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

Case 3:00-cv-00230-SRU Document 108 Filed 03/14/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CLAUDIOUS CHANNER; :
Plaintiff : CIVIL ACTION NO,
: 3100 CV230 (SRU)(\/VIG)
VS., 2
RFCHARD BLUMENTI-IAL;
JANET RENO; 2
CITY OF HARTFORD; :
JAMES MARKOWSKIQ 2
DETECTIVE PERODEALM Z
DETECTIVE MERRITTQ :
DETECTIVE WOLF; :
DETECTIVE ELLIS; SERGEANT :
CAGEANELLO, ET AL 2
Defendants : MARCH 10, 2005
MOTION FOR ENLARGEIVIENT OF TIME
The undersigned, on behalf of the defendant, City of Hartfotd, respectfuily
requests this Court tor an enlargement of time of seven days from Match 10, 2005, to
and including March 17, 2005, in which to repiy to the piaintitfs Memorandum in
Opposition to Motion to Dismiss and the accompanying exhibits.
In support of this Motion, the defendants submit the foliowingt
Defendant, City of |—tartforci's, counsel filed its Motion to Dismiss on November
13, 2003, After numerous extensions of time, the plaintiff finalty filed his Memorandum
in Opposition on January 27, 2005, Due to scheduling commitments in other matters,
and the attempting to file Summary Judgment briefs in two other matters, the
iimtrmii. or 0610;; SAGE LIL]? )£;i,”;}G0(°

Case 3:00-cv-00230-SRU Document 108 Filed O3/14/2005 Page 2 of 3
undersigned counsel requires the additional week En order to properly respond tothe
plaintiffs l\/lemorandum of Lew in Opposition and the many attached supporting
documentation
This is this defendants second such request for an enlargement of timer
The pro se plaintiff is presently an inmate at a Connecticut correctional tacitity,
and we are unable to obtain his position with regard to this l\/lotion as he is not readiiy
acoessibte by telephone.
DEFENDANT
CITY OF HARTFORD
BY:
Eric P. Daigle
Fed. Bar No. ct23486
HALLORAN 8t SAGE LLP
One Goodwin Square
Hartford, CT 06103
Tele: (860) 522-5103
daigIe@heIloran—sage.oom
- 2 -
gm :r{B6[)_)1·§;2?,:§p]·
a-i¤m1m1,c?rr16l
Case 3:00-cv—00230—SRU Document 108 Filed 03/14/2005 Page 3 of 3
CERTIFICATION
This is to certify that on this 10m day of March, 2005, the foregoing was either
maiied, postpaid, or hand—deIivered to:
Ciaudious VV. Chenner
Inmate #15148
PO, Box 100
Somers, CT 06071
David J, Sheidon, Esquire
Assistant United States Attorney
RO. Box 1824
New Haven, CT 05508--1824
Eric P. Daigle
I5521i‘5*_$ DOC
6521T5·1(HSFF‘)
- 3 ...
.i,,,t,,mm & SAGE i,i.,1¤ I§i§?,“’2i1%‘§°°“