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

Case 3:00ecv-00706-SRU Document 121 Filed 08/18/2004 Page 1 ot 3 ,
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BROADWAY THEATRE CORP. )
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V. ) CIVIL ACTION NO: 3:00-C\/-00706 (SRU)
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BUENA VISTA PICTURES )
DISTRIBUTION, COLUMBIA )
PICTURES INDUSTRIES, INC., )
DREAMWORKS DISTRIBUTION L.L.C., )
LIONS GATE FILMS INC, )
METRO-GOLDEVYN-MAYER )
DISTRIBUTION CO., MIRAMAX FILM ) _
CORP., NEW LINE CINEMA )
CORPORATION, PARAMOUNT )
PICTURES CORPORATION, SONY )
PICTURES RELEASING )
CORPORATION, UNIVERSAL FILM )
EXCHANGES, INC., WARNER BROS. )
DISTRIBUTING, AND USA FILMS, LLC ) AUGUST I3, 2004
DEFENDANTS’ MOTION FOR EXTENSION OF TIME
The Defendants, pursuant to L.Civ.R. 7(b) 2, hereby move for an extension of time to and
inciuding September 27, 200-4, to file a Response in Opposition to the Plaintiff s Motion to
Vacate dated August I2, 2004.
Good cause exists for the granting of this motion in that the time limitation in question
cannot reasonable be met despite the diligence of counsei and each defendant for the following
reasons:
ORAL ARGUMENT NOT REQUESTED

Case 3:00ecv-00706-SRU Document 121 Filed 08/18/2004 Page 2 ot. 3
This matter was dismissed with prej ndice on May I0, 2004 and since that time counsel
have been actively engaged in other matters, including trial in Superior Court. Over the course
U ofthe next two weeks, counsel for the defendants are either on vacation or will be attending out-
ot?-state depositions. Additionally, many in—house counsel for the defendants are on vacation this
week and next. Given the number of defendants, an extension of time is necessary in order to
have adequate opportunity to discuss and formulate a response. Finally, discovery may also have
to be undertaken prior to the preparation of an appropriate response.
This afternoon the undersigned contacted Attorney Max Brunswick by telephone to
inquire whether he would agree or object to this motion for extension of tirne. Attorney
Brunswick does not object to the granting of this motion.
This is the tirst motion for extension of time tiled with respect to this limitation.
Respectfully Submitted,
THE DEFENDANTS,
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By V isa, =’‘
Richard W. Bowerman (ct 0-418l)
Elizabeth K. Andrews (c-@0986)
Tyler Cooper & Alcorn, LLP
205 Church Street
Post Office Box l936
New Haven, Connecticut 06509
(203) 784·-8200
(203) 777—l l8l (fax)
e-mail: tggggjerinaiitdktrlereooperoznn
- Their Attorneys —
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Case 3:00-cv-00706-SRU Document 121 Filed 08/18/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a mie amd correct copy of the foregoing was served by first-class
meii on August 13, 2004 io the following:
Peter C. Spodiek, Esquire
8 Hazel Terrace
Woodbridge, Connecticut 06525
Mex F. Bmnswick, Esquire
12 Trumbull Street
New Haven, Connecticut 06511
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Richard W. Bowezmzm (c1;0¤$I8l)
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