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

Case 3:01-cv-01979-WWE

Document 43

Filed 04/27/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT KARL HOGFELDT Plaintiff vs. OLD SAYBROOK POLICE DEPARTMENT SERGEANT DONALD HULL; PATROLMAN DAVID PERROTTI; PATROLMAN CHRIS DEMARCO; PATROLMAN JAY RANKIN; EACH INDIVIDUALLY AND AS POLICE OFFICERS AND MEMBERS OF THE OLD SAYBROOK POLICE DEPARTMENT; AND THE TOWN OF OLD SAYBROOK OF OLD SAYBROOK : : : : : : : : : : : : : : CIVIL ACTION NO. 3:01 CV 1979 (WWE)

APRIL 23, 2004

PLAINTIFF'S MOTION NUNC PRO TUNC FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT The Plaintiff in the above-referenced matter hereby moves Nunc Pro Tunc for leave of the court to extend time to respond to the Defendants' Motion for Summary Judgment for a period of thirty (30) days from the date of the present request. In support of this Motion the Plaintiff hereby represents: 1. That the Motion for Summary Judgment in this matter is lengthy and raises a number of complex issues of law and facts; 2. That the Plaintiff has to date spent considerable time and expense in

Case 3:01-cv-01979-WWE

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obtaining two necessary expert witness reports that only recently became available; 3. That considerable time and effort has been expended to date by the Plaintiff in drafting his response which is approximately two-thirds complete; 4. That the Plaintiff further represents that he is a solo practitioner who is presently involved in a lengthy trial in the New Haven Superior Court which is expected to extend for at least thirty days; 5. The Plaintiff's counsel also represents that his client is an indigent citizen, who has raised a very significant claim of police misconduct which claim is now supported by two respected experts, one of whom is a State of Connecticut Medical Examiner; 6. Defendants' counsel has been contacted to learn if he has an objection to the present motion, but the Plaintiff has been unable to obtain a response to date.

Case 3:01-cv-01979-WWE

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Filed 04/27/2004

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ACCORDINGLY, for the above state reasons, the Plaintiff requests an extension of time of thirty (30) days of the date of this motion until May 24, 2004, to file his response to the Defendants' Motion for Summary Judgment. PLAINTIFF,

BY______________________________ A. Paul Spinella, Esq. Spinella & Associates One Lewis Street Hartford, CT 06103 Telephone: (860) 728-4900 Fax: (860) 728-4909 Federal Bar #: ct00078

O R D ER The foregoing Motion/Objection having been presented, IT IS HEREBY ORDERED GRANTED/DENIED BY THE COURT,

_________________________ Clerk/Ass't Clerk/J udge Dated:________________________

Case 3:01-cv-01979-WWE

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CERTIFICATION THIS IS TO CERTIFY that a copy of the foregoing has been mailed postage pre-paid on this date to: Daniel C. DeMerchant, Esq. Thomas R. Gerarde, Esq. John J. Radshaw, III Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114-1190 Bruce E. Newman, Esq. Law Offices of Bruce E. Newman, LLC One High Street P.O. Box 927 Deep River, CT 06417

____________________________ A. Paul Spinella, Esq.