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

Case 3:03-cv—OO383eW|G Document 215 Filed O9/15[ZOO5 Page 1 of 3
U UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., AL., MASTER CONSOLIDATED CASE
CIVIL NO. 3:03 CV 383 (MRK)
Plaintiffs,
THIS PERTAINS TO:
CIVIL NO. 3:03 CV 1790 (MRK)
V. (Prentiss etal. v. Wasley Products, Inc. et al.)
BARRY BULAKITES, ET AL.,
Defendants. SEPTEMBER 14, 2005
WASLEY DEFENDANTS’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO RESPOND
TO BULAKITES DEFENDANTS’ FIRST SETS OF DISCOVERY REQ QUESTS
Pursuant to Rules 26, 33, and 34 of the Federal Rules of Civil Procedure and Rule 7(b) of .
the Local Rules of Civil Procedure, defendants Wasley Products, Inc., Alan Wesley, Andrew
Brady, Sandi Dun1as—Laferriere and Barry Connell (the "Wasley Defendants") hereby move for
. an extension of time of thirty (30) days, up to and including October 26, 2005,1 to respond, by
either answer or objection, to the Bulakites Defendants’ first sets of interrogatories and requests
for production of documents issued to each of the Wasley Defendants.2 In support of this
n motion, the undersigned represents that the discovery requests seeks information dating back
over a period of more than ten years. Additional time is needed to locate and review information
I Although the requests are dated August 24, 2005, they were mailed on August 26, 2005 and were not received by
-Wasley Defendants’ counsel until the following week.
2 Wesley Products, Inc. is also a plaintiff in the lead case and is represented by other counsel in that case who will
i respond to the requests directed to Wasley Products, Inc. as they pertain to the lead case.

_ Case 3:03-cv—00383-WIG Document 215 Filed 09/15/2005 Page 2 of 3
and prepare appropriate responses, particularly given that many of the defendants have been out
of town for the past two weeks and have not yet had an opportunity to review the requests.
This is the Wasley Defendants’ first motion seeking an extension of time to respond to
the Bulakites Defendants’ discovery requests. Counsel for the Bulakites Defendants does not
object to the requested extension. This matter has not yet been assigned for trial.
DEFENDANTS
WASLEY PRODUCTS, TNC., ALAN A.
WASLEY, ANDREW BRADY, SAND] DUl\/IAS-
LAFERRIERE, AND BARRY CONNELL
- . fr
Bw L" L - 1n: z--J.! ~*
‘ · eodore J. Tucci (ctO5249)
· [email protected]
. . ean 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—OO383-WIG Document 215 Filed O9/t5[2QO5 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing was mailed, first class postage prepaid, on
the 14th day of September, 2005 to the following:
Steven J. Errante, Esq.
Nancy A. Fitzpatrick, Esq.
Eric P. Smith, Esq.
Lynch, Traub, Keefe and Errante, P.C.
l 52 Trumbull Street, P. O. Box 1612
New Haven, CT 06506
Sara R. Simeonidis, Esq.
Deborah S. Freeman, Esq.
Bingham 1\/IcCutchen
One State Street
Hartford, CT 06103-3178
James J. Reardon, Jr., Esq.
Thomas G. Rohback, Esq.
Doug Dubitsky, Esq.
LeBoeuf, Lamb, Greene & MacRae, LLP ··
225 Asylum Street ·
Hartford, CT 06103 . .
Thomas G. Moukawsher, Esq. .
Ian O. Smith, Esq. '
Moukawsher & Walsh l
21 Oak Street, Suite 209
Hartford, CT 06106
Joseph V. Meaney, Jr., Esq.
Cranmore, Fitzgerald & Meaney
49 Wethersfield Ave.
Hartford, CT 06114-1102 `
4!»· ` ,11:
n E. Tomasco