Free Objection - District Court of Connecticut - Connecticut

Case 2:91-cv-00180-RNC

Document 558

Filed 05/13/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT P.J., et al., Plaintiffs, v. STATE OF CONNECTICUT, et al. Defendants. : : : : : : CIVIL NO. 291CV00180 (RNC)

MAY 13, 2008

OBJECTION TO MOTION FOR EXTENSION OF TIME The Plaintiffs object to the Defendants' Motion for Extension of Time [Doc. # 556] to the extent it requests a two-month delay in the hearing set for June 26, 2008. The Plaintiffs do not object to the Defendants' request to postpone their brief in opposition to the Motion for Orders to Remedy Substantial Non-Compliance with Settlement Agreement until June 26, 2008, as long as they have an opportunity to review that document prior to the hearing on June 26th. In support of this Objection, the Plaintiffs represent that the Motion to Remedy Substantial Non-Compliance asserts that Defendants have failed to comply with the Settlement Agreement. Further, Plaintiffs assert that the Defendants have denied Plaintiffs the discovery needed to fully assess and inform the Court as to the extent OF the Defendants non-compliance. Accordingly, the Plaintiffs request an initial order requiring the Defendants to cooperate fully in Plaintiffs' discovery and a scheduling order that sets a schedule for the completion of discovery and trial. Motion For Orders To Remedy Substantial Non-Compliance With Settlement Agreement [Doc. # 552], ¶¶16 a. and b. The Defendants' representation in their Motion that new data analysts are about to be

Case 2:91-cv-00180-RNC

Document 558

Filed 05/13/2008

Page 2 of 3

hired by Defendants, that promotions within the Connecticut Department of Education have occurred and that Defendants' counsel has a busy schedule, should not prevent the Court from holding a hearing on June 26, 2008 to assess whether Court's intervention is necessary to facilitate the completion of discovery and establish a scheduling order that schedules the completion of discovery and trial. WHEREFORE, the Plaintiffs Object to the Defendants' Motion to the extent a delay in the June 26, 2008 hearing is requested. PLAINTIFFS, By /s/ David C. Shaw David C. Shaw, Esq. The Law Offices of David C. Shaw, LLC Fed. Bar No. ct05239 34 Jerome Ave., Suite 210 Bloomfield, CT 06002 Tel. (860) 242-1238 Fax. (860) 242-1507 Email: [email protected]

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Case 2:91-cv-00180-RNC

Document 558

Filed 05/13/2008

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on May 13, 2008 a copy of the foregoing Objection was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. .

Darren P. Cunningham Assistant Attorney General State of Connecticut P.O. Box 120 Hartford, CT 06141

/s/ David C. Shaw

David C. Shaw, Esq.

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