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

Case 3:03-cv-00383-WIG

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT GREGORY PRENTISS, et al., Plaintiffs vs. WASLEY PRODUCTS, INC, et al., Defendants/Third Party Plaintiffs MASTER CIVIL ACTION NO. 3:03CV0383 (DJS) THIS PLEADING PERTAINS TO CIVIL NO. 3:03 CV 1790 (DJS)

vs. PROVIDENT MUTUAL LIFE INSURANCE COMPANY, et al., MARCH 29, 2004 Third Party Defendants

THIRD-PARTY DEFENDANT NATIONWIDE LIFE INSURANCE COMPANY OF AMERICA'S F/K/A PROVIDENT MUTUAL LIFE INSURANCE COMPANY CONSENTED MOTION FOR EXTENSION OF TIME TO ANSWER AND/OR OTHERWISE PLEAD

Defendant Nationwide Life Insurance Company of America f/k/a Provident Mutual Life Insurance Co. ("Nationwide"), hereby respectfully requests an extension of time of thirty (20) days to answer and/or otherwise plead in the above-captioned matter. In support of this motion, Nationwide states the following: 1. The original writ summons and verified complaint in the above captioned

proceeding were served upon Nationwide on or about March 8, 2004.

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2.

As a result, Nationwide must retrieve old and presumably archived

materials and provide its counsel with those materials when found to evidence the factual record of this dispute. 3. Counsel requires additional time to obtain any underlying materials,

review the complaint and consult with out-of-state Nationwide counsel to appropriately respond to the complaint. 4. No prior request for an extension of time of any kind has been made by

Nationwide in this proceeding. 5. Counsel for Nationwide spoke by telephone with attorney for Third-Party

Plaintiffs, Theodore J. Tucci, and he consents to an extension of time up to and including April 19, 2004. WHEREFORE, Nationwide respectfully requests that its motion for extensio n of time to answer and/or otherwise plead be granted.

DEFENDANTS NATIONWIDE LIFE INSURANCE COMPANY OF AMERICA f/k/a PROVIDENT MUTUAL LIFE INSURANCE CO. ______/s/ Bryan D. Short_____ Deborah S. Freeman [ct 05257] Bryan D. Short [ct 24374] BINGHAM MCCUTCHEN LLP One State Street Hartford, CT 06103-3178 Phone (860) 240-2700 Fax (860) 240-2818

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CERTIFICATE OF SERVICE

I hereby certify that on March 29, 2004 the original of the foregoing was served via First Class Mail on the following counsel of record:

Theodore J. Tucci Jean E. Tomoasco Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103-3597 Thomas G. Moukawasher, Esq. Ian O Smith, Esq. Moukawsher & Walsh 21 Oak Street, Suite 209 Hartford, CT 06106 Maurice FitzMaurice, Esq. Peter K. Rydel , Esq. Reid and Riege, P.C. One State Street Hartford, CT 06103 and a copy sent to the following: Mary E.R. Bartholic, Esq. Thomas W. Witherington, Esq. Cohn Birnbaum & Shea P.C. 100 Pearl Street Hartford, CT 06103 Albert Zakarian, Esq. Victoria Woodin Chavey, Esq. Eric Sussman, Esq. Day, Berry & Howard LLP CityPlace I Hartford, CT 06103 ______________________ Bryan D. Short

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