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

Case 2:91-cv-00180-RNC

Document 539

Filed 09/25/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT P.J., et al., Plaintiffs, v. STATE OF CONNECTICUT, et al. Defendants : : : : : : : CIVIL NO. 291CV00180(RNC)

SEPTEMBER 25, 2007

MOTION ON CONSENT FOR EXTENSION OF TIME The defendants in the above action respectfully move the Court for an extension of time, up to and including September 28, 2007, to respond to Plaintiffs' "Motion to Compel" dated August 21, 2007. In support of this motion, the defendants respectfully submit: 1. Undersigned counsel has been working diligently to respond to Plaintiffs' Motion to Compel. Undersigned counsel has been in near constant communication with personnel from the State Department of Education that are most intimately familiar with the relevant issues. 2. Plaintiff's attorney David Shaw has indicated that he has no objection to this motion being granted. 3. This is the second extension of time sought for the subject time limitation. 4. Defendants continue to produce materials that may refine and limit the scope of the parties' differences. See D. Conn. L. Civ. R. 37. For example, on September 21, 2007 ­ after both defendants last motion for extension of time and plaintiffs' Motion to Compel-defendants produced data and answers requested in the Plaintiff's Motion for Disclosure and Production dated June 22, 2007. 5. More time is required in order to aid the court in its determination of the pending discovery issues.

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Case 2:91-cv-00180-RNC

Document 539

Filed 09/25/2007

Page 2 of 3

WHEREFORE, the defendants respectfully request that this motion be granted.

DEFENDANTS STATE OF CONNECTICUT ET AL RICHARD BLUMENTHAL ATTORNEY GENERAL /s/_____________________________ Darren P. Cunningham Assistant Attorney General Federal Bar No. ct25380 P. O. Box 120 Hartford, CT 06141-0120 Tel.: (860) 808-5210 Fax: (860) 808-5385

ORDER The foregoing motion having been duly presented to the Court, it is hereby ORDERED: GRANTED/DENIED.

___________________________ United States District Court

CERTIFICATION

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Case 2:91-cv-00180-RNC

Document 539

Filed 09/25/2007

Page 3 of 3

I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 25th day of September, 2007, first class postage prepaid to:

The Honorable Donna Martinez United States Magistrate Judge 450 Main Street Hartford, CT 06103 David C. Shaw, Esq 34 Jerome Avenue Suite 210 Bloomfield, CT 06002 Frank Laski, Esq Mental Health Legal Advisors Committee 294 Washington St. Suite 320 Boston, MA 02108

/s/_________________________ Darren P. Cunningham Assistant Attorney General

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