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

_k fw——_—_Case 3:03-cv-01010—JBA”_ Document 128 Filed 06/24/2005 Page 1 of 3 émw
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CECIL YOUNG, :
: CIV. NO. 3:03CV1010 (JBA)
Plaintiffs :
VS.
CITY OF BRIDGEPORT HOUSING
AUTHORITY, ET AL :
Defendants JUNE 23, 2005
MOTION FOR EXTENSION OF TIME
The Plaintiff, Cecil Young, in the above caption matter, hereby respectfully
requests an extension of time to file documents reflecting the instant case may be
dismissed pursuant to a settlement between the parties. This request is being made in
accordance with correspondence of this date to the Court requesting a Status
Conference. Both parties have exchanged agreements and have had lengthy -
discussions concerning the language of the settlement agreement. However, there is
still an issue with the Defendants’ request for a novation and a shifting of the
responsibility to complete the settlement payment responsibilities from the Defendants
to a third-party insurance carrier, which the Plaintiff never agreed to.
On June 16, 2005 the Plaintiff had forwarded to the Defendants a document
completely releasing the Defendants from any and all liability to the Plaintiff with the
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Case 3:03-cv-01010-JBA Document 128 Filed 06/24/2005 Page 2 of 3
exception of Workers’ Compensation Claims and their responsibility to complete the
payments in accordance with the terms of the agreement.
We have spoken to Defense Counsel three (3) times since the documents were
fonivarded, and we understand the insurance carriers are still reviewing and editing or
amending this information. Therefore, we respectfully request a Status Conference with
the Court. As previously stated we have reviewed the transcript and believe the Plaintiff
has complied with its representations concerning settlement. The Plaintiff has also E
provided the Defendants with a signed form dismissing this matter with prejudice, as l
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was also agreed.
For the foregoing reasons the Plaintiff requests this Motion for Extension of Time |
be granted. I
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THE P ij;/~
BY
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`1`15 [GI Street, uite 710
Bridge ort, CT 06604
(203) 333-8500 I
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Case 3:03-cv-01010-JBA Document 128 Filed 06/24/2005 Page 3 of 3
CERTIFICATION
a
THIS IS TO CERTIFY that a copy of the foregoing was mailed, postage prepaid I
and/or sent by facsimile on this 23"' day of June, 2005 to:
James Mahar, Esq.
Ryan, Ryan, Johnson & Deluca, LLP
80 Fourth Street
Stamford, CT 06905 l
Barbara Brazzel-l\/Iassaro, Esq.
Office of the City Attorney if i
999 Broad Street / __ ,,.»· I
Bridgeport, CT 06604 \
I H I A J E.u—n e Q
_'g_ _C . iss' I/oft e Superior Court
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