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

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. Case 3:03-cv-00383-WIG Document 332 Filed 12/13/2006 Page 1 of 3 -
I UNITED STATES DISTRICT COURT
` ` - DISTRICT OF CONNECTICUT .
WASLEY PRODUCTS, INC., ET AL., :I MASTER CONSOLIDATED CASE
: CIVIL NO. 3:03 CV 383 (MRK/WIG)
Plaintiffs, : -
: THIS PERTAINS TO: ·
. : CIVIL NO. 3:03 CV 1790 G)
V. _ I : (Prentiss etal. v. Wasley Products, Inc. et al.)
BARRY BULAKITES, ET AL., I
- : DECEMBER 13, 2006 _
‘ P- Defendants. : ` .
‘ WASLEY DEFENDANTS’ UNOPPOSED MOTION
` 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
· I Rules of Civil Procedure, defendants Wasley Products, Inc., Alan Wasley, Andrew Brady, Sandi
_ I I Dumas—Laferriere and Barry Connell (the "Wasley Defendants") hereby move for an extension
_ I - of time of 30 days, to and including January 15, 2007, to respond, by either answer or motion, to
` I plaintit`fs’ First Amended Complaint. .
- _ In support of this motion, the Wasley Defendants state that, on October 23 and 24th, 2006,
` . · I all of the parties to the consolidated cases participated in a settlement conference before U.S.
Magistrate Judge Gartinkel. The parties were not able to resolve the cases but additional
_ I- information was provided to the court in November and, with the assistance of the court, _ I
` ‘ settlement discussions are ongoing. I
‘ _ · · In addition, plaintiffs’ counsel indicated that he intends to amend (or move to amend) the _
I · First Amended Complaint to correct certain errors that appear in the current draft. For example, -
_I- -0RAL ARGUMENT OT REQUESTED _ · I I I A _
·_ I I ` Hlmri-1362362-1 _ . I - ‘ · _

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Case 3:03-cv-00383-WIG Document 332 Filed 12/13/2006 Page 2 of 3
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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. It would
be helpful to have the revised complaint in place before defendants formulate a response. · . .
p · The Wasley Defendants therefore request that the deadline for responding to the First
Amended Complaint be extended 30 days, to and including January 15, 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
_ and expense of responding to the First Amended Complaint if it remains necessary to do so.
. This is the Wasley Defendants’ second motion seeking an extension of time of this ._
- Q deadline. The undersigned contacted plaintiffs’ counsel, Thomas Moukawsher, who does not
I an I obj ect to the requested extension. This matter has not yet been assigned for trial. _
‘ I . · - DEFENDANT S
- WASLEY PRODUCTS, INC., ALAN A. . _
- _ I · · ‘ · ‘ ‘ WASLEY, ANDREW BRADY, SANDI DUMAS-
· · LAFERRIERE, AND BARRY CONNELL
U U _ ‘ U - - By: /s/
_ _ ` Theodore J. Tucci (ctO5249)
= ‘ ‘ _ ‘ . [email protected] ·
_ - . Jean E. Tomasco (ct09635)
_- _ [email protected]
. _ _ Robinson & Cole LLP
- ` ` 280 Trumbull Street
I _ - _ Hartford, CT 06103-3597
_ _ _ Tel. No.: (860) 275-8200 ‘
I ‘ A Fax: (860) 275-8299 _ . .

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Case 3:03-cv-00383-WIG Document 332 Filed 12/13/2006 Page 3 of 3
CERTIFICATE OF SERVICE U-
I hereby certify that on December 13, 2006, a copy of the foregoing Wasley Defendants’
Motion for Extension of Time was tiled electronically. Notice of this tiling shall be sent by E- ‘
p _ mailto all parties by operation ofthe Courtis electronic filing system. Parties may access this
filing through the Court’s system. _ p
‘ . ` I ‘ ‘ Jean E. T omasco I - - _