Free Motion for Extension of Time to Complete Discovery - District Court of Delaware - Delaware

I »L : IN THE UNITED STATES DISTRICT COURT
’ F012 THE Dxsnuicr or mamma
O. BURBAGE ,_ _
plainéiffl S CASE NO. # O4 133 SLR
cm or wnmmcrxou, DELENARE ¥ __ 14 S __ . . ..~. I
et,al * I: I .· I i
Q _ _ __;
PIAINI‘IFF'S PDTION EUR
ADDITIONAL TIME
{
CII“IE'5N()W, 'Ihe PLAINTIFF, 0, BURBAGE in a Pro-Se Fashion ask's and
herby moves this Honorable Court for Additional Time, in which to finish Discovery
and Pre-trigzil Motions in the above entitled and numbered cause, as grounds for
this motion.
Plaintiff 's States, that he has still been experiencing bad recovery
symptoms, such as ( a fourth time getting an enternal tissuetand leg infection ),
coming from the operation and no follo·w—up or rehabe enstilled for recovery,
which still makes it very hard to sit and work of timely measures preparing this
case. For at this time our medical staff here at F.C.I. EUCION IS GOING THRU a
very hard and disarraech level of medical suffic.ieng;y. And in addition, on FEBRUARY
14, 2005 the Plaintiff was put in for transfer due to, the true level of reduction
otwards his custody status and also will be transfered and can be asked to packout
at any time.
IJHEREEORE, Plaintiff states even with this uncontrolable situation
the plaintiff Pray's and Respectfully request this Honorable Court Grant
additional time in which téffinnissh Discovery and Pre—tr.=iaal motions.
(1)

Case 1:04-cv—OO133—SLR Document 35 Filed 03/21/2005 Page 2 of 3
DATES . . 5/. V. ' . }a¤.·¤¤·» · 1 ·· ; vv nn ‘
" *"`* •· I I rr , ;<•·I:-
F.C.I. ELKION
REI; # 21524-051
P.0. BOX 10
LISBON, OHIO MA32
P.S. i.e.
EMZPHASIS ADDED: CITING HAINE".5 V, KERNER 30. LEd,2d 652
the SUPREME COURT HELD THAT: under Pleading § 130 Pro-Se complaint holds
allegations of a pro—se complaint to less stringent standards than formal
pleadings drafted by lawyers.
SUBSCIRBED and SWORN to before this day of .20
I am
NOIARY PUBLIC
My Conmision Exspires; .
··AuTu0R1zn0 nv THE ACT or JULY zv, --255.
T0 AnM1r~e1srsu OATI-lS(18 usc 40041*.
g · :050]
CORRECTIONAL TREATMENT SPECIALIST
E[:5{0€
DATE

Case 1:04-cv—OO133—SLR Document 35 Filed O3/21/2005 Page 3 of 3
PROOF OF SERVICE
I, KNOWLINGTON O, BURBAGE, certify that on { ,
ZQQEC Imailed a copy of this document and all attachments via first class mail
to the following parties at the addresses below;
CLERK OF COURTS
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELEWARE
8éh NORTH KING ST.
LOCK BOX 18
WILMINGTON, DELEWARE 19801
ROSAMARIA TASSONE, ESQUIRE
ASSISTANT CITY SOLICITOR
CITY OF WILMINGTON LAW DEPARTMENT
800 N. FRENCH ST. 9TH FLOOR
WILMINGTON, DELEWARE 19801
I.D. #35hé
PROOF OF SERVICE FOR INCARCERATED LITIGANTS
In addition to the above proof of service, all litigants who are currently
incarcerated should include the following statements wiht all documents to be filed
with court;
I certify that this document was given to officials on this date for
forwarding to the UNITED STATES DISTRICT COURT CLERK OF DISTRICT OF DELWARE,
and ROSAMARIA TASSONE, ESQ. I futher certify under penalty of perjury that
the foregoing is true and correct. TTLE 28 U.S.C. §1746
I / T? I `
RESPECTFULLY SUBMITTED THIS { day of "’ I , ZOJS .
i;;%;‘* ‘" ?TEEgl!EEF e§?R”EjZCgc Q
KNOWLINGION O, BURBAGE ,
F.C.I. ELKTON
REG #2152h-051
P.O. BOX 10 `
LISBON, OHIO éé432
PLEADINGS BY PRISONERS WHO REPRESENT THEMSELVES ARE TO BE FILED AT THE ¤
PKIMHTF SUCH PLEADINGB ARE DELIVERED TO PRISON AUTHORITTES FOR FORWORDING I
TO CLERK ( HOUSTON V, LACK, 487 U.S. 266 ( 1988m) ). 1
x

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