Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:00-cv-00720-JCH

Document 82

Filed 05/09/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WILLIAM CONNELLY Plaintiff v. DAVID COSGROVE, ET AL Defendants : : : : : : CIVIL NO. 3:00CV720(JCH)(HBF)

MAY 8, 2006

THE DEFENDANT'S MOTION FOR A THREE DAY EXTENSION OF TIME TO FILE FOR SUMMARY JUDGMENT The defendants respectfully move for a three day extension of time from today's deadline to May 11, 2006, to file their motion for summary judgment. The counsel for the defendants has been steadfastly working on the motion for summary judgment, but it has taken longer than expected to reach some of the defendants and obtain supporting affidavits as well as the responses to the plaintiff's requests for discovery. The undersigned counsel for the defendants has been working diligently to complete the motion by today's deadline date, but despite a good faith effort, has not been successful. But, in a further effort to minimize delay, only a three additional days are requested. This is the second request for an extension of time by the defendants. If this request is not granted the defendants will be severely prejudiced as their motion for summary judgment is nearly complete and three additional days will not cause the plaintiff to suffer any undue prejudice. The plaintiff is incarcerated and so his position with respect to this motion is unknown.

Case 3:00-cv-00720-JCH

Document 82

Filed 05/09/2006

Page 2 of 2

WHEREFORE, the defendants respectfully request that this Motion for a three day extension of time from May 8, 2006 to May 11, 2006 to file for summary judgment, be granted.

DEFENDANTS COSGROVE, ET AL RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

__/s/__ ______________________ Robert B. Fiske, III Assistant Attorney General Office of the Attorney General 110 Sherman Street Hartford, CT 06105 Federal Bar #ct17831 Tel.: (860) 808-5450 Fax: (860) 808-5591 E-Mail: [email protected]

CERTIFICATION I hereby certify that a copy of the foregoing was mailed to the following on this, the 8th day of May, 2006, to:

Mr. William Connelly, #189009 Enfield Correctional Institution 289 Shaker Road Enfield, CT 06082 __/s/___________________ Robert B. Fiske, III Assistant Attorney General

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