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

. I . Case 3:03-cv-010%.-JBA Document 1-O3 Filed 05/I6/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
———-—-—-—-—-———-—— -- ——————————— X
H. JONATHAN FRANK E Docket No. 3:03CV0l0l4(JBA)
and FRANK FAMILY l996 TRUST, :
Plaintiffs, 3
v. Q
ARTHUR LOVETERE, et al., E
y Defendants. g May l3, 2005
I , _____________________________ 2;
MOTION FOR EXTENSION OF TIM
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, and Peter Eio (collectively, the
“Outside Directors") hereby move for an extension of time of
thirty (30) days, to and including June 20, 2005, in which to
respond and/or object to the plaintiff’s discovery requests
served on counsel for the Outside Directors on April 2l, 2005.
The Outside Directors' responses are currently due on or before
q May 2l, 2005. This is the Outside Directors' first request for l
an extension of time to respond to these discovery requests.
The Outside Directors require additional time to respond to
these discovery requests because: (l) on May l0, 2005, a
settlement conference was conducted before Magistrate Judge
Margolis in this matter, and, in an effort to minimize costs in

. . Case 3:03-cv-01014-JBA Document 103 Filed 05/1(6/2005 Page 2 of 3
( > ¤
advance of what they hoped would be a productive discussion, the
defendants did not expend substantial time and expense in
preparing responses to the discovery prior to the conference; (2)
three of the Outside Directors reside out of state, making the
preparation of their responses especially time-consuming; and (3)
counsel requires additional time to adequately respond to the
(requests, 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 six defendants.
Undersigned counsel has contacted plaintiff’s attorney,
Jeffrey Simes, who objects to this request. Mr. Simes has
indicated that he would consent, on certain grounds, to a limited
extension to June l0, 2005.
THE DEFENDANTS
ARTHUR LOVETERE, LOUIS J. BACCEI,
I WORTH LOOMIS, THEODORE PATLOVICH,
STEPHEN J. RAFFAY and PETER EIO
By:
·s T. Cowdery (ct05l03)
4 -.rah A. L. Merriam (ct25379)
Cowdery, Ecker & Murphy, L.L.C.
750 Main Street
Hartford, CT 06l03
Tel: (860) 278-5555
Fax: (860) 249-0129
E—mail: [email protected]

G ~ Case 3:03-cv—0101{4-JBA Document 103 Filed 05/1(6/2005 Page 3 of 3
CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing Motion for
Extension of Time was sent on May 13, 2005, via U.S. Mail, first-
class, postage pre-paid to all counsel of record as follows:
Jonathan B. Tropp, Esq. Jason J. Kuselias, Esq.
Patricia M. Canavan, Esq. Craig A. Raabe, Esq.
Terrence Gallagher, Esq. Robinson & Cole, LLP
Day, Berry & Howard, LLP 280 Trumbull Street
One Canterbury Green Hartford, CT 06l03-3597
Stamford, CT 0690l
Richard M. Strassberq, 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 l0022 Hartford, CT 06l03
James T. Shearin, Esq._
Pullman & Comley _
850 Main Street
P.O. Box 7006
Bridgeport, CT 0660l-7006
` Sarah A. L. Merriam