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

i·——mHm_ Cage 3:03-cv-OO720_eJCH Document 28 Filed 07/30/2004 Page 1 °l 3 _ If
l · " O O
n
i “N$i§?Ri£t"'E§éiE‘E§J.E3““T fits i
l T v
i _______________________________ znuulut 30 A 0*5* i
J mvio Moimmsa, civn. xenon No. tm W.m.
l PLAMIFR 5 szoscvvzo non) A r it ,»;;:;:_ ;u·s. tzut iz
V. {
wvMAN-coRnoN mvssrmsur E
cxsrmcs, mc., 5
..“......._...... ‘?1EF:EH’?t?}`€Ti· .___. E —*¤LY29»2<><>4
Morton ron rxrnusrou or rms
The Plaintiff, David Mortimer ("Plaintiff Mortimer"), pursuant to Local Rule of
Civil Procedure 7(b) hereby requests an additional extension of time of two (2) weeks
from July 30, 2004 to August 13, 2004, to file closin papers relating to the settlement of
this matter.
In support hereof Plaintiff Mortimer represents as follows: i
- 1. Plaintiff Mortimer executed the Confidential Settlement Agreement and
General Release and it was sent to counsel for the Defendant on July 16, 2004.
2. As of July 28, 2004, counsel for the Defendant confirms that the
Settlement Agreement has been sent to the Defendant, Wyman Gordon, but that the
Agreement has not yet been executed by the Defendant.
3. Plaintiffs counsel drafted a Stipulation of Dismissal on July 8, 2004
and forwarded it via email to Defendant’s counsel for execution. Counsel for the I
gggr Aneuivmur Nor izngunsrrn R
{
I l
—


F



K

"——é_"—`“__m"_l
l
I . —· Case 3:03-cv-OO720>)lCH Document 28 Filed 07/SQ%5004 Page 2 of 3 I
-,,. __,
l l
l E
I Plaintiff continues to await receipt of the fully executed Stipulation so that they may tile I
I it with Court. · l
4, Once the fully executed Settlement Agreement and the settlement I
I monies are received by the Plaintiff’ s counsel, the Stipulation of Dismissal will executed
and filed by the undersigned.
5. Counsel for the Defendant Wyman Gordon has been consulted and he
consents to the requested extension of time.
WHEREFORE, the Plaintiff Mortimer respectfully requests an additional
extension of time up to and including August 13,2004, to file closing papers with the
Court.
THE PLAINTIFF, I
DAVID MORT1MER I
By: .
M` hael E. Satti (Ct. 01311)
Satti & Provatas, P.C.
225 State Street, Suite 200 I
New London, CT 06320 l
(860) 447-8975
—His Attorneys-
4 l

{ .. " Case 3:03-cv-OO72(?0Â¥c,ICH Document 28 Filed 07/3<0/$004 Page 3 of 3
r l
t l
l l
. I
CERTIFICATION {
This is to certify that on this day 29*hday of July 2004, the foregoing was sent via
First Class Mail, postage prepaid to the following attorneys of record:
Michael C. Wilcox, Esq.
Aloise & Wilcox
1 Exchange Place
Worcester, MA 06108
Louis P. Aloise
Aloise & Wilcox
1 Exchange Place
Worcester, MA 06108
Jon L. Schoenhom
Schoenhorn & Associates
97 Oak Street
Hartford, CT 06016 l
/ Migael E. Satti
6 l
3 l