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

Case 3:03-cv-00056-WWE

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Filed 12/04/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DAVID E. CHARDAVOYNE, Plaintiff, V. THAMES WATER HOLDINGS INCORPORATED and THAMES WATER NORTH AMERICA, INC., Defendants. : : : : : : : : : : :

No. 03-CV-56 (WWE)

December 4, 2003

MOTION ON CONSENT FOR EXTENSION OF TIME TO FILE MOTION TO DISMISS The defendants Thames Water Holdings Incorporated and Thames Water North America, Inc. move for an extension of time, to and including January 9, 2004, to file a motion to dismiss or transfer addressed to the Amended Complaint in this matter. In support of this motion, counsel for defendants represents as follows: 1. At a status conference on November 19, 2003, the Court (Fitzsimmons,

Magistrate-Judge) stated that: a. The Court would deny as moot, in light of the filing of the Amended

Complaint, the pending Motion to Dismiss filed by defendant Thames Water Holdings Incorporated and addressed to the original Complaint in this action; and b. Defendants would be permitted to file a motion to dismiss or

transfer addressed to the Amended Complaint, no later than December 12, 2003. 2. At the status conference, the Court also scheduled a settlement

conference, to be held on December 17, 2003.

Case 3:03-cv-00056-WWE

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3.

In order to avoid the possible waste of the parties' resources, defendants

seek to extend their deadline to file a motion to dismiss or transfer until after the settlement conference (and after the subsequent holidays). 4. 5. This is the first motion for an extension of time addressed to this deadline. Counsel for plaintiff has consented to the granting of this motion.

WHEREFORE, defendants request that their deadline for filing a motion to dismiss or transfer addressed to the Amended Complaint in this action be extended to January 9, 2004. Respectfully submitted, ________________________ Jonathan B. Orleans (ct05440 Zeldes, Needle & Cooper, P.C. 1000 Lafayette Blvd., Suite 500 Bridgeport, CT 06604 Tel: (203) 333-9441 Fax: (203) 333-1489 e-mail: [email protected] Attorney for Defendants

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Case 3:03-cv-00056-WWE

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CERTIFICATION This is to certify that a copy of the foregoing has been sent via U.S. First Class Mail, postage prepaid, on this date, to: James R. Hawkins II, Esq. Finn, Dixon & Herling LLP One Landmark Sq., Suite 1400 Stamford, CT 06901-2689 Dated at Bridgeport, Connecticut on this day of December, 2003. ________________________ Jonathan B. Orleans

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