Skakel v. Murphy

Filing 42

MOTION for Leave to File Excess Pages by Michael C. Skakel. (Attachments: # 1 Exhibit Proposed Reply Brief With Excess Pages)(Seeley, Hope)

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MICHAEL C. SKAKEL Petitioner, v. PETER J. MURPHY, Respondent. : : : : : : : CASE NO. 3:07 CV 1625 (PCD) JANUARY 7, 2009 MOTION FOR LEAVE TO FILE EXCESS PAGES Pursuant to Rule 7(d) of the Local Rules of Civil Procedure, the Petitioner, Michael Skakel, respectfully requests permission to file a Reply Brief that is longer than ten (10) pages in length. Mr. Skakel's Reply Brief is 17 pages in length. The extra pages are necessary for the following reasons. This was a murder case that originated in the Superior Court for the State of Connecticut and was appealed to the Connecticut Supreme Court. A Petition For Certiorari was also filed with the United States Supreme Court. The factual background and procedural history of the case is lengthy. The Respondent has raised in his 76-page memorandum five complex issues of constitutional magnitude which require additional pages for full and complete reply. Counsel for the Respondent, Michael O'Hare, has been contacted and has no objection to this motion. Wherefore, for the foregoing reasons, Mr. Skakel respectfully requests that the Court permit him to file a Reply Brief that exceeds the ten (10) page limit. THE PETITIONER, MICHAEL C. SKAKEL BY /s/__________ ___________ HUBERT J. SANTOS Federal Bar No. ct00069 Email: hsantos@santos-seeley.net HOPE C. SEELEY Federal Bar No. ct 4863 Email: hseeley@santos-seeley.net SANDRA SNADEN KUWAYE Federal Bar No. ct18586 Email: ssnaden@santos-seeley.net SANTOS & SEELEY, P.C. 51 Russ Street Hartford, CT 06106 Tel: (860) 249-6548 Fax:(860) 724-5533 2 CERTIFICATION I hereby certify that on January 7, 2009, a copy of the foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by email to all parties by operation of the Court's electronic filing system or by mail on anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. Michael O'Hare, Esq. Office of the Chief State's Attorney 300 Corporate Place Rocky Hill, CT 06067 Tel. No. (860) 258-5887 Fax No. (860) 258-5968 E-mail: michael.ohare@po.state.ct.us Federal Bar No. ct 05318 _/s/___________________________ HOPE C. SEELEY 3

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