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

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Case 3:03-cv-00383-WIG Document 340 ‘ Filed 01/12/2007 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/VVIG)
‘ Plaintiffs, :
: THIS PERTAINS TO: _
I : CIVIL NO. 3:03 CV 1790 (MRK/WIG)
l V. : (Prentiss etal. v. Wasley Products, Inc. etal.)
BARRY BULAKITES, ET AL., JANUARY 12, 2007
I _ _ Defendants. ` U
_ WASLEY DEFENDANTS’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO RESPOND
TO PLAINTIFFS’ FIRST AMENDED COMPLAINT
[ U Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 7(b) of the Local
l I I 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 I
I I of time of 30 days, to and including February 15, 2007, to respond, by either answer or motion,
. ` . l to plaintiffs’ First Amended Complaint. p `
_ ` 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. In addition,
I _ 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 allegations pertaining to Mr. Wiblyi andthe Wasley Retirement Plan that
. should not be included in light of the court’s ruling on the motion to amend. It would be helpful
I ·__# I I _ to have the revised complaint in place before defendants formulate a response. I _
I rraarr-1376413-1 an an

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Case 3:03-cv-00383-WIG Document 340 Filed 01/12/2007 Page 2 of 3
_ The Wasley Defendants therefore request that the deadline for responding to the First ·
0 Amended Complaint be extended 30 days, to and including February 15, 2007. The requested
extension would allow time for the plaintiffs to correct their complaint and for all parties to 0
engage in further 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? third motion seeking an extension of time of this
` deadline. The undersigned contacted plaintiffs’ counsel, Thomas Moukawsher, who does not
_ obj ect to the requested extension. This matter has not yet been assigned for trial.
- . . DEFENDANTS
. · WASLEY PRODUCTS, INC., ALAN A.
_ WASLEY, ANDREW BRADY, SANDI DUMAS-
q ‘ LAFERRIERE, AND BARRY CONNELL .
_- ` l ‘ ‘ By:_..Jg. L_..._
Theodore J. Tucci (ctO5249) · -
- - - - I . ‘ _ · [email protected]
` ` - _‘ . - Jean E. Tomasco (ct09635)
‘ _ [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 340 Filed O1/12/2007 Page 3 of 3
CERTIFICATE OF SERVICE
_ I I hereby certify that on Januaiy 12, 2007, a copy ofthe foregoing Wesley Defendants’
. Motion for Extension of Time was tiled electronically. Notice of this filing shall be sent by E-
‘ mail to all parties by operation ofthe COl.11't’S electronic tiling system. Parties may access this.
filing through the Court’s system. I
. Jean E. Tomasco I