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

Case 3:00-cv—00705—CFD Document 182 Filed 07/21/2006 Page 1 of 3
IN TI-IE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
gE;{;¤1%E CORPORATION ) nvriismr File Noi 3:00cv-705 (ern)
SECURITIES LITIGATION g §_Iuly 219 2006
l
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME
Plaintiffs hereby move for an extension of time to and including August 4, 2006
to submit a Stipulation of Settlement and related exhibits in this matter. Plaintiffs’ Lead
Counsel need some brief a.dditional time to discuss the settlement and certain issues
raised by Attorney Su garman’s withdrawal with named plaintiff David Berlin.
Additionally, lead counsel require more time to investigate the reasons for Mr.
Sugarman's withdrawal. Thus, we request an additional two weeks to submit the
settlement documents.
This is the fifth 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 J une 26, 2006 and granted bythe Court on July l0, 2006. The fourth request was
filed on July 7, 2006 and granted on July l4, 2006. Plaintiffs counsel has contacted
defense counsel regarding this motion, and the Defendants take no position concerning
the requested extension of time.

Case 3:00-cv—00705—CFD Document 182 Filed 07/21/2006 Page 2 of 3
WHEREFORE, Plaintiffs request that the time to submit the Stipulation of
Settlement be extended t0 and including August 4, 2006.
A THE PLAll§TlFFS
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By: t*·i Z lt tt *“t”r*‘e-e;~»
J. Daniel Sagarin (CT04289)
David A. Slossherg (CT13116)
Brian C. Fournier (CTl6272)
Hurwitz, Sagarin, Slossherg & Knuff, LLC
l47 North Broad Street
Milford, CT 06460
(203) 877-8000
~and-
Sanford P. Duniain (CT08l38)
Lee A. Weiss Qyro hczc vice)
Shannon Hopkins (pm here vice)
Milberg Weiss Bershad & Schulman LLP
()ne Pennsylvania Plaza
· New York, NY 10119
(212) 594-5300
Lead Counsel lor Plaintiffs

Case 3:00-cv—00705—CFD Document 182 Filed 07/21/2006 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that on July 21, 2006 a eopy of the foregoing was mailed, tirst
elass mail and sent by facsimile to:
Stanley A. Twardy, Jr., Esq.
Day, Berry & Howard LLP
One Canterbury Green
Stamford, CT 06901
Michael gl. Chepiga, Esq.
Robert A, Bourque, Esq. V
William l\/lh Regan, Esq.
Simpson Thaeher & Bartlett LLP
425 Lexington Avenue
New York, NY 10017 fam;
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