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

Case 3:00-cv—00328-AHN Document 96 Filed 05/30/2007 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
(at Bridgeport)
WHQTHROP HOUSE ASSOCIATION, INC., ) Case No.:
) 3-O0-CV-328-AHN
Plaintiff, )
v. )
)
BROOKSIDE ELM ASSOCLATES LHVIITED PARTNERSHIP, et al., )
)
Defendants. ) May 30, 2007
JOINT MOTION FOR A RULE 6gb)g1) ENLARGEMENT OF TIME
ENLARGEMENT
OF TIME RE: 1. The subject time period within which the plaintiff shall serve the 2/ 17/00
Complaint and the 5/19/00 First Amended Complaint on the remaining
_ defendants
2. The subject time period within which the appearing defendants shall file
a responsive pleading or motion
The plaintiff in the above—entitled Action, Winthrop House Association, Inc.,
hereby respectfully files this Joint Motion for an Enlargement of Time, as follows:
1. The reguested Enlargement of Time.
(a) The Association. The Court has previously extended tmtil 5/31/07
the time for the plaintiff s service of the 2/17/00 Complaint and the 5/19/00 First Amended
Complaint on the non—appearing defendants, gz (i) NESK Corporation; (ii) Competrol
Real Estate Limited; (iii) Olayan America Corporation; (iv) Neil H. Smith; and (v)
Edmond A. Kavounas.
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Wingiagjeigégzg-sp%gg3,2§gAHN Document 96 Filed 05/30/2007 Page 2 of 3
Brookside gzlm Associates Limited Partnershqr, et aL •.Ioint Motion for a Rule 6(b)(1)
(United States District Court, at Bridgeport, C T) Enlargement o[ T ime, dated 5/30/07
(b) The appearing Defendants. The Court has previously extended
until 5/31/07 the time for the appearing defendants to file a responsive pleading or motion.
(c) The Reguest. In order to permit the parties to continue their
settlement discussions, and in view of the fact that Arthur Collins, II (as the representative
of the principal appearing defendants) submitted an amended settlement proposal on or
about 5/24/07 to Robert Follert (as President of the plaintiff), as part of the continuing
settlement discussion process, thus, all Counsel respectfully request that an Enlargement of
Time be granted by the Court until 7/31/07 with regard to undertaking the matters referred
to above in Paragraphs l(a) and (b).
2. The Joint Agreement. This is to confirm that each of the other Counsel of
Record has approved the timeframes set forth in this Joint Motion and agrees to this Joint
Motion.
=z= * *
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Mnglatgleigégzqi-Scml(%9)32§éAHN Document 96 Filed 05/30/2007 Page 3 of 3
Brookside Elm Associates Limited Partnershqn, et aL •Joint Motion for a Rule 6(b)(1)
(United States District Court, at Bridgegort, C T Q Enlargement of T img, dated 5/30/07
• Dated May 30, 2007 at Greenwich, Connecticut.
PLAINTIFF
By: ( go-\Jl"é0d;
Philip H. Bartels
For: Shipman & Goodwin LLP
Its Attorneys
289 Greenwich Avenue
Greenwich, CT 06830
(203) 869-5600 * 869-4648
Federal Bar No. ct06836
· CERTIFICATION
5 THIS IS TO CERTIFY that a copy of the foregoing shall be E-Mailed this day to
all subject Counsel of Record, mailed to the other persons noted below and shall be
electronically tiled with the Clerk of the Court, on May 30, 2007:
Jane 1. Milas, Esq. Richard M. Dighello, Jr., Esq.
Garcia & Milas Updike, Kelly & Spellacy
_ 44 Trumbull Street One State Street
New Haven, CT 06510-1001 P.O. Box 231277
Hartford, CT 06123-1277
Mr. Edmond A. Kavounas Mr. Neil H. Smith
Executive Managing Director Senior Director
Rockwood Capital, LLC Rockwood Capital, LLC
Two Embarcadero Center Two Embarcadero Center
Suite 23 60 Suite 2360
San Francisco, CA 94111 San Francisco, CA 94111
NESK Corporation
Competrol Real Estate Limited
Olayan America Corporation
c/o Mr. Edmond A. Kavounas
Rockwood Capital, LLC
Two Embarcadero Center
Suite 23 60
San Francisco, CA 94111

Philip H. Bartels
#2349 v1A - Winthrop House.CONDOS.Joint Motion for Continuance
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