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

q Case 3:03-cv—00383e.W|G Document 184 Filed 07/20/2005 Page 1 of 4
UNITED. STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., ET AL., MASTER CONSOLIDATED CASE
. I CIVIL NO. 3:03 CV 383 (MRK)
. ..... .. .. Plaintiffs,
. THIS PERTAIN S. TO:.
. CIVIL NO. 3:03. CV 1790. (MRK)
V. (Prentiss et al. v. Wesley Products, Inc. et al. ).
EARRY BULAKITES, ET AL.,
l . ..... .. Defendants. IULY 19, 2005
n RESPONSE. TO BULAKITES. DEFENDANTS’
MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY
I Defendants Wesley Products, Inc., Alan Wesley, Andrew Brady, Sandi Dumas-
Laferriere end Barry Connell (the "Wasley Defendants"). hereby respond to the. motion for
extension of time filed by defendants Barry Bulakites,. James Winslow, and Joshua Adams.
Corp. (the. "Bu1akites Defendants") to respond to the Wesley Defendants’ discovery requests,
which were served in mid—June.. . The Bulakites. Defendants seek an extension of time of 60
_ days, to. and including September 15, 2005, to respond to the requests. The Wesley
Defendants initially were willing to agree to an extension of 30 days (to and including August
15, 2005), which is the. same time period agreed to. for all other parties concerning responses.
to discovery.
During the case management conference, and as set forth in the proposed case
management conference submitted to the court,. counsel for all parties agreed that written
i discovery and document production would occur in advance of depositions and agreed upon e
date. of October 6, 2005 for the completion of interrogatories and requests for production.

Case 3:03-cv—OO38;§—1/t/IG Document 184 Filed 07/2Q/2005 Page 2 of 4
. These cases have been pending for well over a year and new cotmsel for the Bulakites
Defendants filed an appearance nearly three months ago. As the court has recognized, it is
imperative that this case. move. forward in a timely fashion. If the Bulakites. Defendants.
n require until September 15, 2005, to. respond to the interrogatories. and produce all documents,
the. Wasley Defendants do not object, provided that the. Bulalcites Defendants serve their
objections (if any) by August 15th. There is. no sound basis to delay the propounding of ‘
discovery objections bythe. Bulalcites Defendants until the. middle of September.. The
_ undersigned contacted counsel for the Bulakites Defendants concerning this. issue; however,
l counsel would not commit to serving objections on behalf of the Bulakites. Defendants by
August 15, 2005.
In order to allow the. case. to move forward, in the event that the court grants the.
requested extension, the. Wasley Defendants respectfully request that the Bulakites.
Defendants should be required to serve all objections by August 15, 2005. This will allow the
. opportunity for the potential resolution of discovery objections while the Bulakites
Defendants. are completing compliance with interrogatories. and production requests as to.
which there is no objection.

_ Case 3:03-cv—OO383jW|G Document 184 Filed 07/20/2005 Page 3 of 4
DEFENDANTS. A
. WASLEY PRODUCTS, INC., ALAN A.
. WASLEY, ANDREW BRADY, SANDI
DUMAS~LAFBRRIERE,. AND. BARRY
A CONNELL
. . By: " J 2Q A
. . Theodore J. Tu (ctO5249)
. . [email protected].
I . 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—OO383-WIG Document 184 Filed 07/ZOZZOO5 Page 4 of 4
CERTIFICATION
This is to certify that a copy of the foregoing was mailed, first class postage prepaid,
on the 19th day of July, 2005 to the following:
Thomas G. Moukawsher, Esq.
Ian O. Smith, Esq.
Moukawsher & Walsh
21 Oak Street, Suite 209
' Hartford, CT 06106
Steven J. Errante, Esq.
Eric P. Smith, Esq.
` Nancy A. Fitzpatrick, 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
Albert Zakarian, Esq.
Victoria Woodin Chavey, Esq.
Eric L. Sussman, Esq.
Douglas W. Bartinik, Esq.
Day, Berry & Howard
CityP1ace
Hartford, CT 061036499
Joseph V. Meaney, Jr., Esq.
Cranmore, Fitzgerald & Meaney
49 Wethersfield Ave. .
Hartford, CT 06114-1102 _ g
Theodore J. Tucci I