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

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,;'\ ase 3:02-cv-018E)8;JCH Document 43 Filed 12/15[2004 Page 1 of 3 I
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Plaintf : Civil No. 3:02CVl808 (JCH) I
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VS. : I
JOHN ARMSTRONG, et. al., December 2004
Defendants l
Morrow ron ssconn ENLARGEMENT or uma
The Plaintiff, Richard Roque,pr0 se, respectfully moves for a second enlargement of time
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of one hundred twenty (120) days, until April 15, 2004, to respond to the Defendants’ Motion to
Dismiss in this action. I
The Defendants, through their counsel, Atty. Neil Parille consented to this request for
enlargement of time, in a telephone conversation with Atty. Kenneth J. Speyer on December 2, I
2004. I
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The Plainti ff was notified on December 1 , 2004, that he has been granted parole, effective I
December 3 , 2 004. A s a c onsequence o f this change in status, Inmates’ Legal Assistance I

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_ ase 3:02-cv-O18(98—\JCH Document 43 Filed 12/1§/2004 Page 2 of 3 p
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Program is no longer permitted to assist the Plaintiff in responding to the Defendants’ Motion for
Summaiy Judgment. The Plaintiff will need time to obtain appointed counsel or private counsel
in this action, and such counsel will need time to familiarize himself or herself with this action ; i
and to prepare a proper response to the Motion for Summary Judgment. A
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The Plaintiff’ s response to said Motion for Summary Judgment is substantially p
incomplete, for reasons beyond the Plaintiffs control. Defense counsel agreed in September to i
provide Inmates’ Legal Assistance Program with copies of the Defendants’ response to the
Plaintiff’ s Request for Production. These doctunents, which weigh nearly four (4) pounds, were j
not received by Ininates’ Legal Assistance until December 2, after the Plaintiff had been notified
of his parole. The parties had also begun settlement discussions in this case. Attorney Speyer, i
{ who has been assisting the Plaintiffwithin Imnates’ Legal Assistance, is employed only part time
i by Ininates’ Legal Assistance, with a substantial caseload of other inmates in need of assistance,
i and consequently has been limited in the amount of time he could devote to this matter. I
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l In the event that this Motion fails to reach the Court before the expiration ofthe previous 3
i extension of time, the Plaintiff respectfully requests that this Request for Extension of Time be
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< " ase 3:02-cv-O18§3>.,1CH Document 43 Filed 12/1{5/$004 Page 3 of 3 l
granted mmcpro tunc. The Plaintiffdid not obtain a mailing address, to which this motion could |
be mailed for his signature, until December 7, 2004.
Respe ly ub ¤ · .· / i l
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Richard Roque, Plaintif pm se 2
c/0 Thomas Merton Ce { er A
43 Madison Avenue i
Bridgeport, CT 06604-3334
The undersigned, although not authorized to appear herein, has assisted in preparing this
Motion. [ ’ / A
emreth J. f
Staff Atto in i
Inmates’ Legal Assistance Program {
78 Oak Street N
_ P. O. Box 260237 1 p
Hartford, CT 06106-0237
(800) 301-4527 or (860) 246-1118 l
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I hereby certify that a true copy ofthe foregoing was mailed on Dec. , 2004, to: 1 l
Atty. Neil Parille
Assistant Attorney General
110 Sherman Street
Hartford, CT 06105 _, 2 l
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Richard Roque A
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