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

Case 3:03-cv-00383-WIG

Document 194

Filed 08/17/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WASLEY PRODUCTS, INCORPORATED : AND PRECISION MOLDING COMPANY, INC. : Plaintiffs, : : V. : : BARRY LEONARD BULAKITES, JAMES : ALBERT WINSLOW, JOSHUA ADAMS : CORPORATION, NATIONWIDE LIFE : INSURANCE CO. OF AMERICA f/k/a : PROVIDENT MUTUAL LIFE INSURANCE CO. : AND LINCOLN NATIONAL LIFE INSURANCE : CO. : Defendants. : __________________________________________ CIVIL ACTION NO. 3:03-CV-00383 (MRK)

AUGUST 16, 2005

DEFENDANT'S SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO WASLEY DEFENDANTS' DISCOVERY REQUESTS Pursuant to Local Rule 7, Defendant Lincoln National Life Insurance Co. ("Lincoln National") respectfully moves for a thirty-day (30) extension of time, to and including September 15, 2005, to respond to Defendants and Third-Party Plaintiffs Wasley Products, Inc., Alan Wasley, Andrew Brady, Sandi Dumas-Laferriere, and Barry Connell's ("Wasley Defendants") First Set of Interrogatories and Requests for Production. This is Lincoln National's second request for such an extension of time. In support of this motion, Lincoln National states: 1. Responses to the above-mentioned discovery requests initially were due on July

25, 2005. Lincoln National requested, and this Court granted, a thirty-day extension to time to respond to these requests, which currently are due on August 24, 2005. 2. Lincoln National's counsel intends to file a Motion to Withdraw as counsel for

Lincoln National in this matter. Lincoln National is in the process of obtaining alternate counsel, but requires additional time to do so.

Case 3:03-cv-00383-WIG

Document 194

Filed 08/17/2005

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3.

This Court previously has granted to Defendant Bulakites a sixty-day (60)

extension of time to respond to the Wasley Defendants' discovery requests, up to and including September 15, 2005. See Docket Entries 173, 183. 4. Counsel for Lincoln National has contacted counsel for the Wasley Defendants,

Attorney Jean Tomasco, who consents to this extension of time. WHEREFORE, Lincoln National respectfully requests an additional thirty days, up to and including September 15, 2005, to respond to the above discovery requests.

DEFENDANT, LINCOLN NATIONAL LIFE INSURANCE CO.,

By: _/s/ Douglas W. Bartinik__________ Albert Zakarian (ct069465) Eric L. Sussman (ct19723) Douglas W. Bartinik (ct26196) Day, Berry & Howard LLP CityPlace I Hartford, Connecticut 06103-3499 Telephone: (860) 275-0100 Fax: (860) 275-0343 [email protected] [email protected] [email protected] Its Attorneys

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Case 3:03-cv-00383-WIG

Document 194

Filed 08/17/2005

Page 3 of 3

CERTIFICATE OF SERVICE THIS IS TO CERTIFY that a copy of the foregoing was mailed this date, postage prepaid, to: Eric P. Smith, Esq. Steven J. Errante, Esq. Lynch, Traub, Keefe & Errante 52 Trumbull Street New Haven, CT 06510 Ian O. Smith, Esq. Thomas G. Moukawsher, Esq. Capitol Place 21 Oak Street, Suite 209 Hartford, CT 06106 Deborah S. Freeman, Esq. Bryan D. Short, Esq. Sara Simeonidies, Esq. Bingham McCutchen One State Street Hartford, CT 06103-3178 /s/_________________________________ Douglas W. Bartinik Joseph V. Meaney, Jr., Esq. Cranmore, Fitzgerald & Meaney 49 Wethersfield Avenue Hartford, CT 06114

Jean Elizabeth Tomasco, Esq. Theodore J. Tucci, Esq. Robinson & Cole 280 Trumbull Street Hartford, CT 06103

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