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

Case 3:03-cv-00383-WIG

Document 334

Filed 12/15/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

WASLEY PRODUCTS, INC., ET AL., Plaintiffs, V. BARRY BULAKITES, ET AL., Defendants.

MASTER CONSOLIDATED CASE CIVIL NO. 3:03 CV 383 (MRK) THIS PERTAINS TO: CIVIL NO. 3:03 CV 1790 (MRK/WIG) (Prentiss, et al v. Wasley Products, et al) DECEMBER 15, 2006

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 January 15, 2007, to respond and/or otherwise plead to Plaintiffs' First Amended Complaint. In support of this motion, Nationwide states as follows: 1. 2. On October 16, 2006, the Plaintiffs filed the First Amended Complaint. Through the First Amended Complaint, the Plaintiffs assert theories of liability

directly against Nationwide for the first time. 3. On October 23 and 24, 2006, the parties to these consolidated matters spent two

days in mediation before Magistrate Judge William Garfinkle. 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

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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 November 1, 2006 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 December 15, 2006. 5. This is Nationwide's second 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 object to the requested extension. This matter has not yet been assigned for trial. WHEREFORE, Nationwide seeks an extension until thirty (30) days, to and including January 15, 2007 in which to respond and/or otherwise plead to the Plaintiffs' First Amended Complaint. DEFENDANT, NATIONWIDE LIFE INSURANCE COMPANY OF AMERICA By: /s/ Deborah S. Freeman 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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Case 3:03-cv-00383-WIG

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CERTIFICATION This is to certify that a copy of the foregoing Motion for Extension of Time has been served this 15th day of December, 2006, 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. Thomas G. Rhoback, Esq. LeBouef, Lamb, Greene & MacRae 225 Asylum Street Hartford, CT 06103 /s/ Deborah S. Freeman Deborah S. Freeman 3CTDOCS/1679100.1