Free Response - District Court of Connecticut - Connecticut

Case 3:01-cv-01908-AVC

Document 240

Filed 09/03/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOHN WARD Plaintiff VS. ROBERT MURPHY ­ Investigator for State of CT. et al Defendants : : : : : September 2, 2004 CIVIL ACTION NO.: 3:01 CV 1908 (AVC)

OBJECTION TO PLAINTIFF'S MOTION FOR EXTENSION OF TIME AND REQUEST FOR RECONSIDERATION Pursuant to D. Conn. L. Civ. R. 7(b)(2) and (3), the undersigned defendants hereby object to the plaintiff's motion for extension of time and Request for Reconsideration dated August 30, 2004. The plaintiff, John Ward, has failed to set forth any basis on which this Court should reconsider the undersigned defendant's Motion for Summary Judgment. Further, the plaintiff's request for an extension of time is based solely upon his status as a pro se litigant. The plaintiff has continuously requested extensions of time to respond to the undersigned defendant's Motion for Summary Judgment. Consequently, he has had sufficient time in which to evaluate how to proceed in the event that Judgment entered. ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Case 3:01-cv-01908-AVC

Document 240

Filed 09/03/2004

Page 2 of 4

Wherefore, for the foregoing reasons, the undersigned defendants request this Court sustain their objection to the plaintiff's motion for extension of time/Request for Reconsideration.

THE DEFENDANTS, DANBURY VISITING NURSE ASSOCIATION, VIRGINIA LOURENCO, R.N., JUDY GIBNEY, R.N., DANBURY HOSPITAL EITAN KILCHEVSKY, M.D. and JOAN MILLS

BY________________________________ BENJAMIN K. POTOK Of Bai, Pollock, Blueweiss & Mulcahey, P.C. 10 Middle Street Bridgeport, Connecticut 06604 (203) 366-7991 (203) 366-4723 fax #ct21298

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Case 3:01-cv-01908-AVC

Document 240

Filed 09/03/2004

Page 3 of 4

CERTIFICATION This is to certify that a copy of the foregoing has been mailed postage prepaid, first class mail to all counsel of record and pro se parties on _______, 2004. Mr. John Ward Ms. Donna Ward 18 Garamella Boulevard Danbury, Connecticut 06810 Carolyn Signorelli Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, Connecticut 06141-0120

__________________________ BENJAMIN K. POTOK

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Case 3:01-cv-01908-AVC

Document 240

Filed 09/03/2004

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ORDER The foregoing objection, having been heard by the Court, is hereby ordered: SUSTAINED/OVERRULED. BY THE COURT

BY__________________________ JUDGE/ASSISTANT CLERK

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