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

Case 3:02-cv-01036-AVC

Document 37

Filed 06/13/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT TERESA T., Plaintiff, v. UNITED STATES OF AMERICA, Defendant. : : : : : : : : :

Civil No. 3:02CV1036 AVC

June 13, 2007

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 June 13, 2007 until August 13, 2007 in which to file its supplemental briefing. As grounds for this Motion, counsel states that additional time is needed to address the issues remanded to this Court from the Court of Appeals for the Second Circuit. 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. Moreover, additional time is needed in order to obtain sealed information from the juvenile court and/ or to conduct depositions of fact witnesses who can provide information and a time line of representation which is necessary to address the issues presented on remand. As such, it is necessary to conduct limited discovery on the factual issues involving legal representation of the plaintiffs, in order to thoroughly address those issues in the defendant's supplemental briefing. In accordance with the Court's order

Case 3:02-cv-01036-AVC

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Filed 06/13/2007

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dated May 29, 2007, the parties will be also filing a joint motion to reopen discovery to address these factual issues. This is the second request for an extension of this deadline. Counsel for the plaintiff 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]

CERTIFICATION OF SERVICE I hereby certify that on June 13, 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

Case 3:02-cv-01036-AVC

Document 37

Filed 06/13/2007

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