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

Case 3:00-cv—O0328-AHN Document 94 Filed O3/29/2007 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
(at Bridgeport)
WINTHROP HOUSE ASSOCIATION, INC., ) Case No.:
) 3-00-CV-328-AHN
Plaintiff, )
v. )
)
BROOKSIDE ELM ASSOCIATES LIMITED PARTNERSHIP, etal., )
)
Defendants. ) March 29, 2007
JOINT MOTION FOR A RULE 6gb)g1) ENLARGEMEN T 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 until 3/31/07
the time for the plaintiffs service of the 2/17/00 Complaint and the 5/19/00 First Amended
Complaint on the non—appearing defendants, g: (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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Wi,,Qa,§e,§gQg§c)é;Qgg3§éAHN Document 94 Filed O3/29/2007 Page 2 of 3
Brookside Elm Associates Limited Partnership, et al. •Joint Motion for a Rule 6(b)(1)
(United States District Court, at Bridgeport, CT) Enlargement ot] Tim e, dated 3/29/07
(b) The appearing Defendants. The Court has previously extended
until 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), Robert Follert (as President of the plaintiff) and
Kenneth Gibble, P.E. (as a principal expert of the plaintiff) met on 3/26/07 as part of the
continuing settlement discussion process, and as a result thereof the principal appearing
defendants anticipate that they will submit an amended settlement proposal next week,
thus, all Counsel respectfully request that an Enlargement of Time be granted by the Court
until 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.
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Wi,,§.`j;;,;,e,g§,gQQ§g,;é;g),Qg§§éAHN Document 94 Filed O3/29/2007 Page 3 of 3
V.
Brookside Elm Associates Limited Partnershur, et al. •J0int Motion for a Rule 6(b)(1)
(United States District Court, at Bridgegort, C T) Enlargement o[ Time, dated 3/29/07
• Dated March 29, 2007 at Greenwich, Connecticut.
PLAINTIFF
By: <
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
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 filed with the Clerk of the Court, on March 29, 2007:
Jane I. 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 2360 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 2360
San Francisco, CA 94111
/@*·~·~·»·~·~’**%d’ Philip H. Bartels
#2349 vlA - Winthrop House.CONDOS.Joint Motion for Continuance
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