Free Response - District Court of Connecticut - Connecticut

Case 3:01-cv-01908-AVC

Document 185

Filed 01/21/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOHN WARD Plaintiff v. ROBERT MURPHY, et al. Defendant : : : : : : : CIVIL ACTION NO. 3:01CV1908 (AVC)

JANUARY 8, 2004

STATE DEFENDANTS' OBJECTION TO PLAINTIFF'S MOTION FOR EXTENSION OF TIME Pursuant to Local Rule 7(b)(2), the Defendants, employees of the Department of Children and Families, Robert Murphy, Ralph Arnone, Roger Lima, Sandra Liquindoli and Edward Federci, (hereinafter, "State Defendants") herein object to the plaintiff's motion for extension of time: The grounds for said objection are as follows: (1) The plaintiff has previously requested an extension to January 9, 2004, to which the State

Defendants did not object. He does not give any good cause for this second request. (2) The Court set a scheduling order on October 22, 2003 in order to bring this case, that has been pending since October 10, 2001, closure. (3) Plaintiff's requests for extensions of time are based upon his inability to articulate a response to the pending Motions for Summary Judgment. This is not a sufficient basis to extend this litigation further and subject the State Defendants to continued uncertainty regarding the pendency of this lawsuit.

ORAL ARGUMENT NOT REQUESTED. TESTIMONY NOT REQUIRED.

Case 3:01-cv-01908-AVC

Document 185

Filed 01/21/2004

Page 2 of 3

Wherefore, the State Defendants respectfully object to the plaintiff's Motion for Extension of Time and respectfully requests that the Motion be denied and the State Defendants' objection be sustained.

STATE DEFENDANTS BY: RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

_________________________________ Carolyn Signorelli Assistant Attorney General Federal Bar No.ct 17534 55 Elm Street, 3rd Fl. Annex Hartford, CT 06l06 Tel: (860) 808-5160 Fax: (860) 808-5384 e-mail:[email protected]

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Case 3:01-cv-01908-AVC

Document 185

Filed 01/21/2004

Page 3 of 3

CERTIFICATION I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 8th day of January, 2004, first class postage prepaid to: Mr. John Ward 18 Garmella Boulevard Danbury, CT 06810 James Williams, Esq. Williams, Walsh & O'Connor 110 Washington Avenue, 2nd Fl. North Haven, CT 06473 Stephen Fogerty, Esq. Halloran & Sage, LLP 315 Post Road West Westport, CT 06880 Heidi M. Cilano, Esq. Garie J. Mulcahey, Esq. Bai, Pollock, Blueweiss & Mulcahey, P.C. 10 Middle Street Bridgeport, CT 06604

_______________________________ Carolyn Signorelli Assistant Attorney General