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

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Case 2:89-cv-00570-PCD Document 86 Filed 02
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II-? I It. II)
I UNITED STATES DISTRICT COURT
I DISTRICT OF CONNECTICUT
I ZIIIIE FEB ll FD 2= Ob
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WILLIAM ROE, et al., on behalf of themselves U_S_ I}§§j"Casé;ANd;€lIlI§`bI- 579 (PCD)
I and all others similarly situated, III E DE Ii I C I
I P/arhdrf _
_ vs. I
I 14“‘, February 2005 I
I MICHAEL HOGAN, etal,
I Defendant; I
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I MOTION FOR EXTENSION OF TIME I
I Patrick A. Arbelo who is a class member by virtue of his status and plaintiff in the above
I captioned action respectfully moves The Honorable Court for an extension of time within which to
tile his Osaecnorrr Arro MEMORANDUM or LAW to defendants MEMORANDUM rrr Opposrnorrr to this Monon I
I Fon ORDER Or= Compunncs. Plaintiff is requesting a 30 day extension of time in this matter. I
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SPECIFIC FACTS I
The plaintiff is incarcerated and opposing counsel dose not object to the requested
extension. This is plaintiff' s second request for an extension of time. Mr. Arbelo respectfully
requests that The Honorable Court take notice of the fact that he is an individual with Bilateral
Blindness Secondary to Congenital Glaucoma. Plaintiff with the assistance of a peer commenced
working on the objection and memorandum of law and is in the process of drafting the brief. I
While in the latter stages of briefing, the plaintiffs peer advocate was forced to commence
work on an other matter pertaining a stabbing assault on his Ward, therefore he was forced to stop I
and stopped working on the present matter pending before The Honorable Court. I

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l Case 2:89-cv-00570-PCD Document 86 Filed 02/
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{ Since plaintiff last requested an extension on 10"‘, January 2005 his peer advocate also moved
on plaintiffs behalf the Superior Court Judicial District of Fairrield at Bridgeport for the appointment
l of Counsel for Mr. Arbelo on the commitment to the Psychiatric Security Review Board. I
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J Mr. Arbelo appeared in person and moved on oral argument in his case, the motion and
l preparations for oral argument were prepared by plaintiffs peer advocate. The plaintiffs peer I
{ advocate since been arduously attempting to complete the brief. Plaintiff thus respectfully
l request for an extension to and including March 9, 2005. The requested extension is necessary
l in order to properly prepare and present the plaintiffs Memorandum of Law.
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Pursuant to 28 U.S.C., § 1746, I declare under penalty of perjury that the forgoing motion for
extension of time was placed in the C.V.H. institutional mail box on the 15“‘, day of February 2005.
Reseecrruttv SUBMITTED, l
THE PLAINTIFF
PATRICK Araseto
PATRICK Aneeto
P. 0. Box 351
Mxooteroww, Conmecncur 06457
Cennnotnon 0r THE Srznvtce

I, Patrick Arbelo hereby certify that a true copy of the forgoing Motion For Extension oflime was
duly served by U.S. Mail, in accordance with Rule 5 (b) of the Federal Rules of Civil Procedure,
postage prepaid on this 15 th, day of February 2005 to:
Thomas Ring, Assistant Attorney General l
55 Elm Street , P.O. Box 120
Hartford, Connecticut 06141 - 0120 i
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Mr. Patrick Arbelo
By: Robert Kalman _
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