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

Case 3:03-cv-00544-WWE

Document 52

Filed 05/11/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT COREY BROOKS, Plaintiff, v. WARDEN MYERS, ET AL, Defendants : : : : : : CIVIL NO. 3:03CV544 (WWE) (HBF)

MAY 9, 2005

DEFENDANTS' MOTION FOR ENLARGEMENT OF TIME TO MOVE FOR SUMMARY JUDGMENT ON REMAINING CLAIM Pursuant to Rules 6 and 56 of the Federal Rules of Civil Procedure and D. Conn. L. Civ. R. 7(b) and 56, defendants Manley, Butkiewicus and Knapp respectfully move for a thirty day enlargement of time to move for summary judgment on the remaining claim in this matter. In support of this motion, defendants submit the following: 1). The undersigned is responsible for approximately 125 matters pending in the federal courts, state courts and before the Connecticut Claims Commissioner. 2). The undersigned is currently in the process of responding to outstanding overdue discovery requests, and in the middle of preparing a motion for summary judgment in another federal court case. 3). The execution of Michael Ross is currently scheduled for May 13, 2005. 4). In January 2005 when the execution of Mr. Ross was scheduled, the undersigned assisted in the research and writing of briefs for the Second Circuit and the United States Supreme Court regarding appeals of the federal district court's decision staying the execution.

Case 3:03-cv-00544-WWE

Document 52

Filed 05/11/2005

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5). The undersigned anticipates that Dan Ross and/or his former counsel may file legal actions seeking to enjoin the execution the week of May 9th. Thus, the undersigned may again assist in the preparation of legal memoranda. 6). The undersigned needs to meet with defendants Knapp, Butkiewicus, Manley to prepare additional affidavits in this matter. 7) This is the first motion for enlargement of time defendants submitted with respect to filing a motion for summary judgment on the one remaining claim. 8). The plaintiff is pro se and incarcerated and thus his position with regard to this motion could not be ascertained.

DEFENDANTS Larry Myers, et al RICHARD BLUMENTHAL ATTORNEY GENERAL __/s/_________________________ Ann E. Lynch Assistant Attorney General 110 Sherman Street Hartford, CT 06105 Tel.: (860)808-5450 Fax: (860) 808-5591 Federal Bar No. ct08326

By:

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Case 3:03-cv-00544-WWE

Document 52

Filed 05/11/2005

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CERTIFICATION I hereby certify that pursuant to § 5(b) of the Federal Rules of Civil Procedure a copy of the foregoing was mailed, postage prepaid, this _____ day of May 2005 to: Corey Brooks, #237651 Cheshire Correctional Institution 900 Highland Ave. Cheshire Ct 06410 __/s/_________________________ Ann E. Lynch Assistant Attorney General

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