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

Case 3:00-cv-00711-RNC Document 144 Filed 10/14/2004 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WILLLAM G. CLARK, )
Plaintiff/ ) CIVIL ACTION
Counterclaim Defendant, )
)
v. ) No. 300CV07l1 (RNC)
)
LUMBERMENS MUTUAL CASUALTY )
COMPANY, )
Defendant/ )
Counterclaim Plaintiff ) OCTOBER 14, 2004
MOTION FOR EXTENSION OF THE
DEADLINE SET FORTH IN THE JUNE 14, 2004 ORDER
Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Local Rule 9(b),
plaintiff William G. Clark respectfully moves the Court to extend the deadline set forth in the
Court’s June 14, 2004 Order by one month, up to and including November 15, 2004. In support
of this Motion, Mr. Clark represents as follows:
1. On May 17, 2004, the parties notified the Court that a settlement had been
reached, but that a certain amount of time was needed to finalize and execute the settlement.
2. As a result of such representation, on June 14, 2004, the Court ordered the Clerk
"to close the file for administrative purposes without prejudice to reopening on or before October
15, 2004." In addition, the Court ordered that the parties could file a stipulation of dismissal
with the Court on or before October 15, 2004.
3. The Court also stated that the "date set forth in this order may be extended
pursuant to a motion filed in accordance with" the Local Rules.
4. In order to implement the conditions necessary to make it possible to execute the
settlement, the parties require additional time. The parties expect that such conditions will be

Case 3:00-cv-00711-RNC Document 144 Filed 10/14/2004 Page 2 of 4
met prior to November 15, 2004.
5. The requested extension will allow the parties to execute the settlement without
urmecessarily requiring the reopening of this file.
6. Defendant Lumbermens Mutual Casualty Company does not oppose the extension
of time set forth in this Motion.
7. This is the first motion for extension of time relating to the deadline set forth in
the CoLut’s June 14, 2004 Order.
WHEREFORE, Plaintiff William G. Clark respectfully requests that the Court extend the
deadline set forth in the COuI't’S June l4, 2004 Order by one month, up to and including
November 15, 2004.
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Case 3:00-cv-00711-RNC Document 144 Filed 10/14/2004 Page 3 of 4
Dated: October 14, 2004 PLAINTIFF
WILLIAM G. CLARK
By, M
William M. Rubenstein
Federal Bar No. ct08834
Chad A. Landmon
Federal Bar No. ct20932
Eric D. Beal
Federal Bar No. ct23167
AXINN, VELTROP & HARKRIDER LLP
90 State House Square
Hartford, Connecticut 06103
(860) 275-8100
Stuart L. Shapiro
Federal Bar No. ct21475
Michael W. Mitchell
Federal Bar No. ct11299
Matthew J. Sava
Federal Bar No. ct21841
SHAPIRO MITCHELL FORMAN ALLEN
& MH.LER LLP
380 Madison Avenue
New York, New York 10017
(212) 972-4900
Elkan Abrarnowitz
Federal Bar No. ct24345
MORVILLO, ABRAMOWITZ, GRAND,
IASON & SILBERBERG, P.C.
565 Fifth Avenue
New York, New York 10017
(212) 880-9650
Attorneys for Plaintiff
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Case 3:00-cv-00711-RNC Document 144 Filed 10/14/2004 Page 4 of 4
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that a copy of the foregoing Motion for Extension of the Deadline
Set Forth in the June 14, 2004 Order has been sent via first class U.S. mail, postage prepaid, this
14th day of October, 2004 to:
Thorn Rosenthal, Esquire
S. Penny Windle, Esquire
Cahill Gordon & Reindel
80 Pine Street
New York, New York 10005
Lawrence W. Andrea, Esquire
127 Kent Hollow Road
Kent, Connecticut 06757
e 4./ {
Chad A. Landmon
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