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

Case 3:03-cv-00383-WIG Document 369 Filed O4/06/2007 Page 1 of 3
I ( UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., ET AL., : MASTER CONSOLIDATED CASE
I 2 CIVIL NO. 3:03 CV 383 (MRK/WIG)
Plaintiffs, :
BARRY BULAKITES, ET AL.,
Defendants. APRIL 6, 2007
(This motion pertains to the Wiblj case, Civil No. 3:06 CV 01435 (MRK))
WASLEY DEFENI)ANTS’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO RESPOND ij
TO PLAINTIFF’S COMPLAINT
l Pursuant to Rule 6(b) ofthe Federal Rules of Civil Procedure and Rule 7(b) of the Local
l Rules of Civil Procedure, defendants Wasley Products, Inc., Alan Wasley, and Sandi Dumas-
l Laferriere (collectively, the "Wasley Defendants”) hereby move for an extension of time to May
3l, 2007, to respond, by either answer or motion, to plaintiff’ s Complaint in the matter of Wiblyi
v. Wasley Products Inc., et al, Civil No. 3:06 CV 01435 (MRK).
In support of this motion, the Wasley Defendants state that the Wiblyi case was
transferred to this court and consolidated for pretrial purposes with the above—capti0ned master
consolidated case, Wasley Products et al. v. Bulakites, et al., Civil No. 3:03 CV 383
(MRKNVIG). The three pending consolidated actions involve many ofthe same defendants and
are presently in the midst of active settlement discussions with Magistrate Judge Garfinkel. The
parties are in the process of scheduling a meeting date for the continuation of settlement
HAM:-1292.ss0-r
04;%/07 10:31 AM

Case 3:03-cv-00383-WIG Document 369 Filed O4/06/2007 Page 2 of 3
discussions. Given the proposed available dates, that meeting likely will be held during the last
week of April 2007. The requested extension to May 3 lst would allow time for the parties to
arrange the meeting and engage in further settlement discussions of all ofthe pending claims
before incurring the time and expense of responding to the Complaint.
This is the Wasley Defendants’ fifth motion seeking an extension of time of this deadline.
The undersigned contacted plaintiffs’ counsel, Thomas Moukawsher, who does not object tc the
requested extension. This matter has not yet been assigned for trial.
Ds1¤ENDANrs
WASLEY PRODUCTS, INC., ALAN A.
‘ WASLEY, and SANDI DUMASLAFERRIERE
By: /s/ Theodore J. Tucci
Theodore J. Tucci (ct05249)
Email: [email protected]
Robinson & Cole LLP
280 Trumbull Street
Hartford, CT 06103-3597
Tel. No.: (860) 275-8200
Fax: (860) 275-8299

Case 3:03-cv-00383-WIG Document 369 Filed O4/06/2007 Page 3 of 3
. CERTIFICATE OF SERVICE
I hereby certify that on April 6, 2007, a copy ofthe foregoing Wasley Defendants’
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 Court’s electronic filing system. Parties may access this
filing through the Court’s system.
/s/ Theodore J. Tucci
Theodore J. Tucci