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Defendants Case Summary

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Defendants, former Assistant Warden Richard Miller, Former Executive Director Scott S. Oakley, Sergeant Jamie Farris, and Correctional Officer II Shawn Murray, by their attorneys, Brian E. Frosh, Attorney General of Maryland, and Nicholé C. Gatewood, Assistant Attorney General, move, pursuant to Fed.R.Civ.P. 6(b)(1)(A), for an extension of time to and including February 29, 2016, to file a response to the complaint filed in the above-captioned case for the following reasons: 1. By Order dated December 16, 2015, this Court granted the Defendants an extension of time to and including January 28, 2016, within which to file a response to the complaint. ECF Document No. 16. 2. On January 18, 2016, undersigned counsel returned to the office from family leave and on January 20th was involved in an accident. Due to an injury, undersigned counsel is presently out of the office on leave. However, arrangements have been made to obtain declarations from North Branch Correctional Institutional personnel to complete drafting Defendants’ detailed response …show more content…
An additional thirty (30) day period to and including February 29, 2016 within which to respond to the Complaint should be sufficient to prepare Defendants' initial pleadings. However, it is anticipated that the response will be filed before this date. 4. This Motion is not made for purposes of delay. WHEREFORE, it is respectfully requested that this Court grant leave for Defendants former Assistant Warden Richard Miller, Executive Director Scott S. Oakley, Sgt. Jamie Farris, and Correctional Officer II Shawn Murray, to file a response in the instant case on or before February 29, 2016. Respectfully submitted,

BRIAN E. FROSH Attorney General of Maryland

/s/ NICHOLÉ C. GATEWOOD Assistant Attorney General Federal Bar No. 28278

St. Paul Plaza - 19th Floor 200 St. Paul Place Baltimore, Maryland 21202 (410) 576-6598 (Telephone) (410) 576-6880

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