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

Case 3:03-cv-00383-WIG

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WASLEY PRODUCTS, INC., ET AL., Plaintiffs, THIS PERTAINS TO BOTH CASES: CIVIL NO. 3:03 CV 383 (MRK) (Wasley Products, Inc., et al. v. Barry L. Bulakites, et al.) CIVIL NO. 3:03 CV 1790 (MRK) (Prentiss et at. v. Wasley Products, Inc. et al.) MASTER CONSOLIDATED CASE CIVIL NO. 3:03 CV 383 (MRK)

v.

BARRY BULAKITES, ET AL., Defendants.

JUNE 30, 2006

PRENTISS PLAINTIFFS' MOTION TO EXTEND CASE MANAGEMENT DEADLINES Plaintiffs, Gregory Prentiss, John Rizzi, Richard Seich and Dorothy Brown ("Prentiss Plaintiffs"), move to extend all case management deadlines by ninety (90) days. Plaintiffs request this extension for the following reasons: 1. July 1, 2005. 2. The parties have argued the pending motions summarized in their Joint Interim The case deadlines were set by the Court in a ruling and scheduling order dated

Status Report dated January 16, 2006, namely: Prentiss Plaintiffs' Motion to Amend the Complaint in Wasley II; The Wasley Plaintiffs' Motion to Join Parties and Amend the Complaint in Wasley I, and Prentiss Participants' Motion to Appoint a Special Master (Both Cases). 3. The parties, by agreement, have postponed the completion of discovery,

summarized in the January 16, 2006 status report, awaiting the outcome of the pending motions. 4. On March 31, 2006 the Court ruled on the above motions denying the Prentiss

Plaintiffs' Motion to Amend to add John Wiblyi as a plaintiff and to add Count III relating to

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Wiblyi's claims, denying their Motion for Joinder of Nationwide and Lincoln as defendants without prejudice to their filing a second proposed amended complaint consistent with the ruling, granting their motion to add Count II relating to the Defined Benefit Plan, granting the Prentiss Plaintiffs' motion for certification of this action as a derivative action under Rule 23.1 and denying their Motion to Appoint a second Special Master without prejudice to renewal at a later date. Prentiss Plaintiffs are currently drafting their amended complaint in accordance with the requirements of the ruling. For all of the reasons stated above, Prentiss Plaintiffs propose the following extensions set forth below: a. The current deadline for completion of discovery is June 30, 2006. The modified

deadline will be September 28, 2006. b. The current deadline for a joint status report is June 30, 2006. The modified

deadline will be September 28, 2006. c. The current deadline for a status conference is July 10, 2006. The modified

deadline will be October 8, 2006. d. The current dispositive motion deadline is August 1, 2006. The modified deadline

will be October 30, 2006. e. The current trial memorandum date is September 1, 2006. The modified deadline

will be November 30, 2006. f. The current trial ready date is September 6, 2006. The modified deadline will be

December 5, 2006. This is Prentiss Plaintiffs' first request for an extension of these deadlines. Counsel for Wasley Products, Inc., Precision Molding Company, Wasley Products, Inc., Alan Wasley,

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Andrew Brady, Sandi Dumas-LaFerriere, Barry Connell, Barry Bulakites, James Winslow and Joshua Adams Consulting, Inc., and Nationwide Life Insurance Company of America f/k/a Provident Mutual Life Insurance Company has indicated that they do not oppose Prentiss Plaintiffs' request. Prentiss Plaintiffs were unable to reach counsel for Lincoln National Life Insurance Company for their position. WHEREFORE, Prentiss Plaintiffs respectfully request that the Court grant their motion to extend the above deadlines by 90 days.

THE PLAINTIFFS:

By/s/ Thomas G. Moukawsher Thomas G. Moukawsher (ct08940) Ian O. Smith (ct24135) Moukawsher & Walsh, LLC 21 Oak Street, Suite 209 Hartford, CT 06106 Tel: (860) 278-7000 Fax: (860) 548-1740 [email protected] [email protected] ATTORNEYS FOR PLAINTIFFS

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CERTIFICATE OF SERVICE I hereby certify that on June 30, 2006, a copy of foregoing PRENTISS PLAINTIFFS' MOTION TO EXTEND CASE MANAGEMENT DEADLINES was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. Theodore J. Tucci Jean Elizabeth Tomasco, Robinson & Cole 280 Trumbull Street Hartford, CT 06103 Joseph V. Meaney, Jr. Cranmore, Fitzgerald & Meaney 49 Wethersfield Ave. Hartford, CT. 06114 Marissa A. Bellair Steven Errante Eric P. Smith Nancy Fitzpatrick Myers Lynch, Traub, Keefe, and Errante, LLP 52 Trumbull Street P.O. Box 1612 New Haven, CT. 06506

Sara Simeonidis Deborah S. Freeman, Bryan D. Short Bringham McCutchen 1 State Street Hartford, CT 06103 Maurice T. Fitzmaurice Reid & Riege, P.C. One Financial Plaza 755 Main Street, 21st Floor Hartford, CT 06103-3185 James J. Reardon, Jr. Thomas G. Rohback LeBoeuf, Lamb, Greene & MacRae 225 Asylum St. Hartford, CT 06103

Dated this 30th day of June, 2006. /s/ Thomas G. Moukawsher Thomas G. Moukawsher ct08940 Ian O. Smith ct24135 Moukawsher & Walsh, LLC 21 Oak Street Hartford, CT 06106 (860) 278-7000 [email protected]

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