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

Case 3:03-cv—00383-WIG Document 237 Filed 10/17/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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WASLEY PRODUCTS, INC., ET AL., 1
: MASTER CONSOLIDATED CASE CIVIL
Plaintifi : NO. 3:03 CV 383 (MRK)
v. THIS PERTAINS TO:
: 3:03 CV l790 (MRK)
BARRY BULAKITES, ET AL., : Prentiss, et al. v. Wasley Products, Inc., et al.
Denennenn Z october 17, 2005
................................. Qi
LINCOLN NATIONAL LIFE INSURANCE COMPANY'S MOTION FOR AN
EXTENSION OF TIME TO FILE ITS OPPOSITION TO PLAINTIFFS'
MOTION FOR PERMISSION TO JOIN ADDITIONAL PARTIES
AND TO AMEND THEIR COMPLAINT
Pursuant to Local Rule 7(b), Defendant Lincoln National Life Insurance Company
("Lincoln National"), by and through its undersigned counsel, hereby moves for a thirty (30) day
extension of time, up to and including November 18, 2005, to file its Opposition to the Motion
for Permission to Join Additional Parties and to Amend Complaint ("Motion to Amend"), filed
by Plaintiffs Wasley Products, Inc., Wasley Products UAW Local 376 Retirement Plan,
Precision Molding 40l(k) Plan, Wasley Products 40l(k) Plan and Precision Molding Company,
Inc. (together, the "Plaintiffs"). Counsel for the Plaintiffs has consented to this Motion for
Extension of Time.
Plaintiffs 'proposed Amended Complaint seeks, for the first time, to add Lincoln
National as a defendant, and puts forth factual allegations and legal theories not contained within
its Original Complaint. Specifically, the Plaintiffs seek to hold Lincoln National liable for the
alleged misdeeds of persons who have not been associated with Lincoln National in many years.

Case 3:03-cv—00383-WIG Document 237 Filed 10/17/2005 Page 2 of 2
Plaintiffs proposed Amended Complaint also seeks to join several new plaintiffs, and assert new
factual allegations and legal theories. Lincoln National needs the additional time to investigate
the Plaintiffs' factual allegations, to determine how the Plaintiffs new allegations factually and
legally relate to Lincoln National, and to determine whether or not to obj ect to certain parts of
the Plan Participants multi—part Motion to Amend.
This is Lincoln National's first request for an extension of time on this deadline. This
matter has not yet been assigned for trial.
Dgtgd; Hartford, CT LeBOEUF, LAMB, GREENE & MacRAE, L.L.P.
October 17, 2005
By: /s/ Thomas G. Rohback
Thomas G. Rohback
James J. Reardon, Jr.
Doug Dubitsky
LEBOEUF, LAMB, GREENE & MacRAE, L.L.P.
225 Asylum Street
Hartford, CT 06103
(860) 293-3500
(860) 293-3730 (fax)
Counsel for Defendant
Lincoln National Life Insurance Company
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