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

Case 3:00-cv-00705-CFD Document 179 Filed 07/07/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
Master File N o. 3:00CV-705 (CFD)
IN RE: PE CORPORATION )
SECURITIES LITIGATION ; July 7, 2005
)
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME
Plaintiffs hereby move for an extension of time to and including July 2l, 2006 to submit
a Stipulation of Settlement and related exhibits in this matter. Plaintiffs’ Lead Counsel has very
recently been informed by Robert Sugarman that he is withdrawing as counsel for named
plaintiff, David Berlin. Inasmuch as Mr. Sugarman has been the sole contact with Mr. Berlin in
connection with the settlement ofthe above matter, we will need some brief additional time to
contact Mr. Berlin directly to discuss the settlement and certain issues raised by Mr. Sugarman’s
withdrawal. Additionally, the reasons for Mr. Sugarman’s withdrawal raise concerns which we
are investigating. Thus, we request an additional two weeks to submit the settlement documents.
This is the third request for an extension of time to comply with the "Notice to Counsel"
dated April 28, 2006 requiring counsel to file 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 file the
Stipulation of Settlement until June 23, 2006. The third request was filed on June 26, 2006 and
has not been acted upon by the Court. Plaintiffs counsel has contacted defense counsel
regarding this motion, and the Defendants take no position concerning the requested extension of
time.
WHEREFORE, Plaintiffs request that the time to submit the Stipul ation of Settlement be
extended to and including July 21, 2006.

Case 3:00-cv—00705—CFD Document 179 Filed 07/07/2006 Page 2 of 2
THE PLAIN TIFF S
__
J. Daniel Sagarin (CT04289)
David A. Slossberg (CT13116)
Brian C. Fournier (CT16272)
Hurwitz, Sagarin, Slossberg & KnuffQ LLC
147 North Broad Street
Milford, CT 06460
(203) 877-8000
—and-
Sanford P. Dumain (CT 08 1 38)
Lcc A. Weiss (pro Imc vice)
Shannon Hopkins (pm hczc vice)
Milberg Weiss Bershad & Schulman LLP
One Pennsylvania Plaza
New York, NY 101 19
(212) 594-5300
Lead Counsel for Plaintiffs
CERTIFICATION OF SERVICE
This is to certify that on July 7, 2006 a copy ofthe 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 .1. Chcpiga, Esq.
Robert A. Bourque, Esq.
William M. Regan, Esq.
Simpson Thacher & Bartlett LLP
425 Lexington Avenue
N ew York, NY 10017
{ Y__, V
l . ...2 .5 ri~rzT1.g,»-»·it.-...»»»~*·“fi“*?· _
Dawd A. Slossberg