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Motion to Extend Response Deadline

Dr. James Murtagh requested a second extension to file a response to a motion to dismiss due to multiple winter storms that delayed his counsel's trial and travel plans, preventing preparation of the response by the original deadline of December 28. The storms caused a one day trial delay in Massachusetts, forced his counsel to drive home from Chicago after flight cancellations, and resulted in a snowstorm that closed his counsel's office in Michigan, all within the response period. Dr. Murtagh asked the court to extend his deadline to file the response to December 31.

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39 views2 pages

Motion to Extend Response Deadline

Dr. James Murtagh requested a second extension to file a response to a motion to dismiss due to multiple winter storms that delayed his counsel's trial and travel plans, preventing preparation of the response by the original deadline of December 28. The storms caused a one day trial delay in Massachusetts, forced his counsel to drive home from Chicago after flight cancellations, and resulted in a snowstorm that closed his counsel's office in Michigan, all within the response period. Dr. Murtagh asked the court to extend his deadline to file the response to December 31.

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JamesMurtaghMD.com
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© Attribution Non-Commercial (BY-NC)
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Case 2:12-cv-00160-NT Document 33 Filed 12/27/12 Page 1 of 2

PageID #: 581

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MAINE PORTLAND DIVISION JAMES MURTAGH, M.D, Plaintiff, v. ST. MARY S REGIONAL HEALTH CENTER, a/k/a ST. MARY S HOSPITAL, ST. MARY S HEALTH SYSTEM and IRA SHAPIRO, M.D. and JOHN DOE 1 THROUGH 10 and JANE DOE 1 THROUGH 10, Defendants. Case No. 2:12-cv-00160 NT

PLAINTIFF S SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE RESPONSE TO MOTION TO DISMISS Plaintiff Murtagh moves this court for an extension of time to file his response to Defendant s Motion to Dismiss through December 31, 2012 due to several winter storms that delayed a trial in which his counsel was the lead counsel for Defendants by one day [December 20, 2012 in Mass. Superior Court, Woburn], then forced him to drive home from Massachusetts due to the cancellation of flights caused by another storm [Chicago Illinois, December 22] and also prevented counsel from going to his office [Michigan snow storm on December 27, 2012]. The three days of weather related delays prevented counsel from preparing the response.

WHEREFORE, Murtagh requests that his deadline for a response be extended from December 28, 2012 through December 31, 2012.

Case 2:12-cv-00160-NT Document 33 Filed 12/27/12 Page 2 of 2

PageID #: 582

Respectfully Submitted, /s/Joseph C Bird 12/27/2012

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