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

Case 3:00-cv-00720-JCH

Document 127

Filed 07/16/2007

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ) ) WILLIAM CONNELLY, ) Plaintiff, ) ) CIVIL ACTION NO. 3:00-CV-720(JCH) v. ) THERESA C. LANTZ, Commissioner of ) the Connecticut Department of Correction, ) ) July 13, 2007 Defendant. ) MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT Plaintiff William Connelly ("Plaintiff") hereby moves pursuant to Rule 7(b) of the Local Civil Rules of the United States District Court for the District of Connecticut ("L.R.") to extend plaintiff's time to respond to defendant Theresa C. Lantz's ("Defendant") motion for summary judgment until August 3, 2007. In support of this motion, Plaintiff states as follows: 1. Defendant's motion for summary judgment was filed on June 26, 2007. Accordingly, pursuant to L.R. 7(a), Plaintiff's opposition is presently due on Tuesday, July 17, 2007. 2. Plaintiff is incarcerated in the Enfield Correctional Institution in Enfield, Connecticut. As a consequence of his incarceration, communication between Plaintiff and his counsel regarding Plaintiff's opposition to the motion for summary judgment is constrained. In particular, transmission to Plaintiff of drafts of opposition papers and the receipt of comments thereon from Plaintiff are constrained by the need to abide by the rules and regulations of the Department of Corrections regarding communication with inmates.

ORAL ARGUMENT NOT REQUESTED

Case 3:00-cv-00720-JCH

Document 127

Filed 07/16/2007

Page 2 of 3

3. For these reasons, Plaintiff believes that additional time may be required to file his opposition memorandum. 4. Counsel for Defendant has been consulted and has no objection to an extension of the present deadline until Friday, August, 3, 2007. 5. This is Plaintiff's first request for an extension of this deadline. WHEREFORE, Plaintiff respectfully requests an extension of time until August 3, 2007 to oppose Defendant's motion for summary judgment. PLAINTIFF, WILLIAM CONNELLY By: /s/ William C. Mercer Jonathan B. Tropp (ct11295) Catherine Dugan O'Connor (ct22530) William C. Mercer (ct26526) Day Pitney LLP One Canterbury Green Stamford, Connecticut 06901 (203) 977-7300 Fax: (203) 977-7301 [email protected] His Attorneys

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Case 3:00-cv-00720-JCH

Document 127

Filed 07/16/2007

Page 3 of 3

CERTIFICATE OF SERVICE THIS IS TO CERTIFY THAT, on the date hereof, a copy of the foregoing was served via First Class U.S. Mail, postage prepaid, upon the following counsel for Defendant: Steven R. Strom, Esq. Robert B. Fiske, III, Esq. Assistant Attorneys General 110 Sherman Street Hartford, CT 06105 /s/ William C. Mercer William C. Mercer

NYLIB2 218680.2

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