Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:00-cv—OO705—CFD Document 184 Filed 08/O4/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR TIIE DISTRICT OF CONNECTICUT
) Master File N0. 3:00CV-705 (CFD) g
SECURITIES LITIGATION ; August 4, 2006 1
) t
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME
Plaintiffs hereby move for an extension of time to and including August 25, 2006
to submit a Stipulation of Settlement and related exhibits in this matter. Plaintiffs' Lead
Counsel needs some brief additional time to revise the settlement documents to reflect
Attorney Sugarman's withdrawal and the status of named plaintiff David Berlin, and to
discuss the revisions with counsel for the defendants. Thus, we request an additional
three weeks to submit the settlement documents.
This is the sixth request for an extension of time to comply with the "Notice to
Counsel" dated April 28, 2006 requiring counsel to tile closing papers on or before May
28, 2006. The second such request was granted by the Court on June 9, 2006 extending
the time to tile the Stipulation of Settlement until June 23, 2006. The third request was
tiled on June 26, 2006 and granted by the Court on July 10, 2006. The fourth request was
tiled on July 7, 2006 and granted on July 14, 2006. The fifth request was filed on July
21, 2006 and granted on July 26, 2006. Plainti ffs' counsel has contacted defense counsel
regarding this motion, and the Defendants take no position concerning the requested
extension of time.

Case 3:00-cv—OO705—CFD Document 184 Filed 08/O4/2006 Page 2 of 3
WHEREFORE, Plaintiffs request that the time to submit the Stipulation of
Settlement be extended to and including August 25, 2006.
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J. Daniel Sagarin (CT04289)
David A. Slossberg (CTI 3 l l6)
Brian C. Fournier (CTl6272)
Hurwitz, Sagarin, Slossherg & Knuff, LLC
l47 North Broad Street
Milford. CT 06460
(203) 877-8000
—and—
Sanford P. Dumain (CT 08138)
Lee A. Weiss (pro imc vice)
Shannon Hopkins (pm hczc vice)
Milberg Weiss Bershad & Schulman LLP
One Pennsylvania Plaza
New York. NY l0l l9
(212) 594-5300
Lead Counsel for Plaintiffs

Case 3:00-cv—OO705—CFD Document 184 Filed 08/O4/2006 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that on August 4, 2006 a copy of the foregoing was mailed, first
class mail and sent by facsimile to:
Stanley A. Twardy, Jr., Esq.
Day, Berry & Howard LLP
One Canterbury Green
Stamford, CT 06901
Michael J. Chepiga., Esq.
Robert A. Bourque, Esq.
William M. Regan, Esq.
Simpson Thaeher & Bartlett LLP _
425 Lexington Avenue
New York, NY I00l7
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__ Brian C. Fournier lfbi