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

Case 3:02-cv-02008-SRU

Document 72

Filed 10/21/2004

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

x
THOMAS SABELLAand KARENSABELLA, Plaintiffs,
-againstNORTHEAST GENERATION SERVICES COMPANY and NORTHEAST UTILITIES, Defendants.

Civil
No.

Action
3:02

Docket
(SRU)

CV 2008

x

MOTION FOR EXTENSION OF DEADLINE Pursuant Rule 7(b), for the the to Federal plaintiffs dismissal Rule of Civil move the Procedure for an 6(b) extension and of matter Local the for

hereby date of

deadline the

above-captioned

following The present

reasons: deadline to fact Local settled and fifty plaintiffs. for Rule this the dismissal is of the above-captioned 21, of 2004. the The total by the

action parties sum of

pursuant have in

41(b), action

October for

payment

one hundred to the

thousand Both Releases, held in

dollars the and escrow plaintiffs a

($150,000.00)

defendants have

and defendants of parties' of for and the the Voluntary counsel proceeds. clearance that

executed which of

General are the being

Notice by the

Dismissal,

upon clearance Plaintiffs' of the

settlement Harry

check

and receipt is waiting

counsel, settlement will

J. Nicolay, tendered bank by

check clear the

defendants, October

expects 2004.

such

check

by Tuesday,

26,

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Case 3:02-cv-02008-SRU

Document 72

Filed 10/21/2004

Page 2 of 4

Accordingly, dismissal October clearance date 26,

the plaintiffs in this in action order

request be extended, to allow

that

the deadline

for

the to the

from October adequate

21,2004 for

2004,

for

time

of the

settlement counsel

check and receipt has spoken who has
time. request

of the proceeds. Ann to H. the Rubin, Esq.,

Plaintiffs' counsel
request

with agreed

for
for

the

defendants,
of

plaintiffs'

an extension have

The plaintiffs time the in this regard

made no prior anticipate

for

an extension extensions

of of

and do not

any further

deadline.

ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Dated:

White Plains, New York October 20, 2004 COLLIER, HALPERN, NEWBERG,NOLLETTI
&

BOCK, LLP
s or Plaintiffs Nicola, Jr. (CT24875)

Attorne By:

Har

.

A Me er of th Firm One North Lexington Avenue White Plains, NY 10601 Telephone: (914) 684-6800 Facsimile: (914)684-6986

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Case 3:02-cv-02008-SRU

Document 72

Filed 10/21/2004

Page 3 of 4

To:

Ann H. Rubin, Esq. Carmody & Torrance LLP 50 Leavenworth Street, P.O. Box 1110 Waterbury, Connecticut 06721-1110 Duncan R. MacKay, Esq. Northeast Utilities Service Company P.O. Box 270 Hartford, Connecticut 06141-0270

3

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Case 3:02-cv-02008-SRU

Document 72

Filed 10/21/2004

Page 4 of 4

CERTIFICATE

OF SERVICE

This is to certify that a copy of the foregoing Motion For Extension of Deadline has been served upon the following counsel of record by depositing a true copy thereof in a properly addressed wrapper, deposited in an official depository of -- an overnight courier service -- Federal Express, located at One North Lexington Avenue, White Plains, New York 10601, marked for overnight delivery, prior to the latest time designated by Federal Express for overnight delivery, with signature of receipt requested, this 20th day of October, 2004.

To:

Ann H. Rubin, Esq. Carmody & Torrance LLP 50 Leavenworth Street, P.O. Box 1110 Waterbury, Connecticut 06721-1110

Duncan R. MacKay, Esq. Northeast Utilities Service Company P.O. Box 270 Hartford, Connecticut 06141-0270

Courtesv

CODV (Via

Facsimile

- 203-579-5704):

Chambers, Honorable Stefan R. Underhill U.S. District Judge U.S. District Court, District of Connecticut 915 Lafayette Boulevard, 4th Floor Bridgeport, Connecticut 06604

Ha

Jr.

(CT24875)

I *-c,