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

Case 3:00-cv-00871-CFD Document 109 Filed 10/1 $2003 Page 1 of 4
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UNITED STATES DISTRICT COURT I
FOR THE _
DISTRICT OF CONNECTICUT I
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GREYSTONE COMMUNITY * :-2;. _, __`,
REINVESTMENT ASSOCIATES, INC. * §";{jfiJ§ I
Pi.-mart * CIVIL ACTION if I
* NO. 3:00CV87‘I (QFD) ·,;,_, ji
VS " 2;;;
Feast UNION NATIONAL BANK * iiii $5
Defendant * OCTOBER 15, 2003 I
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JOINT MOTION FOR EXTENSION OF TIME I
Pursuant to Rule 7(b) of the Local Rules of Civil Procedure, the parties, Greystone I
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Community Reinvestment Associates, Inc. ("Greystone") and First Union National Bank I
("First Union") (jointly, the "Parties"), hereby request an extension of time to comply with the
C0urt's Trial Memorandum Order (the "Order"). Under the Order, compliance is required on
or before November 15, 2003. By this Motion, the Parties seek an extension of time of thirty
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(30) days from the completion of a settlement conference to be conducted by the Honorable
Thomas P. Smith. In support of this request, the parties would further note the following:
1. Greystone brings this action against First Union asserting claims of breach of
contract, breach of fiduciary duty, unjust enrichment, breach of confidentiality agreement,
innocent misrepresentation, negligent misrepresentation, fraudulent misrepresentation, and
NO ORAL ARGUIVIENT REQUESTED I
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_ _ _ , Case 3:00-cv-0087 l

violations of the Connecticut Unfair Trade Practices Act ("CUTPA"), Conn. Gen. Stat. § 42-
110a, et gi. l
2. The Parties previously submitted Cross-Motions for Summary Judgment on or
about November 5, 2002, in this matter.
3. The Parties have only recently received a ruling denying those Cross-Motions
for Summary Judgment dated September 30, 2003.
4. Along with said ruling, the Parties received this Court's Order and a referral to
the Honorable Thomas P. Smith for a settlement conference.
5. The instant litigation is complex and the Parties have previously participated in
at least three settlement conferences concerning this litigation with the Honorable William I. A
earrmkei.
6. Given the current procedural posture of this action, as well as the time and
expense necessary to properly comply with the Court's Order, the Parties respectfully believe
that it will be in everyone's best interest to postpone compliance with said Order until
settlement has been fully explored with Judge Smith.
7, The Parties respectfully believe that the likelihood for settlement will improve if _
the Parties are not forced to incur any additional litigation expenses at this point in time. \
8. The Parties respectfully submit that an extension of time of thirty (30) days from
the settlement conference with Judge Smith should allow the Parties time to comply with the
Court's Order, if necessary, and is not unreasonable under the circumstances of this case. 5
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_ t Case 3:00-cv-OOSWFD Document 109 Filed 10<1q2003 Page 3 of 4 (
9. The Parties represent that this is a first request for an extension of time directed l
towards the Court's Trial Memorandum Order. I
10. The Parties expect that a settlement conference will be conducted in January l
2004, in this matter and are in the process of forwarding available dates to Judge Smith for
his consideration.
WHEREFORE, the Parties respectfully request that they be allotted an additional thirty
days from the holding of a settlement conference in this matter in order to comply with the
Court's Trial Memorandum Order.
THE PLAINTIFF THE DEFENDANT
GREYSTONE COMMUNITY FIRST UNION NATIONAL BANK
REINVESTMENT ASSOCIATES, INC. \
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Eliot . Gersten, Esq. James T. Shearin ct 01326 {
John J. Robacynski - Brian C. Roche ct17975 i
Gersten & Clifford Pullman 8 Comley, LLC I
214 Main Street 850 Main Street, 8"‘ Floor
Hartford, CT 06106 Bridgeport, CT 06604
Telephone: (860) 527-7044 Tel. (203) 330-2000
Facsimile: (860) 527-4968 Facsimile (203) 576-8888
E-Mail: [email protected] E-Mail: [email protected]
bcr@pu|Icom.com
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_ , t Case 3:00-cv-008?f—§)FD Document 109 Filed 10{T72003 Page 4 of 4 N
CERTIFICATION I
This is to certify that a copy hereof was mailed, postage prepaid, on the date hereon to
each attorney of record and to all pro se parties of record as follows:
Eliot B. Gersten, Esq.
John J. Robacynski
Gersten & Clifford 5
214 Main Street ‘
Hartford, CT 06106 I
James T. Shearin (ctO1326)
Brian C. Roche (ct17975) I
Br¤rm5g1uo.1rscw49aa43v1 I
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