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

Case 3:03-cv-00727-CFD

Document 7

Filed 04/09/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WESLEYAN UNIVERSITY, Plaintiff, V. RSA VENTURE, LLC Defendants. : : : : : : : : : CIVIL ACTION NO. 303 CV 0727 (CFD)

APRIL 9, 2004

MOTION FOR EXTENSION OF TIME TO FILE STIPULATION OF DISMISSAL Pursuant to Rule 7(b) of the Local Civil Rules of the United States District Court for the District of Connecticut, the plaintiff, Wesleyan University ("Wesleyan"), respectfully requests an extension of time of thirty (30) days in which to file a Stipulation of Dismissal pursuant to Rule 41 of the Federal Rules of Civil Procedure, or otherwise advise the Court as to the status of the above-captioned litigation, up to an including May 10, 2004. Wesleyan submits that there is good cause for granting an extension of time. During the pendency of this matter, Wesleyan and the defendant, RSA Venture, LLC ("RSA"), have continually engaged in good faith settlement discussions in an effort to resolve the above-captioned matter. On February 23, 2004, the parties filed a Joint Status Report in which they advised the Court that they anticipated filing a Stipulation of Dismissal pursuant to Federal Rule 41 within thirty (30) days of the Joint Status Report, but reserved their respective rights in connection with this action.
One Goodwin Square 225 Asylum Street Hartford, CT 06103

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00727-CFD

Document 7

Filed 04/09/2004

Page 2 of 3

Although the parties have continued to engage in settlement negotiations and have reached a tentative resolution of this matter, they are still finalizing the specific terms thereof. Accordingly, Wesleyan requests the additional time to either file a Stipulation of Dismissal to allow the parties to finalize and execute the settlement agreement contemplated by the parties, or otherwise advise the Court as to the status of anticipated litigation at that time. This is Wesleyan's first request for an extension with regard to this matter. Counsel for RSA has consented to the extension. WHERFORE, the plaintiff, Wesleyan University, respectfully requests that the Court grant an extension of the time to file a Stipulation of Dismissal pursuant to Federal Rule 41 or otherwise advise the Court as to the status of the above-captioned litigation, up to an including May 10, 2004. Dated: April 9, 2004 Hartford, Connecticut RESPECTFULLY SUBMITTED, THE PLAINTIFF WESLEYAN UNIVERSITY By:________________________ Thomas J. Finn Federal Bar No.: ct 20929 Paula Cruz Cedillo Federal Bar No.: ct 23485 HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, Connecticut 06103 (860) 522-6103
-2­
One Goodwin Square 225 Asylum Street Hartford, CT 06103 Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00727-CFD

Document 7

Filed 04/09/2004

Page 3 of 3

CERTIFICATION This is to certify that on April 9, 2004, a copy of the foregoing was mailed, postage prepaid, to: Richard H. Saudek, Esq. Cheney, Brock & Saudek, P.C. P.O. Box 489 Montpelier, Vermont 05601-0489 Attorney for Defendant _____________________ Thomas J. Finn
535757

-3­
One Goodwin Square 225 Asylum Street Hartford, CT 06103 Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105