Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-OO3$3—\/\/IG Document 229 Filed 10/04/-2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., ET AL., MASTER CONSOLIDATED CASE
CIVIL NO. 3:03 CV 383 (MRK)
Plaintiffs,
THIS PERTAINS TO:
CIVIL NO. 3:03 CV 1790 (MRK)
V. CPrentiss et al. v. Wasley Products, Inc. et al.)
BARRY BULAKITES, ET AL.,
Defendants. OCTOBER 3, 2005
WASLEY DEFENDANTS’ MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFFS’ MOTION TO AMEND THEIR
COMPLAINT AND SEEK DERIVATIVE STATUS UNDER RULE 23.1
Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 7(b) of the Local
Rules of Civil Procedure, defendants Wasley Products, Inc., Alan Wasley, Andrew Brady, Sandi
Dumas—Lafer1iere and Barry Connell (the "Wasley Defendants") hereby move for a brief
extension of time of ll days, up to and including October 21, 2005, to respond to the Prentiss
Pla.intiffs’ Sept. 16th Motion to Amend their Complaint and Motion for Certification of
Derivative Status under Rule 23.1.
In support of this motion, the undersigned states that the Wasley Defendants do not
obj ect to the Plaintiffs’ request to amend their complaint to add Nationwide Life Insurance Co.
f7k/a Provident Mutual Life Insurance Co., and Lincoln National Life Ins. Co. as defendants in
their action. However, Plaintiffs also seek to add claims pertaining to the accrued balance
calculations in establishing opening balances for the Wasley 401(k) Plan. They also seek to add
a new plaintifi John Wiblyi, whose claims date back to the late 1980s. His claims do not pertain

Case 3:03-cv-OO383—»l/\/IG Document 229 Filed 10/04/2005 Page 2 of 3
to the Wasley 40l(k) Plan but pertain to the predecessor plan, a11d his claims appear to be unique
from those of the other plaintiffs. The Wasley Defendants require additional time to locate and
review infomation concerning these claims and to determine whether or not to obj ect to these
portions of Plaintiffs’ requested amendment and to Plaintiffs’ motion for certification of
derivative status.
This is the Wasley Defendants’ first motion seeking an extension of time of this deadline.
Counsel for the plaintiffs does not obj ect to the requested extension. This matter has not yet
been assigned for trial.
DEFENDANTS
WASLEY PRODUCTS, INC., ALAN A.
WASLEY, ANDREW BRADY, SANDI DUMAS-
LAFERRIERE, AND BARRY CONNELL
Theodore J. Tu- (ct05249)
[email protected]
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-00333-\{\/IG Document 229 Filed 10/Q4/2005 Page 3 of 3
CERTIFICATION
This is to certify that a copy ofthe foregoing was mailed, first class postage prepaid on
this 3rd day of October, 2005 to the following:
Steven J. Errante, Esq.
Nancy A. Fitzpatrick Myers, Esq.
Marisa A. Bellair, Esq.
Lynch, Traub, Keefe and Errante, P.C.
52 Trumbull Street
P. O. Box 1612
New Haven, CT 06506
Sara R. Simeonidis, Esq.
Deborah S. Freeman, Esq.
Bryan D. Short, Esq.
Bingham McCutchen
One State Street
Hartford, CT 06103-3178
Thomas G. Rohback, Esq.
Doug Dubistsky, Esq.
James J. Reardon, Jr., Esq.
LeBoeuf, Lamb, Greene & MacRae, LLP
225 Asylum Street
Hartford, CT 06103
Thomas G. Moukawsher, Esq.
Ian O. Smith, Esq.
Moukawsher & Walsh
21 Oak Street, Suite 209
Hartford, CT 06106
_ Joseph V. Meaney, Jr., Esq.
Cranmore, Fitzgerald & Meaney
49 Wethersfield Ave.
Hartford, CT 06114-1102
Theodore J. Tucc' q
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