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

Case 3:00-cv-00328-AHN

Document 66

Filed 10/25/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

WINTHROP HOUSE ASSOCIATION, INC., Plaintiff, v. BROOKSIDE ELM ASSOCIATES LIMITED PARTNERSHIP, NESK CORPORATION, COMPETROL REAL ESTATE LIMITED, OLAYAN AMERICA CORPORATION COLLINS ENTERPRISES, LLC, COLLINS PROPERTIES, LLC, PREISS/BREISMEISTER P.C., NEIL H. SMITH, EDMOND A. KAVOUNAS, ARTHUR COLLINS II, FREDERICK A. PREISS, and COLLINS CLOSE, LLC, Defendants.

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Civil Action No. 300-CV-328 (AHN)

October 25, 2005

MOTION FOR EXTENSION OF TIME The defendants, Brookside Elm Associates Limited Partnership, Collins Properties, LLC, Collins Enterprises, LLC, Collins Close, LLC and Arthur Collins II, pursuant to Rule 7(b), Local

Case 3:00-cv-00328-AHN

Document 66

Filed 10/25/2005

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Rules Civ. Pro., respectfully request a forty-five (45) day extension of time, until December 12, 2005, to file their answer or motion addressed to the Complaint. The present matter has been stayed to a date thirty (30) days past the completion of mediation proceedings. The parties participated in several mediaton sessions, as well as extensive briefing and oral argument in connection with certain advisory opinions sought. The final mediation session concluded on September 26, 2005. As a result of the stay, there has been no scheduling order finalized with respect to this case. A status conference is scheduled in this matter for November 2, 2005. The defendants seek this extension of time so that a schedule of deadlines for pleading, discovery, and other issues contemplated under Rule 26(f) now may be determined at the status conference. This is the defendants' second request for an extension of time with respect to this same limitation. Plaintiff's counsel does not object to this request for extension of time.

Case 3:00-cv-00328-AHN

Document 66

Filed 10/25/2005

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THE DEFENDANTS BROOKSIDE ELM ASSOCIATES LIMITED PARTNERSHIP COLLINS PROPERTIES, LLC COLLINS ENTERPRISES, LLC ARTHUR COLLINS, II COLLINS CLOSE, LLC ___________/s/___________________ Jane I. Milas Garcia & Milas, P.C. 44 Trumbull Street New Haven, CT 06510 Tel. (203) 773-3824 Facsimile (203) 782-2312 Email: [email protected] Federal Bar No. ct01271

Case 3:00-cv-00328-AHN

Document 66

Filed 10/25/2005

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CERTIFICATION I hereby certify that on October 25, 2005 a copy of Defendants' Motion for Extension of Time was filed electronically to all parties of record. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

___________/s/___________________ Jane I. Milas