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

Case 3:02-cv-01752-CFD Document 25 Filed 04/29/2004 Page 1 of 3
DE ORCHIS & PARTNERS, LLP e- , as
24 Hoyt Street Fs E ®
Stamford, Connecticut 06905
(203) 323-9120 ZUUII AFI? 29 A II= I8
Attorneys for Plaintiff 'lfi., {15f‘f’,‘lf,§f§,i,;1f3_lr ziztr t
Joseph Palmieri U `--i Q 5 Ti I.
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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JOSEPH PALMIERI,
Plaintiff, W
02 CIV. 1752 (CFD)
- against -
KEN HALL & ASSOCIATES, INC. d/b/a
SPORT CRAFT BOATS, SPORT CRAFT
MARINE, SPORT CRAFT, INC., ROBERTS
ACQUISITION CORPORATION and STONE ,
HARBOR MARINA, I
I
Defendants.
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PLAINTIFF'S MOTION FOR EXTENSION OF TIME BY
WHICH TO CONSUMMATE SE'I'l'LEI\r1E_NT
Plaintiff, JOSEPH PALMIERI (hereinafter referred to as the "PLAINTIFF"), by and
through his undersigned attorneys, De Orchis & Partners, LLP, respectfully moves for a two
(2) week extension of time by which to complete the settlement in this matter and in support ,
of the same states as follows:
1. On March 29, 2004, the plaintiff and only appearing defendant, Stone Harbor
Marina ("Stone Harbor"), agreed to an amicable resolution of this matter in exchange for
certain consideration.

.... . .... .2. AA.,,, “_ -. -..-..... |
Case 3:02-cv-01752-CFD Document 25 Filed 04/29/2004 Page 2 of 3 (
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2. Thereafter, the plaintiff provided Stone I-larbor's counsel with a proposed
settlement agreement for which the undersigned has yet to receive any comments much less
an executed original.
3. In foIIow—up, the undersigned has telephoned and faxed Stone I-larbor's counsel
l
but has yet to receive a response. Today, the undersigned, for the first time, spoke to Stone (
I-larbor's counsel's assistant who explained that Stone Harbor's counsel was in trial.
4. The undersigned has no reason to believe that the amicable settlement has
failed and believes additional time is required to accommodate Stone Harbor's counsel's
schedule.
Accordingly, the plaintiff respectfully requests that the Court refrain from dismissing this
matter for an additional two (2) weeks up to and including May 13, 2004. The plaintiff will
advise the Court as soon as the settlement documents and funds are exchanged. i
Dated: Stamford, Connecticut
April 28, 2004
DE ORCHIS & PARTNERS, LLP
Attorneys for PIai
y:
John K. FuIw ` er (CT-24765) l
=·- Orchis & Pa ers, LLP )
24 O - ‘ ‘ 5
Stamford, Connecticut i
(203-323-9120) `
Our File: 2113-1 \
TO: Steven G.l\A. Biro, Esq. (
291 Vine Road
Stamford, CT 06905-2106 |
Attorneys for Stone Harbor ll/larina
l
l
i

I I
Case 3:02-cv-01752-CFD Document 25 Filed 04/29/2004 Page 3 of 3 E
DECLARATION OF SERVICE BY MAILI

I
Linda Salerno, declares that: I
I am not a party to this action, am over 18 years of age, and reside in Staten Island,
New York. I am a secretary for De Orchis 8. Partners, LLP, the attorneys for the within I
named Plaintiff, with offices at 61 Broadway, 26th Floor, New York, New York 10006. I
On April 28, 2004, I served upon:
Steven G.M. Biro, Esq.
291 Vine Road
Stamford, CT 06905-2106 I
Attorneys for Stone Harbor Marina I
PLAINTIFF’S MOTION FOR EXTENSION OF TIME BY WHICH TO I
CONSUMMATE SETTLEMENT I
· I
by depositing the same in a sealed and postage prepaid wrapper, in a post-office or
official depository of the U.S. Postal Service within the State of New York, addressed to I
the last known address of the addressee(s) as indicated above.
l declare under penalty of periury that the foregoing is true and correct.
Executed on April 28, 2004.
I
. .iar’ A I I
Linda Ierno
/
I
._.____m__,_,a ____________________ _ I