UNITED STATES DISTRECT COURT
DISTRICT OF CONNECTICUT
CLARENCE R. COLLINS, JR., et : CIVIL ACTION NO. 3103—CV—9—
ef a ciass of sirnitarly situated :
property owners, 2
Plaintiffs,
v. 2
OLIN CORPORATION and the
TOWN OF I-IAMDEN, ;
Defendants. MARCH 22, 2006
MOTEON FOR EXTENSION OF TtlV§E
Pursuant te D. Conn. L. Civ. R. 7(b), the defendant, Town of Hamden
("|—|amden"), hereby mcves for an extensien ef time, up tc and including one week after
the Status Conference presently scheduled fer April ti, 2006, to file its Answer to
plaintiffs Amended Complaint dated May 28, 2003.
As the Court is aware, this matter was crlginalty brought in Connecticut state
court with a return date of June 3, 2003. Hamden remeved this action to federal court,
and thereafter filed a Metion te Dlsmiss, dated August t, 2003, and a Motion fer Partial
Summary Judgment, dated December I5, 2004.
By Order dated February 28, 2006, the Court granted I—lamden‘s Motiens to
Dlsmiss and Motion for Partial Summary Judgment, and thereby summarity disposed of
Counts Two, Four, Six, Eight, Tera, Twetve, and Fifteen as against Hamden. As a
consequence, the only Count remaining against Hamden is Ccunt 17, which seeks
recovery of respcnse costs under CERCLA § 107.
Om G°°‘1"’*" S°I““'° §‘I10nc(860)522—6l03
Case 3:03-cv-00945-CFD Document 169 Filed O3/23/2006 Page 2 of 4
Based upon the evidence adduced to date, Hamden anticipates seeking
summary disposition of this Count in the future. ln the interim, however, because this
Count remains, the Town is obliged to fiie an Answer and Affirmative Defenses. In
addition, all claims against co-defendant Olin Corporation remain pending,
This Court has scheduled a Telephone Status Conference in this matter, which
has been rescheduled for April T11, 2006 at 4 FEM. Because the status of the case
against Hamden may be one of the subjects of that conference, Hamden submits that it
should not be required to fiie an Answer untii after the conference is held. That way, the
parties' resources will not be unnecessarily used until it is clear they will be needed.
Hamden therefore requests that its time to file an Answer be extended until one week
after the conference is held,
Counsel for Hamden has contacted counsei for the Plaintiffs and for Olin
Corporation, Both have consented to this ll/lotion,
This is the first Motion for an Extension of Time that has been filed with respect
to an Answer to Count 17, but the Third Motion for an Extension of Time to Plead that
has been filed,
Wherefore, Hamden respectfully requests that the Court grant this Motion, and
extent its time to Answer the remaining Count of the Amended Complaint until one week
after the Status Conference is held.
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Case 3:03-cv-00945-CFD Document 169 Filed O3/23/2006 Page 3 of 4
THE DEFENDANT,
TOWN OF HAMDE-EN
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By-MQ ‘ /
.§,o·$e;i>h G. réwer, Jr.
»“HALLORAN & SAGE LLP
Aylzederat Bar #c:t04602
One Goodwin Square
225 Asylum Street
Hartford, CT 06103
(860) 522-6103
its Attorneys
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Case 3:03-cv-00945-CFD Document 169 Filed O3/23/2006 Page 4 of 4
CERTIFICATE OF SERVICE
This is to certify that on this 22“d of March, 2006, l hereby mailed a copy ofthe
foregoing to:
Counsel for Plaintiffs Counset for Otin Corgoration
Monte E. Frank, Esq. Michael |—i. Wetmore, Esq.
Cohen and Wolf, P.C, Joei B. Samson, Esq.
158 Deer Hili Avenue Husch & Eppenberger, LLC
Danbury, CT 06810 190 Carondeiet Plaza, Suite 600
St. Louis, MO 63105
Mark Roberts, Esq. Sandra K. Davis, Esq,
Andrew Rainer, Esq. Mark S. Baldwin, Esq,
McRoberts, Roberts & Rainer, LLP Brown Rudnick Berlack israels LLP
101 Merrlrnao Street 185 Asylum Street, 38“" Floor
Boston, MA 02114 Hartford, CT 061036402
Neil `i'.. Leifer, Esq.
Michael A. Lesser, Esq.
Brad J, Mitcheil, Esq.
David C. Strouss, Esq.
Thornton 8 Naumes, LLP
100 Summer Street, 30m Floor
Boston, MA 02110
or
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