Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:01-cv-02296-RNC

Document 112

Filed 07/22/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JAMES VAN DE VELDE, Plaintiff, : : CIVIL NO. 3:01cv02296(RNC)

: : VS. : : MELVIN WEARING, BRIAN SULLIVAN, : THOMAS TROCCHIO, EDWARD KENDALL, : ESTATE OF ANTHONY DILULLO, by Lisa : Bull DiLullo, Legal Representative, : JOHN DOES, RICHARD LEVIN, : LINDA LORIMER, RICHARD BRODHEAD, : THOMAS CONROY, and JAMES PERROTTI, : Defendants. :

JULY 22, 2008

CONSENT MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTIONS TO DISMISS AND FOR JUDGMENT ON THE PLEADINGS Plaintiff James Van De Velde hereby moves for an extension of time to August 5, 2008, to file his memorandum in opposition to the Motion to Dismiss Plaintiff's Second Amended Complaint filed by defendants Richard Levin, Linda Lorimer, Richard Brodhead, Thomas Conroy, and James Perrotti ("the Yale defendants"), and the Motion for Judgment on the Pleadings filed by defendants Melvin Wearing, Brian Sullivan, Thomas Trocchio, Edward Kendall and Estate of Anthony DiLullo ("the New Haven defendants"). Under the scheduling order previously approved by the Court, the responses to these motions are due to be filed July 20th and 23rd, respectively. Significant progress has been made in preparing a response, but additional time is necessary. The preparation of a responsive filing is more burdensome in this round of motion practice than in the motions addressed to the prior complaint, principally because the New Haven defendants have also filed a lengthy memorandum of law to which plaintiff

Case 3:01-cv-02296-RNC

Document 112

Filed 07/22/2008

Page 2 of 3

must respond. In the last round of motions, those defendants simply moved for judgment on the pleadings but adopted all of the legal arguments advanced by the Yale defendants; there was no separate legal filing. Aaron Bayer, Esq., counsel for the Yale defendants, does not object to the requested extension. Undersigned counsel has not heard from counsel for the New Haven defendants; however, based on prior communications it is anticipated that they also would not have any objection. No prior motions for extension have been filed with respect to this deadline. WHEREFORE, plaintiff moves that his time to respond to defendants' motions be extended to August 5, 2008. THE PLAINTIFF JAMES VAN DE VELDE By___/s/David T. Grudberg David T. Grudberg, ct01186 JACOBS, GRUDBERG, BELT & DOW, P.C. 350 Orange St. P.O. Box 606 New Haven, CT 06503 Ph.:(203) 772-3100 Fax:(203) 772-1691 Email: [email protected] James I. Meyerson, ct24660 396 Broadway - Suite 601 New York, New York 10013 Ph.:(212) 226-3310 Fax: (212) 219-9412 Email: [email protected] His Attorneys

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Case 3:01-cv-02296-RNC

Document 112

Filed 07/22/2008

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on July 22, 2008 the attached Motion for Extension of Time was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by email to all parties by operation of the court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the court's CM/ECF system.

/s/David T. Grudberg David T. Grudberg, ct01186 JACOBS, GRUDBERG, BELT, DOW & KATZ, P.C. 350 Orange St. P.O. Box 606 New Haven, CT 06503 Ph.:(203) 772-3100 Fax:(203) 772-1691 Email: [email protected]

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