Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

YUM--1-- °"°°°°°"_°M_"
‘ Case 3:03-cv-01Og5JCH Document 29 Filed O1/05/2004 Page 1 of 3
¤ E O l
l
UNITED STATES DISTRICT COURT l
DISTRICT OF CONNECTICUT _ ,,_ 2 ¤
lllllli rlllrl ·- E3 A lu- l \
UNITED TECHNOLOGIES CORPORATION, I _·303CVlOO7 ICH 5
Plaintiff, : A ·· A `
I PARKER HANNIFIN CORP.’S
v. : MOTION FOR EXTENSION OF 5
TIME TO FILE
MEMORANDUM IN
OPPOSITION TO PLAINTIFF’S
MOTION FOR STAY
¤ m
PARKER HANNIFIN CORPORATION, : l
Defendant : December 30, 2003
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO FILE MEMORANDUM IN
OPPOSITION TO PLAINTIFF’S MOTION FOR STAY l
Pursuant to Rule 7(b) of the Local Rules of Civil Procedure, the Defendant, Parker
Hannifin Corporation, respectfully submits this Motion for Extension of Time in response to the
Plaintiffs Motion for Stay. · ‘ = ·o
The background of this case is set out in length in previously filed court papers. On
December I2, 2003, the Plaintiff moved for a stay based on the assertion that the claims against
the Defendant in this action arise out the same facts that engendered its claims against the
Defendant in concurrent, private ADR. Thus, the Plaintiff is now seeking a stay pending
completion of arbitration under private ADR. 4
l
The Defendant takes issue with the Plaintiff s assertions in its Motion for Stay, and plans
to file an opposition brief However, for reasons set forth below, the Defendant moves for an `
extension of thirty days beyond the 2l—day period set forth in Local Rule 7(a), by which a party I
shall file a memorandum in opposition to any motion. I
_ g
,__ l _ "`T"”"“—m··——¥0"*'i’f? ’‘’‘‘ i

- H
_ Case 3:03-cv-O10@CH Document 29 Filed O1/@73004 Page 2 of 3
i
A Under the ADR track, the patties have recently been engaged in negotiations in
connection with arranging mediation before retired Magistrate Judge F. Owen Eagan, which has i
now been scheduled for January 7, 2003. As directed by the mediator, the Defendant is preparing i
n
a mediation position paper to be filed no later than January 2, 2004. Further, because ofthe
complexities and magnitude of this case, the Defendant is currently preparing a technical
presentation to be given at the mediation, the goal of which is to resolve this matter short of
additional proceedings. Because ofthe time required to prepare for this mediation, and in light of I
the impact of the holiday season, the Defendant is requesting this 30-day extension in order to 1
have a reasonable opportunity to prepare its opposition brief {
This Motion for Extension of Time is the first of its kind filed by the Defendant. i
Undersigned counsel have inquired of opposing counsel, and there is consent to this Motion. ,
» a ENDANT,
PARKER HANNIF » 6 · I
B · _ _ A i.·i ‘j.;J‘# .
M k · .cru11am
CT F deral Bar No. CTl6024 -
KE *1 AND WOOLEY, LLP .
28 Trumbull Street
Hartford, CT 06103
860-246-9700
I
Robert M. Kern
CT Federal Bar No. CT25058
David C. McGovern
CT Federal Bar No. CT25059
KERN AND WOOLEY, LLP
10900 Wilshire Blvd., l1“‘ Floor
Los Angeles, CA 90024
3l0—824—l777
Attorneys for Defendant
Parker Hannifin Corporation .
Dated: December 30, 2003 I
2
1
i

a ·» l
_ I Case 3:03-cv-O10€7§JCH Document 29 Filed O1/((5*5004 Page 3 of 3 i
i CERTIFICATION OF SERVICE i
This is to certify that on December 30, 2003, a copy ofthe foregoing Motion for
Extension of Time was sent via tirst class mail to the following recipients: _
Attorneys for Plaintiffs; i
Charles W. Fortune, Esq. _ 4
David M. Bizar, Esq.
Day, Berry & Howard LLP
CityPlace I
Hartford, CT 06103
i
Mark R. `ulia i ` l
P?iStratofIex - UT ederal Pleadingsworionfor Ext. to Object to Mo!. jiar Stay. wpd |
E
E
i
i
3 i
i