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

Case 2:91-cv-00180-RNC

Document 474

Filed 12/11/2003

Page 1 of 3

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

DECEMBER 10, 2003

MOTION FOR ENLARGEMENT OF TIME The plaintiffs move for a one-week enlargement of time to serve their comments to the Expert Advisory Panel Report to the United States District Court on the Expert Advisory Panel and defendants. In support of this motion the plaintiffs represent the following: 1. The Court Order dated November 15, 2003 provides that plaintiffs must submit their comments to the Expert Advisory Panel Report on the Expert Advisory Panel and defendants by no later than December 12, 2003. 2. Plaintiffs are unable to complete and serve their comments by that date due to the fact that plaintiffs' counsel, Attorney David Shaw, has three days of hearings scheduled during the week beginning December 7, 2003 and is required to submit comments to a settlement proposal in ARC/Connecticut v. O'Meara, No.3:01 CV 1871 (JBA) by no later than December 12, 2003. 3. Attorney Ralph Urban, counsel for the defendants has been contacted. He indicates he does not oppose a one-week enlargement of time.

Case 2:91-cv-00180-RNC

Document 474

Filed 12/11/2003

Page 2 of 3

4. A one-week enlargement of the deadline for filing plaintiffs' comments will not adversely impact the other aspects of the Court's Scheduling Order as the Expert Advisory Panel is not scheduled to visit Connecticut to facilitate resolution of the parties comments until January 21, 2003 ­ January 22, 2003. If this Motion is granted the Expert Advisory Panel and defendants will still have a full month to review plaintiffs' comments before the January 21, 2003 meeting with the parties. 5. This is the first enlargement of time requested with respect to this time limitation. WHEREFORE, the plaintiffs request an enlargement of the time within which to serve the plaintiffs' comments to the Expert Advisory Panel Report to the Court from December 12, 2003 to December 19, 2003.

PLAINTIFFS,

By_/s/ David C. Shaw________ David C. Shaw, Esq. 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 474

Filed 12/11/2003

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing was mailed first class, postage prepaid to all counsel of record on December 10, 2003:

Ralph Urban, Esq. Assistant Attorney General State of Connecticut P.O. Box 120 Hartford, CT 06141 Frank J. Laski, Esq. Mental Health Legal Advisors Committee 294 Washington St., Suite 320 Boston, MA 02108

______/s/ David C. Shaw____________ David C. Shaw, Esq.

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