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

Case 3:02-cv-02243-JCH

Document 14

Filed 07/09/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT OCTAVIA E. PLESNIK, Plaintiff, v. ISBELLA LACY, et al., Defendants, : : : : : JULY 8, 2004 CIVIL NO. 3:02CV2243(JCH)

MOTION FOR EXTENSION OF TIME TO RESPOND TO AMENDED COMPLAINT Defendants Lacy, Elliot, and Lombardozzi, U.S. Postal Service employees sued in their official capacity, respectfully move for thirty (30) days' extension of time up to and including August 9, 2004, to respond to the Amended Complaint. of this motion, the defendants represent as follows: 1. This is a federal action brought by the plaintiff The original Complaint, filed a year and half In support

proceeding pro se.

ago on December 18, 2002, is on the form captioned "Civil Rights Complaint." There are no assertions of fact or law in the

Complaint, but a two-page letter to an EEOC official is attached. 2. Plaintiff is known to this office as a former Postal In 1998, Plaintiff, who was represented by

Service worker.

counsel, litigated a Rehabilitation Act claim against the Postmaster General to a defendant's verdict. Civ. No. 3:97CV00088(PCD). 3. Defendants in this case were not aware of the abovePlesnik v. Runyon,

captioned action until May of this year.

Case 3:02-cv-02243-JCH

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Filed 07/09/2004

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4.

Accordingly, the U.S. Postal Service is searching its

records to obtain some background and decide how to proceed. Those materials have just been located and were received by defense counsel on June 22 and June 25. 5. Additional time is required to review these materials

and determine how to proceed. 6. This is the first request for extension of the deadline

to respond to the Amended Complaint. 4. Given the plaintiff's pro se status and other factors,

I did not confer about this request with the plaintiff. WHEREFORE Defendants respectfully request a 30-day extension up to and including August 9, 2004, to file their response to the Amended Complaint.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

CAROLYN A. IKARI ASSISTANT U.S. ATTORNEY 450 Main Street Hartford, Connecticut 06103 (860) 947-1101 Fed. Bar No. ct13437

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Case 3:02-cv-02243-JCH

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Filed 07/09/2004

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CERTIFICATION OF SERVICE I hereby certify that a copy of the within and foregoing has been mailed, postage prepaid, via first-class mail, this 8th day of July, 2004, to: Octavia E. Plesnik 5 Perth Street, #20 Dorchester, MA 02121

CAROLYN A. IKARI ASSISTANT UNITED STATES ATTORNEY

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