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

Case 2:91-cv-00180-RNC

Document 536

Filed 09/12/2007

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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 12, 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 25, 2007, to respond to Plaintiff's "Motion to Compel" dated August 21, 2007. In support of this motion, the defendants respectfully submit: 1. Undersigned counsel has numerous hearings and other court commitments that have and will limit counsel's ability to prepare a response to Plaintiff's motion. 2. Plaintiff's attorney David Shaw has indicated that he has no objection to this motion being granted. 3. This is the first 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 August 31, 2007 ­ after the filing of the Motion to Compel ­ defendants produced exit data requested in the Plaintiff's Motion for Disclosure and Production dated May 22, 2007. Additionally, defendants are also planning to respond to Plaintiff's Motion for Disclosure and Production dated June 22, 2007 by October 1, 2007. WHEREFORE, the defendants respectfully request that this motion be granted.

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Case 2:91-cv-00180-RNC

Document 536

Filed 09/12/2007

Page 2 of 3

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

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Case 2:91-cv-00180-RNC

Document 536

Filed 09/12/2007

Page 3 of 3

CERTIFICATION

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 12th 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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