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

Case 3:03-cv-00383-WIG

Document 353

Filed 03/06/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

WASLEY PRODUCTS, INC., ET AL., Plaintiffs,

MASTER CONSOLIDATED CASE CIVIL NO. 3:03 CV 383 (MRK) THIS PERTAINS TO: CIVIL NO. 3:06 CV 1435 (Wiblyi v. Wasley Products, Inc., et al.)

V. BARRY BULAKITES, ET AL., Defendants.

March 6, 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, up to and including April 5, 2007, to answer or otherwise plead to the Plaintiff's Complaint. In support of this motion, Nationwide states as follows: 1. This case was recently consolidated with the above-reference master consolidated

case Wasley Products, Inc., et al v. Bulakites, et al, Civil Action No. 3:03 CV 383 (MRK/WIG) (the "Wasley I and II Actions") for pretrial purposes. 2. The parties to the Wasley I and II Actions are presently engaged in settlement

discussions with Magistrate Judge Garfinkel.

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3.

Counsel for the Plaintiff John Wibyli is counsel for the Plaintiffs in the Wasley II

Action and is engaged in the above-referenced settlement talks with Magistrate Judge Garfinkel, which talks included a universal settlement of all claims, including Mr. Wibyli's claim. 4. The requested extension would allow for the parties to further engage in their

universal settlement discussions with Magistrate Judge Garfinkel, which have been progressing, before requiring Nationwide to respond to the Complaint. 5. This is Nationwide's fourth request for an extension of time in which to respond

to the Plaintiff's Complaint. The undersigned contacted Plaintiffs' counsel Tom Moukawsher who consents to this extension. This matter has not yet been assigned for trial.

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WHEREFORE, Nationwide seeks an extension of thirty (30) days, up to and including April 5, 2007 in which to respond and/or otherwise plead to the Plaintiff's Complaint. DEFENDANT, NATIONWIDE LIFE INSURANCE COMPANY OF AMERICA

By: /s/ Sara R. Simeonidis_______________ 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] [email protected] Its Attorneys

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CERTIFICATION This is to certify that a copy of the foregoing Motion for Extension of Time has been served this 6th 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 this action 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 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. Thomas G. Rhoback, Esq. LeBouef, Lamb, Greene & MacRae 225 Asylum Street Hartford, CT 06103

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Joseph V. Meaney, Jr. Cranmore, Fitzgerald & Meaney 49 Wethersfield Avenue Hartford, CT 06114-1102

/s/ Sara R. Simeonidis Sara R. Simeonidis

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