By Ryan Michaels | The Maine Mirror | September 30, 2026



There was movement today in my federal lawsuit, Michaels v. Haynes, et al., Case No. 2:26-cv-00056-LEW.

The two defendants I was able to successfully serve, the Town of Berwick and Amy Cilley, are now represented by attorneys, and both sought additional time today to respond to my complaint.

The requests, however, were different.

Two Defendants, Two Requests for More Time

Amy Cilley’s attorney filed a motion asking the U.S. District Court for the District of Maine for an additional seven days, moving her requested response deadline from October 2 to October 9, 2026.

That filing also clearly informed the Court that I oppose the extension.

The Town of Berwick requested substantially more time.

According to the Town’s motion, Berwick was served on September 10, 2026, making its response due October 1. On September 30, one day before that deadline, the Town’s newly appearing attorney requested an additional three weeks, asking the Court to move the deadline to October 22.

Along with those filings, the Town’s attorney sent me a letter dated September 30.

The letter informed me that a Notice of Appearance and the Town’s Motion to Enlarge Time had been filed that day. It then asked me to provide my position:

“Please let me know at your earliest convenience whether you consent to the enclosed Motion.”

(September 30, 2026 correspondence from attorney John J. Wall III to Ryan Michaels accompanying the Town of Berwick’s court filings and asking Michaels to advise whether he consents to the Town’s motion for additional time.)



What the Court Filing Said

There is one portion of the Town’s filing that I believe warrants clarification.

Paragraph 7 of the motion states:

“The undersigned counsel has not reached the Plaintiff and, therefore, does not know his position with regard to the Motion.”

The very next paragraph states:

“The undersigned counsel will promptly notify the Court if he learns of the Plaintiff’s position.”

The motion then asks the Court to extend Berwick’s deadline by three weeks, until October 22.

(Excerpt from the Town of Berwick’s September 30, 2026 Motion to Enlarge Time showing paragraphs 7 and 8, including counsel’s statement that he “has not reached the Plaintiff” and his representation that he would promptly notify the Court upon learning the Plaintiff’s position.)



I want to be careful about what those documents do and do not establish.

The motion states that counsel had not reached me and therefore did not know my position. The correspondence sent to me that same day asks me to provide that position.

I cannot speak to counsel’s intent, nor do I intend to speculate about it.

I can document what happened next.

I Responded

After receiving the request, I informed counsel that I did not consent to the Town’s requested three-week extension.

I also made clear that the ultimate determination of whether additional time is warranted belongs to the Court.

After reviewing the Town’s filing, I decided that simply communicating my position privately to counsel was not enough. Because paragraph 7 addressed whether counsel had reached me and whether my position was known, I wanted the chronology reflected clearly in the court record.

I therefore prepared a short response to the Town’s motion and served a copy on its attorney.

( September 30, 2026 email from Ryan Michaels to attorney John J. Wall III serving a copy of Michaels’ response to the Town’s Motion to Enlarge Time and advising that the response was being submitted to the Court for filing.)



Putting the Chronology Before the Court

My response is intentionally narrow.

It does not accuse the Town or its attorney of dishonesty or misconduct.

Instead, it states five basic points: I do not consent to the three-week extension; the Town’s filing states that counsel had not reached me and did not know my position; counsel sent me correspondence on September 30 asking for my position; I responded that same day; and the Town filed its three-week extension request one day before its acknowledged October 1 response deadline.

The response concludes:

“Plaintiff respectfully opposes the requested extension and leaves the determination of whether good cause exists for the requested enlargement to the Court.”

(Plaintiff Ryan Michaels’ September 30, 2026 response to the Town of Berwick’s Motion to Enlarge Time, documenting his opposition, the chronology of the September 30 correspondence, and his request that the Court determine whether good cause exists for the requested extension.)



Why I Am Showing the Documents

There is an unusual dynamic involved in reporting on litigation in which I am also the plaintiff.

That makes transparency especially important.

When I write about this case through The Maine Mirror, readers should be able to distinguish between what I allege as a plaintiff, what defendants and their attorneys say, what the documentary record establishes, and what the Court ultimately decides.

Those things are not interchangeable.

In this instance, I do not need to tell readers what to think about the wording of the Town’s motion or the timing of its request.

The documents are available.

The dates are available.

My response is available.

And the Court will decide whether the Town has established sufficient grounds to receive the additional three weeks it requested.

Whatever that decision ultimately is, I believe the most responsible approach is to put the underlying record in front of readers and allow them to examine it for themselves.

The Maine Mirror will continue documenting developments in Michaels v. Haynes, et al. while clearly distinguishing allegations, representations by the parties, documented facts, and decisions made by the Court.


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