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ANNE MILGRAM
ACTING ATTORNEY GENERAL OF NEW JERSEY
R.J. Hughes Justice Complex
25 Market Street
P.O. Box 112
Trenton, NJ 08625-0112
Attorney for Defendants,
State of New Jersey, the Hon. W. Hunt Dumont, P.J.Cv.
and the Hon. Deanne M. Wilson, J.S.C.
By: Kimberly A. Sked
Deputy Attorney General (609) 777-3609
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
VICINAGE OF NEWARK
GARY MOSHER,
THE HON. STANLEY R. CHESLER,
U.S.D.J. Plaintiff,
DOCKET NO. 06-2526 (SRC-CCC) v.
Civil Action
THE STATE OF NEW JERSEY,
JUDGE DEANNE M. WILSON, JUDGE CERTIFICATION OF COUNSEL WILLIAM HUNT DUMONT, JUDGE DENNIS CAVANAUGH, and PATRIOT MEDIA,
Defendants.
Kimberly A. Sked, of full age, hereby certifies and says:
1. I am licensed to practice law in the State of New Jersey and am admitted to practice before the United States District Court, District of New Jersey. I am employed by the State of New Jersey, Department of Law and Public Safety, as a Deputy Attorney General. I am assigned to represent Defendants State of New Jersey, the Honorable W. Hunt Dumont, P.J.Cv., and the Honorable Deanne M. Wilson, J.S.C. (collectively, the "State Judicial Defendants"), in this case.
2. I make this certification on behalf of the State Judicial Defendants in support of their motion, pursuant to Fed. R. Civ. P. 6(b)(1), for an extension of time until October 5, 2006 to Answer, move or otherwise reply to the Complaint.
3. The State Judicial Defendants are judges appointed to the Superior Court of New Jersey, and are assigned to the Law Division, Morris Vicinage. Plaintiff alleges that they have violated his constitutional rights in the course of adjudicating two State court lawsuits. See Complaint, page 2, Cause of Action. Plaintiff appears to be seeking that the State of New Jersey be held vicariously liable for the judges' decisions. With respect to the relief sought, Plaintiff asks this Court to order an investigation of the New Jersey Judiciary, resolve his State claims, and grant him unspecified compensatory and punitive damages. Complaint, page 5, fU 1-3.
4. On June 22, 2006, the State Judicial Defendants received copies of the Summons and Complaint by mail with requests for waivers of service dated June 22, 2006.
5. Each of the State Judicial Defendants executed and returned the waivers of service.
6. The State Judicial Defendants were granted representation by the Attorney General of New Jersey.
7. On August 10, 2006, the State Judicial Defendants were granted a Clerk's Extension, pursuant to L. Civ. R. 6.1, extending their time to respond to September 5, 2006.
9. Due to the vagueness of Plaintiff's Complaint, this office is still investigating the Plaintiff's allegations concerning the State Judicial Defendants in order to answer, move, or otherwise respond to the Complaint.
10. The State Judicial Defendants request the additional time in order to more fully and diligently investigate the facts surrounding the Complaint prior to preparing a responsive pleading in this matter.
11. The delay in filing a response in this case would in no way prejudice the Plaintiff. Rather, it will provide the State Judicial Defendants the opportunity to present meritorious defenses and to appropriately respond to the allegations raised in the Complaint.
I certify under penalty of perjury that the foregoing is true and correct.
Kimberly A. Sked
Deputy Attorney General
Dated: September 5,-2006 |
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