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

Case 3:03-cv—01014-JBA Document 120 Filed 07/07/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
—————————————————————————-——- —-X
H. JONATHAN FRANK : Docket No. 3:03CV0l014(JBA)
and FRANK FAMILY 1996 TRUST, : 1 `
Plaintiffs, 5
v. ;
ARTHUR LOVETERE, et al., E
Defendants. i July 7, 2005
-————-———-————---——--——— e ---—— X
MOTION FOR EXTENSION OF TIME
Pursuant to Rule 6(b) of the Federal Rules of Civil
Procedure and Rule 7(b) of the Local Rules of Civil Procedure,
defendants Arthur LoVetere, Louis Baccei, Worth Loomis, Theodore
Patlovich, Stephen Raffay, Peter Eio, William Rowland and Cecil
Ursprung, hereby move for an extension of time of six (6) days,
to and including July 14, 2005, in which to respond to the Second
Amended Complaint. The requested extension would give the
defendants a total of twenty (20) days from the date of filing of
the complaint in which to file a response. The defendants’
responses are currently due on June 8, 2005. This is defendants’
first request for an extension of this deadline, which was set by
the Court in a scheduling order filed June 10, 2005.
- The Second Amended Complaint consists of 84 paragraphs, many
of which are lengthy and include numerous allegations, legal
conclusions, and extraneous narrative. Although the complaint
was filed with the Court on June 24, 2005, it was not served on
counsel for the defendants until June 27, 2005, and most of the

Case 3:03-cv—01014-JBA Document 120 Filed 07/07/2005 Page 2 of 3
defendants did not personally receive copies until later that
week. The short time available for review of the complaint was ·
further hindered by the intervening Independence Day holiday.
Several of the defendants reside out-of-state, and one has lost
much of his sight, making the review of the allegations of the
new complaint and preparation of appropriate responses especially
time-consuming. n
Plaintiff’s counsel, Terrence Gallagher, did not take a
position on this request.
THE DEFENDANTS
ARTHUR LOVETERE, LOUIS J. BACCEI,
WORTH LOOMIS, THEODORE PATLOVICH,
STEPHEN J. RAFFAY, PETER EIO and
WILLIAM ROWLAND
By:
-s T. Cowdery (ct05103)
. ah A. L. Merriam (ct25379)
Cowdery, Ecker & Murphy, L.L.C.
750 Main Street
Hartford, CT 06103 `
· Tel: (860) 278-5555
Fax: (860) 249-0129
E-mail: [email protected]
DEFENDANT CECIL URSPRUNG
By: ·
Edward F Spinella, Esq.
Reid and Riege, P.C.
One Financial Plaza t
Hartford, CT 06103
Tel: (860) 240-1045
» Fax: (860) 240-1002
E-mail: [email protected]

Case 3:03-cv—01014-JBA Document 120 Filed 07/07/2005 Page 3 of 3
CERTIFICATION 5
THIS IS TO CERTIFY that a copy of the foregoing Motion for
Extension of Time was sent on July 7, 2005, via facsimile and via
U.S. Mail, first—class, postage pre-paid to all counsel of record
as follows:
Jonathan B. Tropp, Esq.
Terrence Gallagher, Esq.
Day, Berry & Howard, LLP
One Canterbury Green
Stamford, CT 06901
Richard M. Strassberg, Esq.
Jeffrey Alan Simes, Esq.
Goodwin Procter, LLP
599 Lexington Avenue
New York, NY 10022
Edward F. Spinella, Esq.
Todd S. Federico, Esq. _
Reid and Riege, P.C.
One Financial Plaza
Hartford, CT 06103
James T. Shearin, Esq.
Pullman & Comley
850 Main Street
P.O. Box 7006
Bridgeport, CT 06601-7006
Q \
ah A. L. Merriam