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

Case 3:03-cv-00383-WIG Document 147 Filed O4/05/2005 Page 1 of 4 I
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UNITED STATES DISTRICT COURT [mw APH-5 FDI2:2| 1
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DISTRICT OF CONNECTICUT U·$.i;i:{{N YA 2A¥U{T !
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WASLEY PRODUCTS, INCORPORATED AND Master Consolidated Case i
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PRECISION MOLDING COMPANY Inc Civil No.3:03CV 383 (MRK) 1
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Plaintiffs, Formerly
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v. No. 3:O3CV383 (DJS)
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Barry Leonard Bulakites, James Albert I
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Winslow et al. ;
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MOTION FOR EXTENSION OF TIME TO REPLACE CO NSEL I
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Defendants Bulakites and Winslow request a brief extension of time up to and l
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including April 11, 2005 be granted to obtain counsel to replace Attorney’s
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Fitzmaurioe and Rydel. This letter is pursuant to conversation with Judge
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Squatrito on March 9m pertaining to his order of March 3“*2005 granting
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Fitzmaurice and Rydel’s motion to withdraw.
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Mr. Bulakites phoned the Court and spoke to Judge Squatrito on the morning of
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March 9m regarding the Courts order and to request an extension of time. 1
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Defendants Bulakites and Winslow had not received the Court’s order until
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March Tm therefore allowing only a few days to secure replacement counsel. i
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Defendants Bulakites and Winslow are actively engaged in conversation with a !
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new firm that they desire represent them in this matter who requested that we
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phone the Court. Unfortunately, the Attorney that has been selected has been 1
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Case 3:03-cv-00383-WIG Document 147 Filed O4/05/2005 Page 2 of 4
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1 on trial and was unavailable to review case files and has not had the _
2 opportunity to speak with Attorney Fitzmaurice. i
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4 Given these facts we were asked to call the court and request a brief i
5 extension of time to allow them to get files and file an appearance. Mr.
6 Bulakites called the Court and spoke to Judge Squatrito on the morning on
7 March 9m, 2005 and explained the predicament. Judge Squatrito indicated that
B he felt a brief extension should not be a problem and indicated he would é
9 inform his Clerk and have him call Mr. Bulakites later that day if there was i
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12 On March 10, 2005 we called the Clerk to verify if a letter needed to be :
13 submitted and were informed to file this motion. Defendants Bulakites and E
14 Winslow filed a motion for extension of time up to an including March 24“‘
15 2005 to have replacement counsel file an appearance. i
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17 Subsequent to that motion defendants were notified that Judge Squatrito had `
18 transferred the consolidated case Judge Kravitz in New Haven. Defendants are E
19 therefore in discussion with firms in New Haven regarding these new
20 developments. The firm we have selected is in the process of obtaining files i
21 and prior records from the case. We expect that they will file their
22 appearance on or before April l, 2005 and therefore respectfully request the
23 extension. i
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- Case 3:03-cv-00383-WIG Document 147 Filed O4/05/2005 Page 3 of 4 Q
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1 Defendants have also recently learned that Attorney Zakarian of Day, Berry & 9 _
2 Howard represents one of the p1aintiff's in this case. We believe that this x
3 represents a conflict in that Attorney Zakarian has represented Defendant
4 Bulakites as part of an employment matter in the past. Further Day, Berry &
5 Howard were consulted with regard to this case by defendants during which
6 discussions Day, Berry & Howard may have obtained confidential information I
7 that the defendants provided. We are researching this further and expect to 0 {
8 make further motions based on this fact. I
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1 0 DEFENDENTS:
11 Barry Leonard Bulakites
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13 James Albert Winslow
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17 Barry Leonard Bulakites i
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Case 3:03-cv-00383-WIG Document 147 Filed O4/05/2005 Page 4 of 4 E
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CERTIFICATION T
This is to certify that a copy ofthe foregoing was mailed, first class mail on March 24m l
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Deborah S Freeman Esq. \
Bryan Short Esq.
Bingham McCutchen ~
One State Street l
Hartford, CT 06103 E _
Albert Zakarian, Esq. i
Vistoria Woodin Chavey, Esq. `
Eric Suusman Esq. i
Day, Berry & Howard
CityPlace 3
Hartford, CT 06103 T
Thomas G Moukawsher Esq
Ian O. Smith Esq. q
Moukawsher & Walsh l
21 Oak Street Suite 209
Hartford, CT 06106 q
Joseph V. Meaney, Jr. Esq. r
Cranmore, Fitzgerald & Meaney {
49 Wethersfield Ave.
Hartford, CT 06114 I
Dated :_‘___ , y"
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