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

Case 2:91-cv-00180-RNC

Document 484

Filed 10/07/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT P.J., et al. Plaintiffs v. STATE OF CONNECTICUT, et al. Defendants : : : : : : CIVIL ACTION NO. 2:91CV00180(RNC)

OCTOBER 5, 2004

DEFENDANTS' MOTION FOR EXTENSION OF TIME

The defendants in the above action respectfully move the Court for an extension of time up and including November 22, 2004 within which to respond to plaintiffs' motion for an award of costs and attorneys' fees. In support of this motion, the defendants respectfully submit: 1. Defendants just received plaintiffs' motion with its accompanying memorandum and lengthy appended materials. 2. Undersigned counsel has a long planned family trip scheduled which will keep him out of state from October 11 through October 19, 2004. In addition, undersigned counsel has three separate court briefs due at the end of October, in addition to numerous hearings and court appearances including an anticipated State Supreme Court argument and an oral argument in the Sheff v. O'Neill litigation in the ensuing weeks. 3. Undersigned counsel will require further time to review plaintiffs' submission, including analysis of the controlling law. 4. Undersigned counsel has attempted to ascertain Attorney Shaw's position with respect to this motion but has been unsuccessful. ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Case 2:91-cv-00180-RNC

Document 484

Filed 10/07/2004

Page 2 of 3

5. This is the first extension of time sought by the defendants for this time limitation. WHEREFORE, the defendants respectfully urge the Court to grant this motion for extension of time as set forth above. DEFENDANTS STATE OF CONNECTICUT ET AL. RICHARD BLUMENTHAL ATTORNEY GENERAL BY: _________________________________ Ralph E.Urban Assistant Attorney General Federal Bar No. 00349 55 Elm Street 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: GRANTED/DENIED. _________________________________ United States District Judge

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Case 2:91-cv-00180-RNC

Document 484

Filed 10/07/2004

Page 3 of 3

CERTIFICATION

I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 5th day of October, 2004, first class postage prepaid to: David C. Shaw, Esq. 34 Jerome Avenue Suite 210 Bloomfield, CT 06002 Frank J. Laski, Esq. Mental Health Legal Advisors Committee 294 Washington Street, Suite 320 Boston, MA 02108

______________________________ Ralph E. Urban Assistant Attorney General

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