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

Case 3:03-cv—01014-JBA Document 116 Filed 06/17/2005 Page 1 of 3
UNITED STATES DISTRICT COURT 4
DISTRICT OF CONNECTICUT
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H. JONATHAN FRANK : Docket No. 3:03CV01014(JBA)
and FRANK FAMILY 1996 TRUST, :
Plaintiffs, E
v. E
ARTHUR LOVETERE, et al., E
Defendants. E June 17, 2005
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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, and defendant Cecil
Ursprung, hereby move for an extension of time of sixteen (16)
days, to and including July 6, 2005, in which to respond and/or
object to the plaintiff’s discovery requests served on counsel
for the defendants on April 21, 2005. The responses are
currently due on or before June 20, 2005. This is the
defendants’ second request for an extension of time to respond to
these discovery requests.
V The defendants require additional time to respond to these
discovery requests because: (1) although the requests are dated
April 20, 2005, the defendants did not begin preparing responses
until after a settlement conference in May failed to produce a
resolution; (2) several of the defendants reside out of state,
making the preparation of their responses especially time-

Case 3:03-cv—01014-JBA Document 116 Filed 06/17/2005 Page 2 of 3
consuming; (3) the summer vacation schedules of the defendants,
counsel, and staff have made the gathering andyprocessing of the
requested materials logistically difficult; and (4) counsel
requires additional time to adequately respond to the requests,
9 which include more than forty (40) requests for production, many
of which have numerous “sub-parts,” and a number of
interrogatories, all directed to each of these defendants.
Undersigned counsel has attempted, but has been unable to
reach plaintiff’s counsel, Jeffrey Simes and Richard Strassberg,
to determine their position regarding this request.
THE DEFENDANTS
ARTHUR LOVETERE, LOUIS J. BACCEI,
WORTH LOOMIS, THEODORE PATLOVICH,
STEPHEN J. RAFFAY and PETER EIO
..
By: .
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: {€@Q§;::
Edward . Spinella, Esq.
Reid and Riege, P.C.
One Financial Plaza
Hartford, CT 06103
Tel: (860) 240-1045
Fax: (860) 240-1002
E-mail: [email protected]

Case 3:03-cv—01014-JBA Document 116 Filed 06/17/2005 Page 3 of 3
CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing Motion for
Extension of Time was sent on June l7, 2005, via facsimile and
via U.S. Mail, first-class, postage pre-paid to all counsel of
record as follows:
Jonathan B. Tropp, Esq. Jason J. Kuselias, Esq.
Terrence Gallagher, Esq. Craig A. Raabe, Esq.
Day, Berry & Howard, LLP Robinson & Cole, LLP
One Canterbury Green 280 Trumbull Street
Stamford, CT 0690l Hartford, CT 06l03—3597
Richard M. Strassberg, Esq. Edward F. Spinella, Esq.
Jeffrey Alan Simes, Esq. Todd S. Federico, Esq.
Goodwin Procter, LLP Reid and Riege, P.C.
599 Lexington Avenue One Financial Plaza
New York, NY l0O22 Hartford, CT 06103
James T. Shearin, Esq.
Pullman & Comley
850 Main Street
P.C. Box 7006
Bridgeport, CT 0660l—7006
v
arah A. L. Merriam