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

Case 3:00-cv-00554-JCH Document 48 Filed 10/20/2004 Page 1 of 3 A
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT .
FEDERAL DEPOSIT INSURANCE CORP.,:: CIVIL ACTION NO: 3:02CVS 54(J CH) I
as Receiver for Burritt Interfinancial
Bancorporation, : p ·
PLAINTIFF, : p
V. : y
WINSTED LAND DEVELOPMENT CO.
Bt al, DEFENDANTS. October 19, 2004 I
A SECOND MOTION FOR EXTENSION OF TIME
(WITH CONSENT) ·
The defendant, John Lombard in the above-captioned action hereby moves this Court for an
extension of time up of 90 additional days, up to and including January 20, 2005, within which to
plead or otherwise respond to plaintiff’ s application for an order to show cause. A
Counsel for the parties have engaged in discussions seeking to resolve the litigation but have
agreed that some limited discovery will be needed before meaningful discussions can proceed
further. In order to accomplish what is hoped as limited discovery, plaintiff is considering a waiver
of its attorney client privilege that exists with prior counsel for the plaintiff in order to allow
document review by defense counsel and depositions of former employees ofthe FDIC and former -
counsel to take place. .
This additional time will permit current counsel for the parties to conduct review and prepare I
any additional discovery schedule- if needed- to permit an adequate factual investigation of the
plaintiff s claims.

Case 3:00-cv-00554-JCH Document 48 Filed 10/20/2004 Page 2 of 3 I
This is the defendant’s second request for an enlargement of time to respond to the
complaint. Defense counsel has spoke with Christine Sciarrinqcounsel for plaintiff, who consents j
to this request for a extension of time.
DEFENDANT,
r\. F
By: I ·
V Eliot B. ers en, Esq. 213) F
` GERSTEN & CLIFFORD
214 Main Street ?
Hartford, CT 06106
(860) 527-7044
His Attorney i

Case 3:00-cv-00554-JCH Document 48 Filed 10/20/2004 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that a copy ofthe foregoing was mailed first-class mail, postage prepaid, on
October 19, 2004 to all counsel and pro se parties of record, as follows: —
Christine Sciarrino L
Assistant U.S. Attorney V
Post Office Box 1824
New Haven, CT 06508
(Counsel for Plaintiff Federal Deposit Insurance Corporation)
William L. Stevens
St. John, Lombard & Stevens 4
13 First Avenue
Waterbury, CT 06710
— Eliot B. Gersten
3 ,