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

Case 2:89-cv-00570-PCD

Document 105

Filed 01/25/2007

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

January 24, 2007

DEFENDANTS' MOTION FOR EXTENSION OF TIME The defendants respectfully request a fourteen day extension of time to February 8, 2007 to file an opposition to the Amended Motion for Order of Compliance, docketed on January 5, 2007, and filed by the individual plaintiff James Kelly. The defendants make this request for the following reasons: Counsel for the defendants is in the process of drafting a Memorandum in Opposition to Amended Motion for Order of Compliance. This process has required, among other things, reviewing the terms of the Agreement of Settlement entered into by the parties in 1990, reviewing documents relating to Mr. Kelly, 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. This process has not yet been completed, but will be within the next two weeks. Mr. Kelly, who filed the Amended Motion for Order of Compliance as an individual plaintiff in the above-referenced action, has been contacted and stated that he does not object to this request for extension of time.

ORAL ARGUMENT NOT REQUESTED

Case 2:89-cv-00570-PCD

Document 105

Filed 01/25/2007

Page 2 of 3

This is the first extension of time requested by the defendants in response to the Amended Motion for Order of Compliance.

DEFENDANTS

BY:

RICHARD BLUMENTHAL ATORNEY GENERAL

____________________________ 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 105

Filed 01/25/2007

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 24th day of January, 2007 first class postage prepaid to:

Mr. James Kelly P.O. Box 351 Silver Street Middletown, CT 06457 Attorney Philip D. Tegeler Connecticut Civil Liberties Foundation 32 Grand Street Hartford, CT 06106 ____________________________ Thomas J. Ring Assistant Attorney General