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

Case 3:02-cv-02147-JBA

Document 51

Filed 11/15/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

MIGUEL A. DIAZ V. BRIAN FOLEY

: : : : :

CIVIL ACTION NO. 3:02CV2147 (JBA)

NOVEMBER 12, 2004

MOTION FOR ENLARGEMENT OF TIME The undersigned, on behalf of the defendant, Brian Foley, respectfully requests this Court for an enlargement of time of forty-five days from November 30, 2004 to and including January 14, 2005, in which to file dispositive motions. Counsel for the undersigned defendant is currently involved in preparing for a jury trial in a case entitled Doe v. City of Hartford, et al. bearing Case No. 3:97CV205 pending in Hartford District Court before Hon. Robert N. Chatigny, U.S.D.J. This trial is scheduled to commence on November 29, 2004. Also, the deposition of the plaintiff was completed on October 13, 2004 and the undersigned counsel for the defendant has recently received the relevant transcripts. In addition, during the deposition, the pro se plaintiff identified several witnesses to the subject incident. With the assistance of the plaintiff, defendant has been attempting to locate these witnesses to arrange their depositions. This is this defendant's first such request for an enlargement of time.

Case 3:02-cv-02147-JBA

Document 51

Filed 11/15/2004

Page 2 of 3

The pro se plaintiff is presently an inmate at a Connecticut correctional facility, and we are unable to obtain his position with regard to this Motion as he is not readily accessible by telephone.

THE DEFENDANT : BRIAN FOLEY

By Eric P. Daigle of HALLORAN & SAGE LLP Fed. Bar #ct23486 One Goodwin Square 225 Asylum Street Hartford, CT 06103 (860) 522-6103 [email protected] His Attorneys

-2-

Case 3:02-cv-02147-JBA

Document 51

Filed 11/15/2004

Page 3 of 3

CERTIFICATION This is to certify that on this 12th day of November, 2004, a copy of the foregoing Motion for Enlargement of Time was mailed, postage prepaid, to: Miguel A. Diaz, #250008 MacDougall Correctional Institute 1153 East Street South Suffield, CT 06080

Eric P. Daigle
616039.1

-3-