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

Case 3:00-cv-00230-SRU

Document 106

Filed 02/11/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

CLAUDIOUS CHANNER; Plaintiff VS. RICHARD BLUMENTHAL; JANET RENO; CITY OF HARTFORD; JAMES MARKOWSKI; DETECTIVE PERODEAU; DETECTIVE MERRITT; DETECTIVE WOLF; DETECTIVE ELLIS; SERGEANT CAGIANELLO, ET AL Defendants

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CIVIL ACTION NO. 3:00 CV230 (SRU)(WIG)

FEBRUARY 9, 2005

MOTION FOR ENLARGEMENT OF TIME The undersigned, on behalf of the defendant, City of Hartford, respectfully requests this Court for an enlargement of time of thirty days from February 10, 2005, to and including March 10, 2005, in which to reply to the plaintiff's Memorandum in Opposition to Motion to Dismiss and the accompanying exhibits. In support of this Motion, the defendants submit the following: Defendant, City of Hartford's, counsel filed its Motion to Dismiss on November 13, 2003. After numerous extensions of time, the plaintiff finally filed his Memorandum in Opposition on January 27, 2005. Due to scheduling commitments in other matters,

One Goodwin Square 225 Asylum Street Hartford, CT 06103

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:00-cv-00230-SRU

Document 106

Filed 02/11/2005

Page 2 of 3

including out-of-state depositions, the undersigned counsel requires the additional time in order to properly prepare the City of Hartford's response to plaintiff's Memorandum. This is this defendant's first such request for an enlargement of time. The pro se plaintiff is presently an inmate at a Connecticut correctional facility, and we are unable to obtain his position with regard to this Motion as he is not readily accessible by telephone. DEFENDANT CITY OF HARTFORD BY: __________________________ Eric P. Daigle Fed. Bar No. ct23486 HALLORAN & SAGE LLP One Goodwin Square Hartford, CT 06103 Tele: (860) 522-6103 [email protected]

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One Goodwin Square 225 Asylum Street Hartford, CT 06103 Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:00-cv-00230-SRU

Document 106

Filed 02/11/2005

Page 3 of 3

CERTIFICATION This is to certify that on this 9th day of February, 2005, the foregoing was either mailed, postpaid, or hand-delivered to: Claudious W. Channer Inmate #15148 P.O. Box 100 Somers, CT 06071 David J. Sheldon, Esquire Assistant United States Attorney P.O. Box 1824 New Haven, CT 06508-1824

_________________________ Eric P. Daigle
650215_1.DOC

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One Goodwin Square 225 Asylum Street Hartford, CT 06103 Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105