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

I Case 3:03-cv-OO57I§PCD Document 9 Filed O1/27/20(I4 Paget of 3
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I DISTRICT OF CONNECTICUT '° tm to "’
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I EVERN GRANT, : CASE NO. 3: 3CV573(F’CD)(JGM) I
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I OMMISSIONER ARMSTRONG, : JANUARY 27, 2004 I
I Respondent :
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I MOTION FOR ENLARGEMENT OF TIME -
WITHIN WHICH TO COMPLY WITH I
THE COURT'S SCHEDULING ORDER I
_ Pursuant to Rule 9(b) of the Local Rules Of Civil Procedu e For The District Of I
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I I onnecticut, the respondent hereby moves for a four-day enlargem nt of time to January
I I , 2004, to file a response to the Courts amended order to shoI cause. This is the
I I spondent's second motion for an enlargement of time. At this Iime, the petitioner is .
pearing gm g in this matter and, therefore, counsel for the reIpondent is unable to
I .-certain whether he objects to the granting of this motion. I
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The grounds for this motion are: I
'I. In an amended order to show cause [Doc. # 5], tnIe Court ordered the I
titioner to serve a copy of his petition, together with a copy of the how cause order, on
I _e respondent on or before November 25, 2003. Those document were not received by I
I e Ofhce of the Chief State’s Attorney until December 19, 2003. The respondent moved I
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r an enlargement of time to January 23, 2004, which was granteI1. I
2. During the month of January 2003, I have been prepIring the respondent’s I
sponse to a show cause order in the matter of Michael Mourni I v. Warden Z renda, I
ase No. 3:02CV2318(CFD)(\/VIG), U.S. District Court, District 0 Connecticut. Also, I
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Case 3:03-cv-0057 PCD Document 9 Filed 01/27/2004 Page 2 of 3
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presented the respondent in the state habeas trial in Daniel Ha s v. Commissioner of
X orrection, Docket No. CV00-0441977, Superior Court in thejudici ldistrict of New Haven
n January 14, 2004. I am preparing for a state habeas trial Irl the matter of Martin
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` ickinson v. Garrell Muilane etal, Docket No. CV01-0096308, lSuperior Court in the
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dicial district of Middlesex which is scheduled to commence n January 28, 2004. \
Iinaily, I prepared and filed two motions on the respondent’s beh lf in the state habeas
rpus matter of Lennard Toccaline v. Commissioner of Correctigln, Docket No. CV02- I
14816-S, Superior Court in the judicial district of Hartford oli January 12, 2004. I
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l } epresented the respondent at a hearing on those motions that wais held on January 20, ‘
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l l 3. Due to these and other considerations, the respondent hereby moves this
I urt for a enlargement of time to January 27, 2004, to file its response in the above-
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I ptioned matter.
Respectfully submitted, l
RESPONDENT-COMMISBIONER |
ARMSTRONG I E
By:
JO AN SULIK , l
Assistant State’s Attornew I
Civil Litigation Bureau
Office of the Chief State’s I/-\ttorney E
‘ 300 Corporate Place I
Rocky Hill, Connecticut 0dO67
(860) 258-5887
(860) 258-5968 (facsimile)
Fed. Bar. No. ct 15122 I
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I Case 3:03-cv-OO573~I°CD Document 9 Filed O1/27{2004 Page 3 Of 3
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I cERTn=icAnoN
I hereby certify that a copy of this motion was mailed to eVern Grant, Inmate
0. 246675, Greensville Correctional Center, 901 Corrections Way, Jarrat, Virginia 23870, I
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I n January 27, 2004.
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I Jo ANN uuI< I
I Assistant State’s Attorne;I I
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