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

Case 3:03-cv-00383-WIG Document 324 Filed 10/30/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
j WASLEY PRODUCTS, INC., ET AL., : MASTER CONSOLIDATED CASE
2 CIVIL NO. 3:03 CV 383 (MRK/WIG)
- Plaintiffs, :
: THIS PERTAINS TO:
r : CIVIL NO. 3:03 CV 1790 (MRK/WIG)
V. : (Prentiss et al. v. Wasley Products, Inc. et al.)
BARRY BULAKITES, ET AL., .
. .- ..... - .. ..... . ..... .D¢f¢rtdants... . . . .... OCTOBER. 3.0,.2096. .. - - . . . . . - . - - .... .
‘ WASLEY DEFENDANTS’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO RESPOND
TO PLAINTIFFS’ FIRST AMENDED COMPLAINT
Pursuant to Rule 6(b) ofthe Federal Rules of Civil Procedure and Rule 7(b) ofthe Local
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
of time to respond, by either answer or objection, to plaintiffs’ First Amended Complaint. The
Wasley Defendants request that their response be due 30 days after the date set for the next
settlement conference.
In support of this motion, the Wasley Defendants state that the First Amended Complaint
was tiled on October 16, 2006, just two weeks ago. On October 23 and 24th, 2006, all ofthe
parties to the consolidated cases participated in a settlement conference before U.S. Magistrate
Judge Garfinkel. The parties were not able to resolve the c_ases but discussions are ongoing.
Magistrate Judge Garfinkel has stated that a follow-up conference will be held; however, a date
for this conference has not yet been scheduled. The Wasley Defendants therefore request that
ORAL ARGUMENT NOT REQUESTED
HARr1-136z362-1 ‘

Case 3:03-cv-00383-WIG Document 324 Filed 10/30/2006 Page 2 of 3 I
‘ the deadline for responding to the First Amended Complaint be extended to 30 days after the
date set for the settlement conference in order to allow adequate time after the conference for the
Wasley Defendants to prepare a response to the First Amended Complaint if it remains necessary
to do so. . l i
This is the Wasley Defendants’ first 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.
q - WASLEY PRODUCTS, INC., ALAN A.
- WASLEY, ANDREW BRADY, SANDI DUMAS—
. · LAFERRIERE, AND BARRY CONNELL
- By: /s/ i
_ . Theodore J. Tucci (ct05249)
[email protected] lf
· 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 324 Filed 10/30/2006 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on October 30, 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-
mail to all parties by operation of the Court’s electronic tiling system. Parties may access this
tiling through the Court’s system. _
Jean E. Tomasco