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

Case 3:03-cv-00383-WIG Document 98 Filed 05/20/2004 Page 1 of 4 0
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
GREGORY PRENTISS, et al., ) MASTER CONSOLIDATED CASE A
) CIVIL NO.: 3:03 CV 383 (DJS) p
Plaintiffs, )
) THIS PLEADING PERTAINS TO
v. ) CIVIL NO.: 3:03 CV 1790 (DJS)
) &
WASLEY PRODUCTS, INC., )
ET AL., ) A
Defendants. ) MAY 19, 2004 ;
DEFENDANTS’ MOTION FOR EXTENSION OF TIME
Pursuant to Federal Rule of Civil Procedure 6(b), and Local Rule of Civil
Procedure 7 (b)(2), Defendants Barry L. Bulakites, James A. Winslow, and Joshua Adams
Corporation ("Defendants") hereby move for an extension of time to answer Defendants- 0
Cross-Claimants Wasley Products, Inc., Alan A. Wasley, Andrew Brady, Sandi Dumas- r
Laferriere, and Barry Connell’s ("Cross-Claimants") crossclaims interposed on February 3
23, 2004. This is Defendants} second request for an extension of time related to these
crossclaims.
l. On or about October 16, 2003, Plaintiffs Gregory Prentiss, John Rizzi, 1
l Richard Seich, and Dorothy Brown ("Plaintiffs") commenced an action captioned ;
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· Case 3:03-cv-00383-WIG Document 98 Filed 05/20/2004 Page 2 of 4 ‘
Prentiss, et al. v. Wesley Products, Inc., et al. (3:03 CV 01790) ("the Participants}
Action"), in which Defendants were named defendants.
2. On December 19, 2003, Plaintiffs moved to consolidate the Participants
Action with the instant action, which Motion this Court granted on January 27, 2004.
3. On February 23, 2004, Cross-Claimants tiled an Answer, Affinnative
Defenses, and Cross—Claims, interposing eight crossclaims against Defendants.
4. On January 23, 2004, however, counsel for Defendants, Maurice T.
FitzMaurice, and Peter K. Rydel (hereinafter "Counsel") moved for leave to withdraw
their appearance as counsel (hereinaner "Motion").
5. Because of the pending Motion, Counsel requested an extension of time
for the Defendants to respond to the crossclaims until 30 days after the Court's Ruling on
Counsel's Motion. The Court granted said request.
6. On April 20, 2004, the Court denied Counsel's Motion to Withdraw.
Thus, the deadline for respond to the crossclaims is Thursday, May 20, 2004.
7. Due to the complexity of the issues presented in this case, and the claims
raised by the Cross—Claimants in particular, Defendants need additional time to respond
to the Crossclaims.
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‘ Case 3:03-cv-00383-WIG Document 98 Filed 05/20/2004 Page 3 of 4 ‘
8. Accordingly, Defendants respectfully request a one—week extension, from
May 20, 2004, until May 27, 2004, to respond to the Crossclaims.
9. Pursuant to Local Rule of Civil Procedure 7(b)(2), Defendants have
inquired of opposing counsel Attomey Theodore J. Tucci and he consents to the lp
extension of time requested herein.
WHEREFORE, Defendants respectfully request that Defendants' Motion for Extension .
of Time be granted. .
DEFENDANTS
BARRY LEONARD BULAKITES, i
JAMES ALBERT WINSLOW &
JOSHUA ADAMS CORPORATION
/2g Qc
By fi
Peter K. Rydel i
Fed. #ot24793 j
ETD AND RIEGE, P.C. r
One Financial Plaza, 21st Flr.
Hartford, CT 06103 I
Tel. 860-278-1150
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Case 3:03-cv-003.83-WIG Document 98 Filed 05/20/2004 Page 4 of 4 I A
CERTIFICATE OF SERVICE
I certify that on this 19th day of May, 2004, a copy of the foregoing Motion for i
Extension of Time was sent via first-class mail to the following: S
Mary E.R. Bartholic, Esq. Bryan D. Short, Esq.
Cohn Birnbaum & Shea, P.C. Deborah S. Freeman, Esq. E
100 Pearl Street Bingham McCutchen
Hartford, CT 06103 One State Street
Hartford, CT 06103
Eric L. Sussman, Esq. Theodore J. Tucci, Esq.
Day, Berry & Howard, LLP Robinson & Cole P
CityPlace I 280 Trumbull Street S
185 Asylum Street Hartford, CT 06l03·3 597 i
Hartford, CT 06103
Thomas G. Moukasher, Esq. q
Moukasher & Walsh, LLC i
Capitol Place E
21 Oak Street 0
Hartford, CT 06106 5% .
` rarer K. Ryd ?
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