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

Case 3:01-cv-01971-PCD

Document 73

Filed 07/21/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

ERIC ATKINSON VS. KEVIN SCHIBI, ET AL.

: : : : :

NO. 3:01CV1971(PCD)(JGM)

JULY 20, 2004

MOTION FOR EXTENSION OF TIME TO FILE TRIAL PREPARATON ORDER SECTIONS B AND C The defendants in the above-captioned matter hereby respectfully move for an additional 30 days, up to and including August 19, 2004 within which to their Trial Preparation Order Section B. The defendants further move for two weeks from that date, until September 2, 2004, to file the Part C portion. In support of this motion, the defendants represent the following: 1. This is the first motion for an extension of time within which comply with the

deadline for Part B set by the Court after its ruling on plaintiff's Motion for Summary Judgment; 2. Due to the volume of cases assigned to the undersigned counsel and the inordinate

press of other matters, more timely response is most difficult. Moreover, the undersigned counsel has been extremely busy this week with a hearing that came up suddenly and was more complicated than originally thought, and has had a vacation planned for several months; and 3. Due to his incarceration, the plaintiff has not been contacted in order to determine

his position with regard to this motion. WHEREFORE, the defendants respectfully seek until August 19, 2004 to file their Part B and until September 2, 2004 for the Part C deadline.

Case 3:01-cv-01971-PCD

Document 73

Filed 07/21/2004

Page 2 of 2

DEFENDANTS Kevin Schibi, et al RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

___/s/______________________________ Lynn D. Wittenbrink Assistant Attorney General 110 Sherman Street Hartford, CT 06105 Federal Bar #ct08575 [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 20th day of July 2004: Eric Atkinson, #214214 Northern Correctional Institution P.O. Box 665 Somers, CT 06071

___/s/_______________________________ Lynn D. Wittenbrink Assistant Attorney General

2