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

Case 3:02-cv-01036-AVC

Document 42

Filed 01/24/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

TERESA T., and ZAZSHEEN P. (A Minor Child),: MATTHEW T. GILBRIDE, ESQ., PPA : for ZAZSHEEN P., : : PLAINTIFFS, : v. : : UNITED STATES OF AMERICA : : DEFENDANT. :

Civil No. 3:02CV1036 (AVC)

January 24, 2008

DEFENDANT'S MOTION FOR EXTENSION OF TIME TO FILE SUPPLEMENTAL BRIEFING Pursuant to Local Rule 7(b) of the Local Rules of Procedure for the District of Connecticut, the Defendant, hereby respectfully requests a sixty (60) day extension of time from January 22, 2008 until March 21, 2008 in which to file its supplemental briefing. As grounds for this Motion, counsel states as follows: the parties have been involved in some limited discovery which is designed to address the issues remanded to this Court from the Court of Appeals for the Second Circuit, the defendant has only recently received the plaintiffs' discovery responses and needs additional time to finalize all discovery including the depositions of certain fact witnesses. Because the Second Circuit seeks additional fact finding regarding the role of the plaintiff's attorney, guardian ad litem and next of friend and their respective duties and responsibilities, if any, to file a timely federal tort claim on the plaintiffs' behalf, the defendants are also seeking to obtain sealed information from the juvenile court.

Case 3:02-cv-01036-AVC

Document 42

Filed 01/24/2008

Page 2 of 3

However, counsel for the plaintiffs has advised counsel for the defendant that the juvenile court has been unsealed to him for limited purposes. Counsel for the defendant needs additional time to seek permission from the juvenile court to have the entire record unsealed, in order to determine the time line of representation which is necessary to address the issues presented on remand. This is the third request for an extension of this deadline. Counsel for the plaintiffs concurs in the granting of this extension of time.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY /s/ Brenda M. Green BRENDA M. GREEN ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT19538 UNITED STATES ATTORNEY'S OFFICE 915 LAFAYETTE BOULEVARD, ROOM 309 BRIDGEPORT, CT 06604 (203) 696-3000 (telephone) (203) 579-5575 (facsimile) [email protected]

Case 3:02-cv-01036-AVC

Document 42

Filed 01/24/2008

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on January 23, 2007, a copy of foregoing was electronically filed with the Court and notice of this filing will be sent by e-mail to all parties of record or by mail to any party unable to accept electronic filing as indicated on the Notice of Electronic filing. /s/ BRENDA M. GREEN ASSISTANT UNITED STATES ATTORNEY