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

Case 3:00-cv—00328-AHN Document 80 Filed 03/15/2006 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. )
)
BROOKSIDE ELM ASSOCIATES LIMITED PARTNERSHIP, etal., )
)
Defendants. ) March 15, 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—entit1ed Action, Winthrop House Association, Inc.,
hereby respectfully files this Joint Motion for an Enlargement of Time, as follows:
I 1. The reguested Enlargement of Time.
(a) The Association. The Court has previously extended until 3/31/06
the time for its 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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Case 3:00-cv—00328-AHN Document 80 Filed 03/15/2006 Page 2 of 3
Winthrop House Association, Inc.
Brookside lizlm Associates Limited Partnershqv, et al. •Joint Motion for a Rule 6(b)(1) -
(United States District Court, at Bridgegort, C T) Enlargement of Time, dated 3/15/06
(b) The appearing Defendants. The Court has previously extended
until 3/3 l/06 the time for the appearing defendants to file a responsive pleading or motion.
(c) The Reguest. All Counsel respectfully request that an Enlargement
of Time be granted by the Court until 5/8/06 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 reviewed this Joint Motion and agrees to this Joint Motion.
* * *
• Dated March 15, 2006 at Greenwich, Connecticut.
PLAIN TIF F
BY?
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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Case 3:00-cv—00328-AHN Document 80 Filed 03/15/2006 Page 3 of 3
Winthrop House Association, Inc.
Brookside Elm Associates Limited Partnershna, et al. •Joint Motion for a Rule 6(b)(1)
(United States District Court, at Bridgegort, C T) Enlargement ot T ime, dated 3/15/06
s 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 15, 2006:
Jane l. 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
99 Birch Lane Chairman
Greenwich, CT 06830 Rockwood Capital Corporation
325 Greenwich Avenue, 3rd. floor
Greenwich, CT 06830
NESK Corporation
Competrol Real Estate Limited
Olayan America Corporation
c/o Mr. Edmond A. Kavounas
99 Birch Lane
Greenwich, CT 06830
Philip H. Bartels ‘
#2349 vl - Winthrop House.CONDOS.Joint Motion for Continuance