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

Case 3:03-cv-00383-WIG Document 347 Filed 02/15/2007 Page ‘I of 3
I UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT ·
o WASLEY PRODUCTS, INC., ET AL., . zi MASTER CONSOLIDATED CASE
: CIVIL NO. 3:03 CV 383 (MRK/WIG)
‘ ` _ Plaintiffs, : .
: THIS PERTAINS TO: ‘ V
_ 2 CIVIL NO. 3:03 CV 1790 (MRK/WIG) -
V. _ : tPrentiss et al. v. Wasley Products, Inc. et al.)
. BARRY BULAKITES, ET AL., -
Defendants. FEBRUARY 15, 2007
, ‘ WASLEY DEFENDANTS’ UNOPPOSED MOTION
I . _ FOR EXTENSION OF TIME TO RESPOND
_ · - TO PLAINTIFFS’ FIRST AMENDED COMPLAINT _
_ Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 7(b) of the Local
_ l - Rules of Civil Procedure, defendants Wasley Products, Inc., Alan Wasley, Andrew Brady, Sandi .
Dumas-Laferriere and Barry Connell (the "Wasley Defenda.nts") hereby move for an extension
.- l of _time of 30 days, to and including March 16, 2007, to respond, by either answer or motion, to
_. _ plaintiffs’ First Amended Complaint. ‘
I . In support of this motion, the Wasley Defendants state that all of the parties are actively ` if
l l engaged in settlement discussions before U.S. Magistrate Judge Garfinkel. The discussions are
progressing. 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.
I For example, the current complaint includes 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. ._
. = I ` Itwould be helpfitl to have the revised complaint in place before defendants formulate a in l l
in . I I HART]-1383217-l ‘ I A _ ` I _ I _ I I


Case 3:03-cv-00383-WIG Document 347 Filed 02/15/2007 Page 2 of 3
response. Further, a related case—involving Mr. Wiblyi——was recently transferred to this court
and a motion to consolidate that case with these cases for pretrial purposes is still pending.
The Wasley Defendants therefore request that the deadline for responding to the First
Amended Complaint be extended 30 days, to and including March 16, 2007. The requested
l extension would allow time for the plaintiffs to correct their complaint and for all parties to
` engage in ftuther settlement discussions of all of the pending claims before incurring the time
and expense of responding to the First Amended Complaint if it remains necessary to do so.
’ ‘ This is the Wasley Defendants’ fourth motion seeking an extension of time of this l
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.
I -
- . - DEFENDANTS
i WASLEY PRODUCTS, INC., ALAN A.
_ . WASLEY, ANDREW BRADY, SANDI DUMAS-
· LAF ERRIERE, AND BARRY CONNELL -
` . n. l3y:. /s/
_ _ ` Theodore J. Tucci (ct05249) _ .
- _ - . [email protected] . _
` . Jean E. Tomasco (ct09635) -
_ ` _ - _ [email protected] ` .
_- ` ` . . Robinson & Cole LLP
_ - ` ‘ ` . 280 Trumbull Street
· ‘ _5 · ‘ Hartford, CT 06103-3597 _ -
- - _ Tel. No.: (860) 275-8200
_ . - _ _ Fax: (860) 275-8299

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I Case 3:03-cv-00383-WIG Document 347 Filed O2/15/2007 Page 3 of 3
I CERTIFICATE OF SERVICE
‘ I hereby certify that on February 15, 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 of the Court’s electronic filing system. Parties may access this
filing through the Court’s system. l . i `
‘ . . ‘ ` Jean E. Tomasco `