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

Case 3:03-cv-00614-AWT

Document 41

Filed 04/02/2004

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

EDWARD WINOKUR and NICHOLA WINOKUR, Plaintiffs, V.

SILVERTON MARINE CORPORATION and WILLIAM J. PETZOLD, INC., Defendants.

: : : : : : : : : : : :

CIVIL ACTION NO. 303 CV 0614 (AWT)

APRIL 2, 2004

MOTION FOR EXTENSION OF TIME TO FILE CLOSING PAPERS ON CONSENT Pursuant to Rule 7(b) of the Local Civil Rules of the United States District Court for the District of Connecticut, the plaintiffs, Edward Winokur and Nichola Winokur (collectively "Winokurs"), respectfully request an extension of time of the deadline in which to file closing papers as set forth in the Notice to Counsel Pursuant to Local Rule 41(b), dated March 3, 2004. The Winokurs request that the time for filing closing papers be extended to June 15, 2004. The Winokurs submit that there is good cause for granting an extension of time to file closing papers. The parties have reached a settlement of the abovecaptioned matter and have agreed to and finalized the terms and provisions of a settlement agreement. The parties' settlement agreement has already been executed by the Winokurs and is currently being circulated to the defendants, Silverton Marine

One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00614-AWT

Document 41

Filed 04/02/2004

Page 2 of 4

Corporation and William J. Petzold, Inc. (collectively "Defendants"), for their respective signatures. However, the terms of the parties' settlement are such that final resolution of the matter can only be realized upon the satisfaction of certain contingencies which are to occur in June 2004. Thus, the Winokurs make the instant motion so as not to be prejudiced and have the matter dismissed in the unlikely event that these conditions to final settlement are not met. Accordingly, the Winokurs request that they be allowed additional time to file closing papers, during which time there will be no activity in the above-captioned litigation. This is the Winokurs' first request for an extension with regards to this matter. Counsel for Defendants have consented to the extension. WHERFORE, the plaintiffs, Edward Winokur and Nichola Winokur, respectfully request that the Court grant an extension of the time for filing closing papers to June 15, 2004.

-2­
One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00614-AWT

Document 41

Filed 04/02/2004

Page 3 of 4

Dated: April 2, 2004 Hartford, Connecticut

RESPECTFULLY SUBMITTED, THE PLAINTIFFS, EDWARD WINOKUR AND NICHOLA WINOKUR

By:________________________ Thomas J. Finn Federal Bar No.: ct 20929 Paula Cruz Cedillo Federal Bar No.: ct 23485 HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, Connecticut 06103 (860) 522-6103

-3­
One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00614-AWT

Document 41

Filed 04/02/2004

Page 4 of 4

CERTIFICATION This is to certify that on April 2, 2004, a copy of the foregoing was mailed, postage prepaid, to:

Ben A. Solnit, Esq. Matthew A. Sokol, Esq. Tyler, Cooper & Alcorn, LLP 205 Church Street New Haven, Connecticut 06509 Attorney for Defendant, Silverton Richard D. Carella, Esq. Law Offices of Richard D. Carella 300 Plaza Middlesex Middletown, Connecticut 06457 Attorney for Defendant, Petzolds _____________________ Thomas J. Finn

534015

-4­
One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105