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

Case 2:91 -cv-001 80-RNC Document 556 Filed 05/08/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
PJ., et al., : CIVIL NO.
Plaintmir, : 2 :9 I CV00l 80(RNC)
STATE OF CONNECTICUT, etal.
Defendants : May 8, 2008
MOTION FOR EXTENSION OF TIME
The defendants in the above action respectfully move the Court, (1) for an extension
of time, up to and including August 21, 2008 to respond to Plaintiffs’ "l\/lotion for Orders to
Remedy Substantial Non-Compliance with Settlement Agreernent" (hereafter ‘°Motion")
dated April 15, 2008, and (2) a delay until after August 25, 2008 for the Oral Argument
currently set by the court for June 26, 2008.
In support of this motion, the defendants respectfully submit:
l. The issues raised in the Motion are numerous and comprehensive and will require
considerable time, research and analysis on the part ofthe State Department of Education
("CSDE") personnel to appropriately set forth a response to the issues regarding compliance
with the governing Settlement Agreement.
i 2. A new CSDE dataperson has been hired who will oversee the collection and
analysis of data related to the Settlement Agreement. This new person started on April 25 and _
will require a significant amount of time for training on the present data needs particular to
the Settlement Agreement along with a general understanding of the underlying lawsuit.

Case 2:91 -cv-001 80-RNC Document 556 Filed 05/08/2008 Page 2 of 4
3. The former data person assigned to the Settlement Agreement will be leaving on
maternity leave in June; thereby making it critical that ample time be given from now through
June to appropriately meet the training needs of her successor.
4. The CSDE’s designee for the Q Settlement Agreement has recently assumed a
promotion and while continuing to be actively involved with the issues related to the
Settlement Agreement, some ofthe responsibilities currently assigned to her will be
reassigned to another education consultant. This transition requires training and will
encompass a significant amount of time over the next few months.
5. ln the next few weeks the undersigned is scheduled to argue two motions to dismiss
in state court, argue a contested involuntary conservatorship petition in state probate court,
represent the Department of Social Services in two Medicaid eligibility hearings, represent
several state boards and commissions at their regular meetings, and likely argue an
administrative appeal in state court.
6. Plaintiffs’ attorney David Shaw has indicated that he glgjg to this motion insofar
as it seeks an extension of the argument date currently set and an extension of the responsive
filing beyond June 26, 2008. Attorney Shaw consents only to an extension of the time
required to file defendants’ response until June 26, 2008.
7. This is the @ extension of time sought for the subject time limitation.
Defendants response is currently due May 6, 2008,
8. More time is required in order to aid the court in its determination ofthe pending
issues.
WHEREFORE, the defendants respectfully request that this motion be granted.

Case 2:91 -cv-001 80-RNC Document 556 Filed 05/08/2008 Page 3 of 4
DEFENDANTS "
STATE OF CONNECTICUT ET AL
RICHARD BLUMENTHAL
ATTORNEY GENERAL
/s/ \ nxvuzxx
Darren P. Cunningham
Assistant Attorney General
Federal Bar No. ct253 80
P. O. Box 120
Hartford, CT 06141-0120
Tel.: (860) 808-5210
Fax: (860) 808-5385
ORDER
The foregoing motion having been duly presented to the Court, it is hereby T
ORDERED: GRANTED/DENIED.
United States District Court

Case 2:91 -cv-001 80-RNC Document 556 Filed 05/08/2008 Page 4 of 4
CERTIFICATION
I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b)
ofthe Federal Rules of Civil Procedure on this 8th day of May, 2008 tirst class postage
prepaid to:
The Honorable Donna Martinez
United States Magistrate Judge
450 Main Street
Hartford, CT 06103
David C. Shaw, Esq
34 Jerome Avenue
Suite 210
Bloomfield, CT 06002 j
Frank Laski, Esq
Mental Health Legal Advisors Committee
294 Washington St.
Suite 320 Y
Boston, MA 02108
Darren P. Cunningham { S
Assistant Attomey General