DISTRICT OF CONNECTICUT
GREGORY PRENTISS, JOHN RIZZI,
RICHARD SEICH, and DOROTHY BROWN, : MASTER CONSOLIDATED CASE
individually and on behalf of the Wasley : CIVIL NO. 3:03 CV 383 (MRK)
Products Inc. 40l(k) Profit Sharing Plan, : L
· Plaintiffs, THIS PLEADING PERTAINS TO: l
: CIVIL NO. 3:03 CV 1790 (MRK)
V. :
BARRY CONNELL, BARRY L. L
BULAKITES, JAMES A. WINSLOW, : ;
JOSHUA ADAMS CORP., : E
Defendants and Crossclaim Plaintiffs,
v. Q (
WASLEY PRODUCTS, INC., ALAN A.
WASLEY, ANDREW BRADY, SANDI :
DUMAS—LAFERRIERE, BARRY CONNELL, :
: MARCH 17, 2005
Defendants and Crossclaim Defendants. 1
MOTION FOR EXTENSION OF TIME TO RESPOND
TO CROSSCLAIMS
I Wasley Products, Inc., Alan Wasley, Andrew Brady, Sandi DUl'H3S-LQIBIIIBTC and Barry
Connell (collectively, the "Wasley Defendants?) hereby request a brief extension of time, up to I
and including April 15, 2005, to respond to the Crossclaims filed by Defendants Barry Bulakites, _ l
James Winslow and Joshua Adams Corporation (collectively the "Bu1akites Defendants") on
September 16, 2004.
The reasons for this motion are as follows. U - ‘ ;
On September 16, 2004 the Bulakites Defendants filed a Second Answer, Affirmative ;
Defenses and Crossclaims against the Wasley Defendants. The Wasley Defendants moved to _
ORAL ARGUMENT NOT REQUESTED r
Case 3:03-cv—00383—W|G Document 142 Filed 03/18/2005 Page 2 of 3
Dismiss all of the Crossclaims. By decision dated March 10, 2005, the Court denied the Wasley
Defendants’ Motion to Dismiss the Crossclaims. in addition, the court recently permitted
counsel for the Bulakites Defendants to withdraw from the case and ordered the Bulakites
Defendants to file substitute appearances. On March ll, 2005, the Bulakites Defendants filed a L
Motion for Extension of Time up to and including March 24, 2005 to retain new counsel}
Counsel for the Wasley Defendants are requesting additional time so as to confer with their _
clients concerning the recent developments in the case and prepare an answer to the Crossclaims.
In addition, it is hoped that by that time new appearances will be filed on behalf of the Bulakites
Defendants which should facilitate service of the pleading.
This is the Wasley Defendants first request for an extension of this deadline. This office 2
contacted Mr. Bulakites who has no objection to this motion but was not able to contact Mr.
Winslow to ascertain his position.
DEFENDANTS and CROS SCLAIM DEFENDANTS
- WASLEY PRODUCTS, INC., ALAN A. WASLEY,
- ANDREW BRADY, SANDI DUMAS.-LAFERRIERQE,
AND Y CONNELL
_ By: CQ;
eodore J. Tucci (ct05249)
[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
I The Wasiey Defendants were not notified of this request until it was filed with the court but do not oppose the
Motion for Extension of Time.
Case 3:03-cv—OO383--WIG Document 142 Filed O3/18/2005 Page 3 of 3 q
CERTIFICATION
This is to certify that a copy of the foregoing was mailed, first class postage prepaid on
the 17th day of March, 2005 to the following:
Barry Bulakites ;
558 Castle Pines Parkway Unit B4 #401
Castle Rock, CO 80108
James Albert Winslow
45 Sagamore Terrace South
Westbrook, CT 06498 l
Deborah S. Freeman, Esq.
Bryan D. Short, Esq. ‘
Bingham McCutehen _
One State Street ·
Hartford, CT 06103-3178 .
Albert Zakarian, Esq.
Victoria Woodin Chavey, Esq.
Eric L. Sussman, Esq.
Day, Berry & Howard
CityPlace
Hartford, CT 06103-3499
Thomas G. Moukawsher, Esq. _
Ian O. Smith, Esq. _
.Mou1
Hartford, CT 06106
Joseph V. Meaney, Jr., Esq.
Cranmore, Fitzgerald & Meaney
49 Wethersfield Ave.
Hartford, CT 06114-1102 6/__ ’ /-4,
Jean E. Tomaseo
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