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

i Case 3:03-cve00383—WIG Document 412 Filed 05/27/2008 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.,
Defendants. MAY 27, 2008
UNOPPOSED MOTION
FOR EXTENSION OF TIME TO RESPOND
TO PLAIN TIFFS’ 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 Wasley Products, Inc. UAW Local 376 Retirement Plan, Precision Molding Co.,
Inc. 40l(k) Profit Sharing Plan, and Wasley Products, Inc. 40I(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 June 18, 2008, to
respond to plaintiffs’ Motion for Irmnediate Enforcement of Settlement Agreement.
In support of this motion, the Plan Parties state that the motion for enforcement pertains
to issues concerning distributions from the two 40I(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. The discussions
have included a telephone conference with an independent service provider to the plans who,
HARTI-1470139-l

Case 3:03-cv-00383-WIG Document 412 Filed 05/27/2008 Page 2 of 4
with the knowledge of the Department of Labor, has been working to bring the 40l(k) plans into
compliance to facilitate distributions. Discussions are still ongoing. 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 Parties’ first motion seeking an extension of time of this deadline.
Plaintiffs’ 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 undersigned to submit the motion on his behalf
DEFENDANTS
WASLEY PRODUCTS, INC., ALAN A.
WASLEY, ANDREW BRADY, SANDI DUMAS—
LAFERRIERE, AND BARRY CONNELL
By: /s/ Jean E. Tomasco
Jean E. Tomasco (ct0963 5)
j [email protected] EQ
Theodore J. Tucci (ct05249)
l``‘
Robinson & Cole LLP
· 280 Trumbull Street
Hartford, CT 06103-3597
Tel. No.: (860) 275-8200
Fax: (860) 275-8299

Case 3:03-cv-00383 And also tiled on behalf of
WASLEY PRODUCTS, INC.,
PRECISION MOLDING CO., INC.,
Individually and on behalf of
WASLEY 1=·RoDUcTs, INC. UAW
LOCAL 376 RETIREMENT PLAN,
PRECISION MOLDING CO., INC.,
401(k) PROFIT SHAIHNG PLAN, and
WASLEY PRODUCTS, INC. 401(I;)
PROFIT SHARING PLAN
With the consent of their counsel
Joseph V. Meaney, Jr.
]'1’I1€3I1€l@C{l1‘Il3WfIIH1.COHl
Cranmore, Fitzgerald & Meaney
49 Wethersfield Ave.
Hanford, CT 06114-1102
Phone: 860—522-9100
Fax: 860-522-3379 I

Case 3:03-cv-00383-WIG Document 412 Filed 05/27/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on May 27, 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-mail to all
parties by operation of the C0urt’s electronic filing system. Parties may access this tiling
through the Court’s system.
. . /s/ Jean E. Tomasco
“ Jean E. Tomasco