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

Case 3:03-cv-00945-CFD

Document 234

Filed 04/01/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CLARENCE R. COLLINS, JR., et al VS. OLIN CORPORATION Defendant. Plaintiffs, : : : : : : : 3:03-CV-945 (CFD)

APRIL 1, 2008

MOTION ON CONSENT FOR EXTENSION OF TIME Plaintiffs hereby move for a thirty (30) day extension of time to May 12, 2008 within which to file their Opposition to Defendant Olin Corporation's Partial Motion for Summary Judgment Based on Statute of Limitations. In support of this request, Plaintiffs state as follows: 1. Certain of Plaintiffs' counsel have been tied up in the attempted mediation of a case in the U.S. District Court, District of Rhode Island, involving over 120 plaintiffs. The case did not settle and jury empanelment is scheduled for April 23, 2008, with trial starting thereafter. 2. Completion of the brief has required not only review of substantial case law cited by the Defendant but of dozens of deposition transcripts. 3. The extension requested will not require adjustment of any other deadlines in the Court's scheduling order. 4. The Defendant has assented to this thirty (30) day extension.

Case 3:03-cv-00945-CFD

Document 234

Filed 04/01/2008

Page 2 of 3

WHEREFORE, the Plaintiffs respectfully request that the Court grant a thirty day extension to May 12, 2008 within which to file their Opposition.

Respectfully submitted, By__/s/ Monte E. Frank____________ Monte E. Frank, Esq. ct13666 [email protected] David B. Zabel, Esq. ct01382 [email protected] Cohen and Wolf, PC 1115 Broad Street Bridgeport, Connecticut 06604 Tele: (203) 368-0211 Fax: (203) 394-9901 Mark Roberts, Esq. ct25062 [email protected] McRoberts, Roberts & Rainer LLP 53 State Street Boston, Massachusetts 02109 Tele: (617) 722-8222 Fax: (617) 720-2320 Neil T. Leifer, Esq. [email protected] David C. Strouss, Esq. [email protected] Thornton & Naumes L.L.P 100 Summer Street, 30th Floor Boston, Massachusetts 02110 Tele: (617) 720-1333 Fax: (617) 720-2445 Dated: April 1, 2008

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Case 3:03-cv-00945-CFD

Document 234

Filed 04/01/2008

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on April 1, 2008, a copy of foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. __/s/ Monte E. Frank____________

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