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

Case 3:03-cv-01029-DJS

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Filed 09/20/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : : : : : PRISONER 3:03CV1029(DJS)(TPS)

CYRUS GRIFFIN Plaintiff VS. CAPTAIN MICHAEL CLEAVER, ET AL. Defendants

SEPTEMBER 16, 2004

MOTION FOR EXTENSION OF TIME The defendants in the above-entitled matter hereby, by and through the undersigned counsel and pursuant to Local Rule 9(d) and Federal Rule of Civil Procedure 12, respectfully move for a 60 day extension of time within which to file an answer or otherwise respond to plaintiff's Complaint, up to and including November 16, 2004. defendants represent the following: 1. The schedule of undersigned counsel has been extremely hectic as she is new to this In support of this motion, the

office, as she is defending the State in numerous other matters demanding her attention, as she did not receive the court's ruling on her motion to dismiss until September 3, 2004 when she received the revised scheduling order, as she is scheduled to conduct two habeas trials in Connecticut Superior Court, G.A. 19 in early October, 2004, as she will be out of the country from September 17, 2004 through October 2, 2004 2. This complaint contains complex factual and legal allegations;

Case 3:03-cv-01029-DJS

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3.

Additional time is necessary in order for the defendants to review the complaint and

pertinent documents in order to prepare an appropriate responsive pleading; 4. This is the second motion for an extension of time in this matter as to a responsive

pleading; and, 5. The undersigned counsel has not contacted counsel for the plaintiff to determine the

plaintiff's position with regard to this motion, since the plaintiff is pro se and is an inmate currently confined to Northern Correctional Institution.

DEFENDANTS, Captain Michael Cleaver, et al. RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:_____/s/________________________ Kathleen A. Keating Assistant Attorney General Federal Bar No. ct25247 110 Sherman Street Hartford, CT 06105 Telephone: (860) 808-5450 E-mail: [email protected]

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Case 3:03-cv-01029-DJS

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CERTIFICATION I hereby certify that a copy of the foregoing was sent by first-class mail, postage prepaid, this 16th day of September 2004, to: Cyrus Griffin Inmate # 262493 Northern Correctional Institution 287 Bilton Road, P.O. Box 665 Somers, CT 06071 ____________/s/______________________ Kathleen A. Keating Assistant Attorney General

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