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

Case 3:03-cv-00383-WIG

Document 325

Filed 11/01/2006

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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) NOVEMBER 1, 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 to answer or otherwise plead to the Plaintiffs' First Amended Complaint up through and including thirty (30) days after the date of the next settlement conference in these consolidated matters. 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

Document 325

Filed 11/01/2006

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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. This is Nationwide's first 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 until after the date of the next settlement conference in these consolidated matters in which to respond and/or otherwise plead to the Plaintiffs' First Amended 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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Case 3:03-cv-00383-WIG

Document 325

Filed 11/01/2006

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CERTIFICATION This is to certify that a copy of the foregoing Motion for Extension of Time has been served this 1st day of November, 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/ Sara R. Simeonidis Sara R. Simeonidis 3CTDOCS/1675036.1