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

Case 3:03-cv-00671-DJS

Document 34

Filed 11/24/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

ROY SASTROM & ROBERT KALMAN Plaintiffs

: : : : v. : : ROBERT BERGER, JOHN RYAN, : JANET WILLIAMS, SYLVIA CANCELA, : SUSAN BLAIR : Defendants :

PRISONER CIVL ACTION NO. 3:03 CV 671 (DJS)(TPS)

November 21, 2003

MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTIONS FOR SUMMARY JUDGMENT

Pursuant to Local Rule of Civil Procedure § 7(b), the defendants, Robert Berger, John Ryan, Janet Williams, Sylvia Cancela and Susan Blair, respectfully request an extension of time to respond to the plaintiff's two motions for summary judgment filed on October 31, 2003 and November 12, 2003. In the present case, discovery had not been completed. Although not obligated to do so, the defendants have taken the liberty of preparing a draft Rule 26(f) report and such report was submitted to the plaintiff for review on or about November 6, 2003. The draft Rule 26(f) report proposed that discovery be competed by May 20, 2003. To date, the plaintiff has not responded to the draft Rule 26(f) report and therefore such report has not yet been filed with the court. The undersigned hereby respectfully request an extension of time until such time as discovery has been completed to respond to the plaintiff's two motions for summary judgment.

Case 3:03-cv-00671-DJS

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Filed 11/24/2003

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The plaintiff, Robert Kalman, is confined at the Whiting Forensic Division of the Connecticut Valley Hospital.1 This is the defendants first request for extension of time. Counsel has not contacted the plaintiff regarding this motion for extension of time. DEFENDANTS ROBERT BERGER, JOHN RYAN, JANET WILLIAMS, SYLVIA CANCELA SUSAN BLAIR BY: RICHARD BLUMENTHAL ATTORNEY GENERAL

_________________________________ Kerry Anne Colson Assistant Attorney General Federal Juris No. ct 25241 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 [email protected] Tel: (860) 808-5210 Fax: (860) 808-5385

On July 28, 2003, the court dismissed all claims asserted by plaintiff Roy Sastrom for failure to file a complete application to proceed in forma pauperis. 2

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Case 3:03-cv-00671-DJS

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CERTIFICATION I hereby certify that a copy of the foregoing Motion for Extension of Time to Respond to Plaintiff's Motions for Summary Judgment was mailed in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on the 21st day of November 2003, first class postage prepaid to:

Robert Kalman Whiting Forensic Division 70 O'Brien Dr. Middletown, CT 06457

_________________________________ Kerry Anne Colson Assistant Attorney General

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Case 3:03-cv-00671-DJS

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Filed 11/24/2003

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