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

Case 3:00-cv—00328-AHN Document 67 Filed 10/26/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
At Bridgeport
WINTHROP I-IOUSE ASSOCIATION, INC. :
Plaintiff : CIVIL ACTION NO.
: 3-00-CV-328(AHN)
vs. :
BROOKSIDE ELM ASSOCIATES
LIMITED PARTNERSHIP, ET AL : OCTOBER 26, 2005
Defendants :
STIPULATED RULE 6gb)g1) MOTION FOR ENLARGEMENT OF TIME
In accordance with Rule 6(b)(l) of the Federal Rules of Civil Procedure and Local Rule 9,
Preiss Breismeister, P.C. and Frederick A. Preiss, defendants in the above-referenced action,
respectfully move for an enlargement of time until forty five (45) days from the date of this motion to
December 12, 2005. This enlargement of time is requested in order to permit the appearing defendants
sufficient time to prepare a responsive pleading. The present matter has been stayed (since
approximately 2001) to a date thirty (30) days past the completion of mediation proceedings. The
parties participated in several mediation sessions, as well as extensive briefing and oral argument in
cormection with certain advisory opinions sought. The final mediation session concluded on
September 26, 2005.
41s92s

Case 3:00-cv—00328-AHN Document 67 Filed 10/26/2005 Page 2 of 3
As a result of this stay, and the span of 4 years between mediation sessions, no scheduling
order has been finalized in this case. A status conference is scheduled for November 2, 2005, at which
time deadlines for pleading, discovery and other issues contemplated under Rule 26(O may be
determined.
In addition, the counsel for plaintiff, Philip H. Bartels, and counsel for Brookside Elm
Associates Limited Partnership, Collins Properties, LLC, Collins Enterprises, LLC, and Arthur Collins
II, Jane I. Milas have no objection to this Motion.
Based on the foregoing, defendants Preiss Breismeister, P.C. and Frederick A. Preiss,
respectfully submit that good cause exists for this Court to grant their Motion for Enlargement of
Time.
Respectfully submitted,
DEFENDANTS,
PREISS BREISMEISTER, P.C.
and FREDERICK A. PREISS
y¤ ’ //
. . IGHELLO, JR., ESQ.
Federal r Number ct17521
Updi e, Kelly & Spellacy, P.C.
One State Street
Hartford, CT 06123-1277
Tel. (860) 548-2600
4l3925 2

Case 3:00-cv—00328-AHN Document 67 Filed 10/26/2005 Page 3 of 3
CERTIFICATION OF SERVICE
A copy ofthe foregoing has been mailed by first class mail, postage prepaid, this 26th day of
October, 2005 to:
Philip H. Bartels, Esq.
Shipman & Goodman, LLP
289 Greenwich Avenue
Greenwich, CT 06830
Jane I. Milas, Esq.
Garcia & Milas
44 Trumbull Street
New Haven, CT 06510-l00l gg N

\ I ';_ ,
’ IC · ‘iI M. DIGHELLO, JR., ESQ.
sri - ly & Spellacy, P.C.
41392s 3