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

Case 3:03-cv-00208-WWE

Document 69

Filed 03/14/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

ROBERT REID Plaintiff, V. JOHN ARMSTRONG, ET AL. Defendants.

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CIVIL ACTION NO. 3 : 03:CV208 (HBF)

March 14, 2008

MOTION FOR EXTENSION OF TIME The plaintiff, through counsel in the above captioned matter respectfully moves this Court to grant a 60-day extension of time (to May 18, 2008) to allow the plaintiff to file his Opposition to the defendant's Motion for Summary Judgment. The plaintiff himself is incarcerated and the undersigned court-appointed counsel was unable to locate the plaintiff until Tuesday, March 11, 2008 at the plaintiff's new correctional institution in New Hampshire. The plaintiff needs to review the Motion for Summary Judgment and Objection and be afforded an opportunity to offer his input. It is anticipated that the undersigned may have to travel to New Hampshire to consult with the plaintiff. The undersigned consulted with Assistant Attorney General Terry O'Neill,

Case 3:03-cv-00208-WWE

Document 69

Filed 03/14/2008

Page 2 of 2

Esq., who consents to the granting of this motion.

THE PLAINTIFF, By /s/ Jim Nugent Fed. Bar No. CT05792 Nugent & Bryant 236 Boston Post Road Orange, CT 06477 (203)795-1111 Email:[email protected]

CERTIFICATION I hereby certify that a copy of the foregoing has been mailed postage pre-paid first class to: Terry O'Neill, Esq. Assistant Attorney General 110 Sherman Street Hartford, CT 06105 March 14, 2008 Date /s/ Jim Nugent