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

i Case 3:03-cv—OO67@lS Document 35 Filed 12/O3/2003 Paget of 2 li
UNITED STATES DISTRICT COURT § [l
DISTRICT OF CONNECTICUT “ ` ‘`°‘’` " T
ROBERT KALMAN, PRO SE. ; _ 3 D 12: I3 a
Plamuff I
V. Z Civil Action Not g03,cvr671* -, [ ` -
(DJS) ('[lPS)V - i
ROBERT BERGER, et al., I
Defendants, November 28, 2003 ,

MOTION FOR EXTENSION OF TIME TO RESPOND TO
DEFENDANTS’ MOTION TO STAY DISCOVERY =
Pursuant to Local Rule Sec, 7(b), of Civil Procedure pro se,
plaintiff Robert Kalman, respectfully requests this Honorable Court to grant
him an extension to respond to Defendants Motion To Stay Discoveg;. i
On November 24, 2003, defendant Robert Berger, John Ryan, Janet l
Williams, Silvia Cancela and Susan Blair served on the plaintiff a motion to N
stay discovery. The plaintiff needs additional time to respond and file other
responsive pleading in opposition.
Defendant’s motion to stay is now pending court decision. The C y
plaintiff has no access to a law library, he is confined to a maximunnsecurity
psychiatric facility by order of the defendants, and defendants are in ‘
possession of the facts, they ordered plaintiff confined. Plaintiff, Robert
Kalman hereby respectfully requests an extension of time of 20 days from
the court’s ruling on this motion. This is the first motion for extension of
I I

I _, Case 3:03-cv—OO67*C1'E§JS Document 35 Filed 12/O@OO3 Page 2 of 2
I time in this matter; plaintiff has not contacted the defendants’ regarding this I
motion. A I
I November 28, 2003
Respectfully submitted,
ROBERT KALMAN, PRO SE
Eats! jg; Q, g Lt I
Robert Kalman
Whiting Forensic Institute
P.O. Box 70 O’Brien Drive
Middletown, CT 06457 -0070
Tel: (860) 346 — 9408
CERTIFICATION
I hereby certiiy that a copy of the forgoing Motion, was mailed in I
accordance with Rule 5 (b) of the Federal Rules of Civil Procedure on this ;
I 28th, day of November 2003 to: I
Richard J. Lynch . I
Assistant Attorney General
Henry A. Salton · I
Assistant Attorney General I
I
Kerry A. Colson I
Assistant Attorney General _
55 Elm Street, P. O. Box 120
Hartford, CT 06141 ——- 0120 I
_ Robert Kalman
__ ;___¤