Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:00-cv—00328-AHN Document 74 Filed 12/19/2005 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 ASSOCLATES LIMITED PARTNERSHIP, etal., )
)
Defendants. ) December 19, 2005
JOINT MOTION FOR CONTINUANCE AND FOR A RULE 6(b)(1)
_ ENLARGEMENT OF TIME
CONTINUANCE I
RE: The 12/20/05 Status Conference
ENLARGEMENT
OF TIME: l. 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 Continuance and for an Enlargement of
Time, as follows:
1. The reguested Continuance. Further to the Court’s recommendation at
the 11/2/05 Status Conference that the Association and the Declarant meet (without
counsel) for further settlement discussions, thus, as of 12/19/05 three face—to—face "client
only" meetings will have occurred and more of such meetings are contemplated (probably
after the year—end holidays). Thus, all Counsel respectfully request that the 12/20/05
Status Conference be continued until the end of 1/06.
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Case 3:00-cv—00328-AHN Document 74 Filed 12/19/2005 Page 2 of 3
Winthrop House Association, Inc.
Brookside Elm Associates Limited Partnershqn, etal. •Joint Motion for Continuance and for a Rule 6(b)(1)
(Qnited States District Court, at Bridgeport, C TQ Enlargement of Time, dated 12/19/05
2. The reguested Enlargement of Time.
(a) The Association. The Court has previously extended until 1/17/06
the time for its service of the 2/17/00 Complaint and the 5/19/00 First Amended Complaint
on the non—appearing defendants, gg: (i) NESK Corporation; (ii) Competrol Real Estate
Limited; (iii) Olayan America Corporation; (iv) Neil H. Smith; and (v) Edmond A.
Kavounas.
(b) The appearing Defendants. The Court has previously extended
until 1/ 17/06 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 2/28/06 with regard to undertaking the matters
referred to above in Paragraphs 2(a) and (b).
3. 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.
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Case 3:00-cv—00328-AHN Document 74 Filed 12/19/2005 Page 3 of 3
Winthrop House Association, Inc.
Brookside 1‘i:lm Associates Limited Partnership, et al. •Joint Motion for Continuance and for a Rule 6(b)(1)
(Qnited States District Court, at Bridgeport, C TQ Enlargement of Time, dated 12/19/05
• Dated December 19, 2005 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
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 December 19, 2005:
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
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 v1 - Winthrop H0use.CONDOS.Joint Motion for Continuance
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