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

Case 3:03-cv-00383-WIG Document 416 Filed 07/10/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., ET AL., : MASTER CONSOLIDATED CASE
: CIVIL NO. 3:03 CV 383 (MRK/WIG)
Plaintiffs, :
BARRY BULAKITES, ET AL.,
: JULY 10, 2008
Defendants. :
MOTION FOR EXTENSION OF TIME TO RESPOND
TO PLAINTIFFS’ MOTION FOR
ENFORCEMENT OF SETTLEMENT AGREEMENT
Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 7(b) of the Local
Rules of Civil Procedure, Wasley Products, Inc. and Precision Molding, Inc., individually and on
behalf of the Wasiey Products, Inc. UAW Local 376 Retirement Plan, Precision Molding Co.,
Inc. 40l(k) Profit Sharing Plan, and Wasley Products, Inc. 40l(k) Profit Sharing Plan, Alan
Wasley, Andrew Brady, Sandi Dumas-Laferriere and Barry Connell (collectively, the "Plan
Parties"), hereby move for a three-week extension of time, to and including August 8, 2008, to
respond to plaintiffs’ Motion for Immediate Enforcement of Settlement Agreement.
In support of this motion, the Plan Parties state that the motion for enforcement pertains
to issues conceming distributions nom the two 40l(k) plans as well as appointment of new
trustees. Counsel for the Plan Parties engaged in good—faith discussions with plaintiffs’ counsel,
Thomas Moukawsher, in an attempt to resolve the issues raised by the motion. By letter dated
June 3, 2008, the undersigned counsel provided Attorney Moukawsher with information and a
copy of doctunents submitted to the IRS regarding the two 401(k) plans.

Case 3:03-cv-00383-WIG Document 416 Filed 07/10/2008 Page 2 of 4
Counsel for the Plan Parties was informed by Attorney Moukawsher only recently—on
July 8, 2008~that his clients had instructed him to proceed with the motion, leaving counsel for
the Plan Parties just 10 days to respond to the motion under the current deadline. Further, one of
the attorneys for the trustees, who has been involved in the compliance issues and submissions
and whose input is necessary in preparing a response to plaintiffs’ motion, will be out of the
office all of next week, and certain of the trustees also are out of state this week. Counsel for the
Plan Parties therefore requires additional time to consult with their clients and prepare a response
to the motion.
This is the Plan Parties’ third request for an extension of this deadline. Plaintiffs’
counsel, Thomas Moukawsher, does not obj ect to a two—week extension of time. However, as
the previous extension of time was prompted by plaintiffs’ counsel’s request for additional time
to review the information provided to him by counsel for Plan Parties, and given the vacation
and travel schedules of counsel and others necessary to preparation of a response, a three—week
extension is requested. Counsel for the companies and for the plans, Joseph V. Mearrey, Jr.,
joins in this motion and has authorized the undersigned to submit the motion on his behalf
WASLEY PRODUCTS, INC., ALAN A.
WASLEY, ANDREW BRADY, SANDI DUMAS-
LAFERRIERE, AND BARRY CONNELL
By: /s/ Jean E. Tomasco
Jean E. Tomasco (ct09635)
[email protected]
Theodore J. Tucci (ct05249)
ttucci rc.com
Robinson & Cole LLP .
280 Trumbull Street
Hartford, CT 06l03—3597~
Tel. N0.: (860) 275-8200
Fax: (860) 275-8299

Case 3:03-cv-00383-WIG Document 416 Filed 07/10/2008 Page 3 of 4
And also filed on behalf of
WASLEY PRODUCTS, mc.,
PRECISION MOLDING CO., INC.,
‘ Individually and on behalf of
WASLEY PRODUCTS, INC. UAW
LOCAL 376 RETIREMENT PLAN,
PRECISION MOLDING CO., INC.,
, 401(k) PROFIT snnnme PLAN, and
WASLEY PRODUCTS, INC. 401(k)
PROFIT SHARING PLAN `
With the consent of their counsel
- Joseph V. Meaney, J r.
].11‘1€3.1'1&3Y@C1i1ll21Wf`1I`1'I1.COII1
Cranmore, Fitzgerald & Meaney . .
‘ 49 Wethersfield Ave.
Hartford, CT 06114-1102
Phone: 860-522-9100
A Fax: $60-5223379

Case 3:03-cv-00383-WIG Document 416 Filed 07/10/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on July 10, 2008, a copy ofthe foregoing Plan Parties’ Motion for
Extension of Time was filed electronically. Notice of this tiling shall be sent by E-mail to all
parties by operation of the Court’s electronic tiling system. Parties may access this filing
through the Court’s system.
l /s/ Jean E. Tomasco
Jean E. Tomasco