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

Case 3:03-cv-00383-WIG Document 414 Filed 06/17/2008 Page 1 of 4
I UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT .
WASLEY PRODUCTS, INC., ET AL., : MASTER CONSOLIDATED CASE
: CIVIL NO. 3:03 CV 383 (MRK/VVIG)
Plaintiffs, :
BARRY BULAKITES, ET AL.,
: JUNE 17, 2008
Defendants. :
UNOPPOSEI) MOTION
L 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, I11c. and Precision Molding, Inc., individually and on
behalf of the Wasley Products, Inc. UAW Local 376 Retirement Plan, Precision Molding Co.,
y Inc. 40l(k) Profit Sharing Plan, and Wasley Products, Inc. 40l(k) Profit Sharing Plan, Alan
Wasley, Andrew Brady, Sandi Dumas-Laferriere and Bany Connell (collectively, the "Plan
Parties"), hereby move for a 30-day extension of time, to and including July 18, 2008, to respond
to plaintiffs’ Motion for Immediate Enforcement of Settlement Agreement.
l In support of this motion, the Plan Parties state that the motion for enforcement pertains
to issues concerning distributions from the two. 40l(k) plans as well as appointment of new
trustees. Counsel for the Plan Parties have engaged in discussions with plaintiffs’ counsel,
Thomas Moukawsher, in an attempt to resolve the issues raised by the motion and recently h
provided Attorney Moukawsher with a copy of documents submitted to the IRS regarding the
Haart-1472272-1

Case 3:03-cv-00383-WIG Document 414 Filed 06/17/2008 Page 2 of 4
two 401 (lc) plans. Attorney Moukawsher has indicated that he requires additional time to review
the documents provided and then discuss them with counsel for the Plan Parties. The requested
extension of time will permit the parties to continue their discussions and, hopefully, resolve
most if not all of the issues presented in plaintiffs’ motion without the need for the court’s
involvement.
This is the Plan Pa.rties’ second request for an extension of this deadline. Pla.intiffs’
counsel, Thomas Moukawsher, has no objection to the requested extension. Counsel for the
- companies and for the plans, Joseph V. Meaney, Jr., joins in this motion and has authorized the
tmdersigned 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)
[email protected]
Robinson & Cole LLP
280 Tmmbull Street .
Hartford, CT 06103-3597
Tel. No.: (860) 275-8200
- Fax: (860) 275-8299

Case 3:03-cv-00383-WIG Document 414 Filed 06/17/2008 Page 3 of 4
A11d also filed on behalf of
WASLEY PRODUCTS, INC.,
PRECISION MOLDING CO., INC.,
Individually and on behalf of
I WASLEY Pnonucrs, mc. UAW
LOCAL 376 RETIREMENT PLAN,
PRsc1s1oN Moromo co., mc.,
401(1<) PROFIT SHARING PLAN, and
WASLEY PRODUCTS, INC. 40l(k)
- PROFIT SHARING PLAN
With the consent of their counsel
Joseph V. Meaney, Jr.
jmeaneyg§),clinlawiirm.com
Cranmore, Fitzgerald & Meaney
49 Wethersfield Ave.
Hartford, CT 06114-1102
Phone: 860-522-9100
Fax: 860—522—3379

Case 3:03-cv-00383-WIG Document 414 Filed 06/17/2008 Page 4 of 4
I hereby certify that on June 17, 2008, a copy of the foregoing Plan Parties’ Motion for
Extension of Time was tiled electronically. Notice of this filing shall be sent by E—ma;il to all
parties by operation ofthe Counfs electronic tiling system. Parties may access this filing
through the Court’s system.
‘ /s/ Jean E. Tornasco n
Jean E. Tomasco