Free Status Report - District Court of Connecticut - Connecticut

Case 3:03-cv-00416-PCD Document 14 Filed 09/15/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

IvL·1RSI-LALL ASCHZE, STE‘i.*`]ELI~l B. LEVINE, )
T[t'vIOTI-IY S. REED, MARCEAL CUEVAS and )
EACK WH.LiAivI DUNLAR )
Plaintiffs, g
v. g Case No. 303C‘v'04i6 PCD
HARTFORD INSURLANCE COlvIPAI*~l"r' §
OF E.L¥NO§S, }
Defendant. §

SETTLEMENTISTATUS CONFERENCE MEMORANDUM
Rursuant to this Court’s Order, the following is Defendant Hanford Insurance
Company of Il|inois’s ("i-iaatforri"} report regarding whether another PIO conference shouid
be scheduied. For the Court’s converdence, we reference our August 2003 SettiernentfStatus
Conference Memorandum which describes the factual and coverage issues involved in this
Eitigation in mere detail, our February 25, 2004 SettEernentfStatus Conference Memorandum,
and our March 24, 2004 SettiementfStatus Conference Memorandum.
At this time it does not appear necessary for the Court to schedute another PIO
conference. This case continues to move toward resoiution. As the Court was previously
advised, the United States District Court for the Southern District of Netv York dismissed
the M'egol'er Action on September 24, 2003, all but one ofthe Threatened Stockholder
I
DC‘·5|4'F5HZl`·.1

Case 3:03-cv—00416-PCD Document 14 Filed 09/15/2004 Page 2 of 3
Actions failed to materialize,1 and the outside directors have settled the Federal and State
Regulatory Actions.
The parties are continuing to work toward settlement of this case in the interest of
achieving resolution without incurring the expense of formal discovery. The Plaintiffs
previously made a settlement proposal based on the defense costs incurred by the outside
directors to date, and are continuing to provide Hartford with support for the numbers they
are proposing. Accordingly, the parties request the Court extend the deadline for the parties
to complete depositions and tile dispositive motions by one montb to enable the parties to
amicably and eibciently resolve this matter without incurring unnecessary legal fees and
costs. If the Court is amenable to such an extension, depositions would be scheduled to be
completed by November i, 2004 and dispositive motions would have to be filed by
Becember 15, 2004.
.4
Dated: September I5, 2004 Re _: b ·. te , F
- ·•- {_.·•' '\ , V I V `
liam . Cha phn III [ct04202] / E
Of Counsel; W. Joe Wilson F
Alan 3. Joaquin TYLER COOPER & ALCORN, LLP
Alison M. Jarandeh 135 Asylum Street
DRHNEKER BBDLE & REATH CltyPiaoef35th Floor
1500 K Street HW., Ste. ll00 Hartford, CT 0ol03-3433
Washington, D.C. 20005 {360) T25-6200
{202) 342-3300 Fax [350} 223-3302
Fax: (202)-342-3465 A rrornens for Defendant
Hortfford Insirrnrrce Cornpnny offffinois
I We understand that the outside directors will move to dismiss the one shareholder action
that has been filed and do not anticipate substantial legal costs to arise from this action.
Dcomrso-.1 · 2 -

Case 3:03-cv—00416-PCD Document 14 Filed 09/15/2004 Page 3 of 3
s.
CERTHIICATE GF SERVICE
I hereby certify that a copy of the foregoing was mailed, postage prepaid, on this
15tb day of September, 2004 to the following counsel of record:
Charles A. Stewart, III
Stewart Ucehipinti & Maltow
E350 Broadwajr, Suite 2200
New York, NY 10013
Richard R Weinstein
Weinstein & Wisser, P.C.
29 S. Main St., Ste. 202
West Hartford, CT 06107 _,
Q 44 E I
T
William H. Cham lin III
oc··si4van‘-.i - 3 -