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

· Case 3:03-cv-O105};§3FD Document 15 Filed 12/Of1[2003 Page 1 of 3
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1 UNITED STATES DISTRICT COURT gl`? R 11 1
DISTRICT OF CONNECTICUT L éY‘`* LI"
BENJAMIN NASH, PRO SE : PRISO%§§{F _ lj I2; yg J
Plaintiff, JJ I —
V. : Civil Action ti; 03cv_10151"1.
(CFD) (WIC) fifi 1
ROBERT BERGER, et al., :
Defendants, November 24, 2003

MOTION FOR EXTENSION OF TIME TO RESPOND TO
DEFENDANTS MOTION TO DISMISS `
Pursuant to Local Rule Sec, 7(b), of Civil Procedure pro se, plaintiff
Benjamin Nash, respectfully requests this Honorable Court to grant him an
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extension to respond to defendants Motion T0.Dismiss this action. On I
. November 18, 2003, defendant Robert Berger, John Ryan, Janet Williams, I
Silvia Cancela and Susan Blair, served on the plaintiff a motion to dismiss 1
pursuant to Rule l2(b)(1), and l2(b)(6) of the Federal Rules of Civil
Procedure. The plaintiff needs additional time in order to produce _
information and to conduct research to file a Memorandum in Opposition or
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to file other responsive pleading in support of his complaint. Defendant’s
motion to dismiss the complaint is now pending court decision. The plaintiff
has no access to a law library, he is confined to a maximum-security
psychiatric facility by order of the defendants, plaintiff is an individual with I
U psychiatric disabilities and he has neither legal education nor prior
experience with litigation. Plaintiff Benjamin Nash hereby respectfully
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. Case 3:03-ev-O105@FD Document 15 Filed 12/O€%%OO3 Page 2 of 3 I
requests an extension of time of 30 days from the court’s ruling on this I
motion for enlargement of time. This is the plaintiff’s first motion to request
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for extension of time, plaintiff has not contacted the defendants’ counsel
regarding this motion requesting extension of time. In the present case
‘ pending before the Court exceptional circumstances exist that justifies and
supports the plaintiffs complaint. I
November 24, 2003
Respectfully submitted, I
@@4 gg, I
enjamin Nash, Pro se,
Whiting Forensic Institute
P.O. Box 70 O’Brien Drive
Middletown, CT 06457 -0070
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F Case 3:O3—cv-O1O5QTC}FD Document 15 Filed 12/O(172})O3 Page 3 of 3 l
CERTIFICATION l
I hereby certify that a copy of the forgoing Motion for Extension of
Time, was mailed in accordance with Rule 5 (b) of the Federal Rules of q
Civil Procedure on this 24th, day of November 2003 to:
Richard J. Lynch
Assistant Attorney General
Emily V. Melendez
Assistant Attorney General
55 Elm Street, P. O. Box 120
Hanford, CT 06141 - 0120 N
E
Benlamin Nash; Pro se,
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