Free Motion to Stay - District Court of Connecticut - Connecticut

Case 3:01-cv-01786-CFD

Document 114

Filed 12/09/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PRISONER CIVIL NO. 3:01CV1786 (CFD)(WIG)

GARY SADLER v. GOVERNOR ROWLAND, ET AL.

: : :

DECEMBER 7, 2004

DEFENDANTS' MOTION FOR STAY The defendants, John Rowland, et al., by and through their undersigned counsel, respectfully request a 60 day stay of the schedule for action in this case, to and including February 14, 2005, to permit exploration of settlement. This case is a civil rights action by Gary Sadler, a pro se inmate, complaining about numerous events and conditions of confinement when he was housed in Virginia in 2000. The additional time is needed because the parties have been seriously discussing settlement recently, and defendants now need time to correspond with, and obtain the approvals of, two state agencies and numerous defendants concerning the proposals. In the meantime, defendants are required to file their Motion for Summary Judgment in this case on December 13, 2004. Defendants are prepared to meet that deadline, but believe that a stay would improve chances for settlement as it would permit time to focus on the negotiations, necessary consultations and settlement paper preparation, circulation and filing, as opposed to litigation. If settlement fails, defendants will file their Motion for Summary Judgment by February 14, 2005.

ORAL ARGUMENT NOT REQUESTED

Case 3:01-cv-01786-CFD

Document 114

Filed 12/09/2004

Page 2 of 2

Wherefore, the defendants request a 60 day stay of the schedule for action in this case, to and including February 14, 2005, to permit exploration of settlement.

DEFENDANTS John Rowland, et al. RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

_____/s/_____________________________ Robert F. Vacchelli Assistant Attorney General 110 Sherman Street Hartford, CT 06105 Federal Bar #ct05222 E-Mail: [email protected] Tel.: (860) 808-5450 Fax: (860) 808-5591

CERTIFICATION I hereby certify that a copy of the foregoing was mailed to the following on this 7th day of December, 2004: Gary Sadler #236395 MacDougall-Walker Correctional Institution 1153 East Street South Suffield, CT 06080

______/s/____________________________ Robert F. Vacchelli Assistant Attorney General 2