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

Case 3:03-cv-00944-RNC

Document 39

Filed 10/07/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : : : : : PRISONER 3:03CV00944(RNC)

JAMES MCKINNON Plaintiff VS. YVONNE, ET AL. Defendants

OCTOBER 5, 2004

MOTION FOR EXTENSION OF TIME The defendants in the above-entitled matter hereby, by and through the undersigned counsel and pursuant to Local Rule 9(d) and Federal Rule of Civil Procedure 12, respectfully move for a 60 day extension of time within which to file an answer or otherwise respond to plaintiff's Complaint, up to and including December 6, 2004. defendants represent the following: 1. The schedule of undersigned counsel has been extremely hectic as she is new to this In support of this motion, the

office, as she is defending the State in numerous other matters demanding her attention, as she is scheduled to conduct two habeas trials in Connecticut Superior Court, G.A. 19 in early October, 2004, and as she was out of the country from September 17, 2004 through October 2, 2004; 2. 3. This complaint contains complex factual and legal allegations; Additional time is necessary in order for the defendants to review the complaint and

pertinent documents in order to prepare an appropriate responsive pleading;

Case 3:03-cv-00944-RNC

Document 39

Filed 10/07/2004

Page 2 of 3

4. and, 5.

This is the first motion for an extension of time in this matter as to a responsive pleading;

The undersigned counsel has not contacted counsel for the plaintiff to determine the

plaintiff's position with regard to this motion, since the plaintiff is pro se and is an inmate currently confined to Corrigan-Radgowski Correctional Institution.

DEFENDANTS, Yvonne, et al. RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:___/s/___________________________ Kathleen A. Keating Assistant Attorney General Federal Bar No. ct25247 110 Sherman Street Hartford, CT 06105 Telephone: (860) 808-5450 E-mail: [email protected]

2

Case 3:03-cv-00944-RNC

Document 39

Filed 10/07/2004

Page 3 of 3

CERTIFICATION I hereby certify that a copy of the foregoing was sent by first-class mail, postage prepaid, this 5th day of October 2004, to: James McKinnon Inmate No. 100770 Corrigan-Radgowski Correctional Institution 986 Norwich-New London Tpke. Uncasville, CT 06382 __/s/________________________________ Kathleen A. Keating Assistant Attorney General

3