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

Case 3:02-cv-00230-EBB

Document 142

Filed 03/07/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

ROBERT F. SALATTO, PRO SE, Plaintiff, v. TOWN OF BRANFORD, ET AL., Defendants. MARCH 6, 2006 Civil Action No. 3:02 CV 0230 (EBB) (JGM)

MOTION FOR EXTENSION OF TIME TO RESPOND TO PENDING MOTIONS The defendants, TOWN OF BRANFORD; ROBERT GILL, Chief of Police; PATRICK O'MALLEY, Patrol Officer; DAVID ATKINSON, Patrol Officer; and JOHN DOE, Shift Supervisor, hereby move for an extension of time to respond to the plaintiff's multiple pending motions. In support of this objection, the defendants offer as follows: 1. The defendants have moved to set aside the entry of default and such motion sets forth the reasons for the same and is incorporated by reference; 2. The defendants have filed an answer and affirmative defenses to the second amended complaint; 3. Good and valuable defenses exist to both liability and damages in this case;

Case 3:02-cv-00230-EBB

Document 142

Filed 03/07/2006

Page 2 of 3

4.

Before, during and after said filing, the plaintiff has filed a plethora of motions regarding discovery, evidence, sanctions and summary judgment.

5.

In order to fully respond to the plaintiff's many, many motions, the defendants need additional time.

6.

The defendants are endeavoring to respond to the pending motions in such a form that will assist the court in the disposition of the same to clarify and focus the pleadings in this case.

7.

The defendants require until Friday, March 17, 2006 in which to respond to all of the plaintiff's motions pending as of March 6, 2006 (up to docket entry 140).

8.

No additional time will be necessary.

WHEREFORE, the defendants pray that their motion is granted and they are allowed until Friday, March 17, 2006 in which to respond to all of the plaintiff's motions pending as of March 6, 2006 (up to docket entry 140). THE DEFENDANTS, TOWN OF BRANFORD; ROBERT GILL, Chief of Police; PATRICK O'MALLEY, Patrol Officer; DAVID ATKINSON, Patrol Officer; and JOHN DOE, Shift Supervisor /s/ John J. Radshaw III John J. Radshaw III, ct19882 HOWD & LUDORF 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax)

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Case 3:02-cv-00230-EBB

Document 142

Filed 03/07/2006

Page 3 of 3

CERTIFICATION I hereby certify that on March 6, 2006, a copy of foregoing was served by U.S. Mail, postage pre-paid to all pro se parties and counsel of record. Robert F. Salatto, Jr. Inmate #180287 Corrigan Correctional Institute 986 Norwich New London Turnpike Uncasville, CT 06382

/s/ John J. Radshaw III John J. Radshaw III

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