 65 Wethersfield Avenue Hartford, Ct 06114 this _____ day of August, 2006. _______________________________ Martin S. Echter -3-

Case 3:02-cv-00230-EBB

Document 190

Filed 08/01/2006

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