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

Case 3:00-cv—00328-AHN Document 90 Filed 10/17/2006 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. g
BROOKSIDE ELM ASSOCLATES LIMITED PARTNERSHIP, etal., )
)
Defendants. ) October 17, 2006
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 until
10/31/06 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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W Q,Q;,gyc,QQ,§2,§&AHN Document 90 Filed 10/17/2006 Page 2 of 3
Brookside Elm Associates Limited Partnershuz, et aL •Joint Motion for a Rule 6(b)(1)
(United States District Court, at Bridgeport, C T Q Enlargement of Time, dated 10/1 7/06
(b) The appearing Defendants. The Court has previously extended
until 10/31/06 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 the appearing defendants have
submitted a settlement offer to the plaintiff, dated 9/20/06, which the plaintiff s disclosed
experts are now reviewing and will then assist the plaintiff in making a counteroffer, all
Counsel respectfully request that an Enlargement of Time be granted by the Court until
12/29/06 with regard to undertaking the matters referred to above in Paragraphs 1(a) and
(b).
2. The Joint Agreement. This is to confirm that each of the other Counsel of
Record has reviewed this Joint Motion and agrees to this Joint Motion.
»¤= * *
• Dated October 17, 2006 at Greenwich, Connecticut.
PLAINTIFF
Philip H. Bartels
For: Shipman & Goodwin LLP
Its Attorneys
289 Greenwich Avenue
Greenwich, CT 06830
(203) 869-5600 * (FAX) 869-4648
Federal Bar No. ct06836
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Wi,Q,,a,§,e,,§,,QpA__qyE,Qg0'§,?1§;£AHN Document 90 Filed 10/17/2006 Page 3 of 3
Brookside Elm Associates Limited Partnershqi, et aL •Joint Motion for a Rule 6(b)(1)
(United States District Court, at Bridgegort, C T) Enlargement o[ T img, dated 10/17/06
CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing shall be E—Mai1ed 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 October 17, 2006:
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 941 ll
NESK Corporation
Competrol Real Estate Limited
Olayan America Corporation
c/0 Mr. Edmond A. Kavounas
Rockwood Capital, LLC
Two Embarcadero Center
Suite 2360
San Francisco, CA 94111 Q g
Philip H. Bartels
#2349 vlA - Winthrop House.CONDOS.Joint Motion for Continuance
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