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

Case 3:03-cv—00383-WIG Document 363 Filed 03/20/2007 Page 1 of 3
UNITED STATES DISTRICT COURT .
DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., ET AL., MASTER CONSOLIDATED CASE
CIVIL NO. 3:03 CV 383 (MRK)
Plaintiffs,
THIS PERTAIN S TO:
CIVIL NO. 3:03 CV 1790 (MRK/WIG)
V. (Prentiss, et al v. Wasley Products, et al)
BARRY BULAKITES, ET AL.,
Defendants. March 20, 2007
MOTION FOR EXTENSION OF TIME
Pursuant to Federal Rules of Civil Procedure 6 and Local Rule 7, the Defendant
Nationwide Life Insurance Company of America f/k/a/ Provident Mutual Life Insurance
Company ("Nationwide"), respectfully requests an extension of time of thirty (30) days, through
and including April 19, 2007, to respond and/or otherwise plead to Plaintiffs’ First Amended
Complaint.
In support of this motion, Nationwide states as follows:
1. On October 16, 2006, the Plaintiffs filed the First Amended Complaint.
2. Through the First Amended Complaint, the Plaintiffs assert theories of liability
directly against Nationwide for the first time. A
3. On October 23 and 24, 2006, the parties to these consolidated matters spent two
days in mediation before Magistrate Judge William Gartinkle. While these matters did not settle
during mediation, settlement discussions overseen by Magistrate Garfinkle continue to-date.
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Case 3:03-cv—00383-WIG Document 363 Filed 03/20/2007 Page 2 of 3
Additionally, Magistrate Garfinkle has informed the parties that a follow-up settlement .
conference will be held, however, a date for this conference has not yet been scheduled.
4. On February 15, 2007 Nationwide requested an extension of time in which to
respond to the Plaintiff s First Amended Complaint, which was granted by the Court. The
response date set by the Court was until March 20, 2007. .
5. This is Nati0nwide’s fifth request for an extension of time in which to respond to
the Plaintiffs’ First Amended Complaint. The undersigned contacted Plaintiffs’ counsel Tom
Moukawsher, who does not obj ect to the requested extension. This matter has not yet been
assigned for trial. A
WHEREFORE, Nationwide seeks an extension until thirty (30) days, to and including
April 19, 2007 in which to respond and/or otherwise plead to the Plaintiffs’ First Amended
Complaint.
DEFENDANT, -
NATIONWIDE LIFE INSURANCE
COMPANY OF AMERICA
By: /\;€§;(L{· gi lp
Deborah S. Freeman [ct05257]
Sara R. Simeonidis [ct25566]
BINGHAM MCCUTCHEN LLP
One State Street
Hartford, CT 06103 _
(860) 240-2700
(860) 240-2800 (fax)
[email protected] n
[email protected]
Its Attomeys l
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Case 3:03-cv—00383-WIG Document 363 Filed 03/20/2007 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing Motion for Extension of Time has been
served this 20th day of March, 2007, via operation of the court’s electronic notification system or
via first class mail, postage prepaid, to all counsel and pro se parties of record in these
consolidated actions as follows:
Theodore J. Tucci, Esq.
Jean E. Tomasco, Esq.
Robinson & Cole LLP
280 Trumbull Street
Hartford, CT 06103-3597 `
Thomas G. Moukawsher, Esq.
Ian O. Smith, Esq.
Moukawsher & Walsh
21 Oak Street, Suite 209
Hartford, CT 06106
Joseph V. Meaney, Jr. ‘
Cranmore, Fitzgerald & Meaney
49 Wethersfield Avenue
Hartford, CT 06114-1102
Steven J. Errante, Esq.
Eric P. Smith, Esq.
Nancy Fitzpatrick Myers, Esq.
Marisa A. Bellair, Esq. ‘
Lynch, Traub, Keefe & Errante, P.C.
52 Trumbull Street
P.O. Box 1612
New Haven, CT 06506-1612
James J. Reardon, Jr., Esq. V
Thomas G. Rhoback, Esq. I
LeBouef, Lamb, Greene & MacRae · J
225 Asylum Street
Hartford, CT 06103 , . 5
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Sara R. Simeonidis
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