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

Case 2:89-cv-00570-PCD

Document 114

Filed 06/25/2007

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WILLIAM ROE, ET AL. Plaintiffs: v. MICHAEL HOGAN, ET AL. Defendants : : : : : : CIVIL ACTION NO. H89-570 (PCD)

June 22, 2007

DEFENDANTS' SECOND MOTION FOR EXTENSION OF TIME The defendants respectfully request a fourteen day extension of time to July 9, 2007 to file an opposition to the Motion for Order of Compliance, dated May 21, 2007, and filed by the individual plaintiff Roy Sastrom. The defendants make this request for the following reasons: Counsel for the defendants is in the process of drafting a Memorandum in Opposition to the Motion for Order of Compliance. This process requires, among other things, reviewing the terms of the Agreement of Settlement entered into by the parties in 1990, reviewing documents relating to Mr. Sastrom, meeting various individuals at Connecticut Valley Hospital concerning the particulars of the issues raised in the motion and drafting affidavits to accompany the defendants' memorandum. Due to the unavailability of key individuals at Connecticut Valley Hospital, defendants' counsel has been unable to complete this process. The defendants' Memorandum in Opposition will be completed within the next two weeks. The undersigned counsel for the defendants attempted to contact Mr. Sastrom, who filed the Motion for Order of Compliance as an individual plaintiff in the above-referenced action, once on June 21, 2007 and twice on June 22, 2007, but was unsuccessful in reaching him to determine his position on this motion. ORAL ARGUMENT NOT REQUESTED

Case 2:89-cv-00570-PCD

Document 114

Filed 06/25/2007

Page 2 of 3

This is the second extension of time requested by the defendants in response to Mr. Sastrom's Motion for Order of Compliance.

DEFENDANTS

BY:

RICHARD BLUMENTHAL ATORNEY GENERAL

/s/ Thomas J. Ring________________ Thomas J. Ring Assistant Attorney General Federal Bar No. ct08293 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5210 Fax: (860) 808-5385 E-mail: [email protected]

Case 2:89-cv-00570-PCD

Document 114

Filed 06/25/2007

Page 3 of 3

CERTIFICATION

I hereby certify that a copy of the foregoing Motion for Extension of Time was mailed in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 22nd day of June, 2007 first class postage prepaid to:

Mr. Roy Sastrom P.O. Box 351 Silver Street Middletown, CT 06457 Attorney Philip D. Tegeler Connecticut Civil Liberties Foundation 32 Grand Street Hartford, CT 06106 /s/ Thomas J. Ring__________________ Thomas J. Ring Assistant Attorney General