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

I _ I ase 3:02-cv-01721-AHN Document 40 Filed O4/05/2004 Page 1 of 3 I
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DISTRICT OF CONNECTICUT I
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I Plaintiff :: I °
I I v. :: 3:02CVl721 (AHN)
EXISS ALUMINUM TRAILERS, INC. I I
TOUREILLON TRAILER SALES, INC. ;; I
I Defendants :: APRIL 2, 2004
MOTION FOR POSTPONEMENT OF PRETRIAL CONFERENCE
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Plaintiff, Action Motors Corp. ("Action"), respectfully moves the Court to postpone the
Pretrial Conference currently scheduled for April 15, 2004, for two weeks to permit the parties I
to complete settlement discussions on this matter. As a further basis for this motion, Action
requests the continuance due to personal commitments of Action's attorneys which can only be I
rescheduled with difficulty or inconvenience. Counsel for both defendants consent to this
motion. I
In support hereof, Action states as follows:
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I 1. Action and Exiss Aluminum Trailers, Inc. ("Exiss") have agreed to a framework
for settling Action's claims against Exiss. It is not certain, at this point, whether the details of

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the settlement will be finalized by April 15, 2004, and whether necessary documents will be E
executed by April 15, 2004. Following execution of the documents, Action will need to move
for a dismissal of its claims against Exiss. An additional two weeks will permit Action and I
Exiss to work out the terms of settlement and execute all necessary documents. There is not
yet a framework in place to settle Exiss's claims against Tourbillon Trailer Sales, lnc.
2. Further, Action requests that the Pretrial Conference be rescheduled from April
l5, 2004, because both of Action‘s attorneys have personal commitments scheduled for that
day that can be only be rescheduled with difficulty or inconvenience. Attorney Ward N
N Mazzucco has an appointment with an ophthalmologist on the morning of April 15, 2004. The
appointment was scheduled two months in advance, and if Attorney Mazzucco has to N
reschedule this appointment, it is unlikely that he will be able to see his doctor for another
several months. Attorney Frances Slusarz is scheduled to purchase and move her residence on N
April 15, 2004. She is expected to supervise the transportation of her family's belongings on
N that day. Rescheduling her move requires coordinating with her moving company and,
potentially, staying over beyond the term of her current residential lease. N
WHEREFORE, Action respectfully requests that the Pretrial Conference be postponed N
by at least two weeks. N
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1 1 J ase 3:02-cv-01721-AHN Document 40 Filed O4/05/2004 Page 3 of 3
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Respectfully submitted,
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By:
Ward . Mazzucco (Fed. Bar No. ct05941)
1 Frances Codd Slusarz (Fed. Bar No. ct24442)
1 Chipman, Mazzucco, Land & Pennarola, LLC
1 30 Main Street, Suite 204 ‘
Danbury, CT 06810-3043
1 Phone: (203) 744-1929
Fax: (203) 790-5954 1
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CERTIFICATION 1
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1 This is to certify that a copy of the foregoing was mailed, postage prepaid and/or hand-
delivered to: David P. Atkins, Esq. of Zeldes, Needle & Cooper, 1000 Lafayette Boulevard, 1
P.O. Box 1740, Bridgeport, CT 06601-1740 and J. Kevin Golger, Esq. of McNamara and 1
Kemaey, 375 Bridgeport Avenue, Shelton, CT 06484-3861 on this 2nd day of April, 2004.
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ances Co Slusarz
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