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

_ I Case 3:03-cv-00383-WIG Document 362 Filed O3/20/2007 Page 1 of 3 . I
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., ET AL., : MASTER CONSOLIDATED CASE
: CIVIL NO. 3:03 CV 383 (MRK/WIG)
e Plaintiffs, :
_ MARCH 20, 2007
BARRY BULAKITES, ET AL., :
. Defendants. _ ·
WASLEY DEFENDANTS’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO RESPOND
TO PLAINTIFFS’ FIRST AMENDED COMPLAINT `
THIS PERTAINS TO: CIVIL NO. 3:03 CV 1790 (MRKfW IG)
(Prentiss etal. v. Wasley Products, Inc. etal.) `
Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 7(b) of the Local
Rules of Civil Procedure, defendants Wasley Products, Inc., Alan Wasley, Andrew Brady, Sandi
Dumas-Laferriere and Barry Connell (the "Wasley Defendants") hereby move for an extension
of time of 30 days, to and including April 20, 2007, to respond, by either answer or motion, to
plaintiffs’ First Amended Complaint.
In support of this motion, the Wasley Defendants state that all of the parties are actively
engaged in settlement discussions before U.S. Magistrate Judge Garfinkel. The discussions are
progressing. Judge Garfinkel has suggested that an additional settlement conference would be
- S beneficial but the conference has not yet been scheduled. In addition, plaintiffs’ counsel has
indicated that he intends to amend (or move to amend) the First Amended Complaint to correct
. certain errors that appear in the current draft. For example, the current complaint includes
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Case 3:03-cv-00383-WIG Document 362 Filed O3/20/2007 Page 2 of 3
allegations pertaining to Mr. Wiblyi and the Wasley Retirement Plan that should not be included
in light of the court’s ruling on the motion to amend. It would be helpful to have the revised
complaint in place before defendants formulate a response.
g The Wasley Defendants therefore request that the deadline for responding to the First
Amended Complaint be extended 30 days, to and including April 20, 2007. The requested
extension would allow time for the plaintiffs to correct their complaint and for all parties to
engage in further settlement discussions of all of the pending claims before incurring the time l
and expense of responding to the First Amended Complaint if it remains necessary to do so.
This is the Wasley Defe11dants’ fifth motion seeking an extension of time of this deadline.
The undersigned contacted plaintiffs’ counsel, Thomas Moukawsher, who does not object to the
- requested extension. This matter has not yet been assigned for trial.
C - DEFENDANTS
WASLEY PRODUCTS, INC., ALAN A.
WASLEY, ANDREW BRADY, SANDI DUMAS-
LAFERRIERE, AND BARRY CONNELL
. By: /s/
· Theodore J. Tucci (ct05249)
[email protected] _
_ Jean E. Tomasco (ct09635)
3 [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 362 Filed O3/20/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on March 20, 2007, a copy of the foregoing Wasley Defendants’
Motion for Extension of Time was filed electronically. Notice of this filing shall be sent by E-
mail to all parties by operation ofthe Court’s electronic filing system. Parties may access this
· filing through the Cou11;’s system.
Jean E. Tomasco -