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

‘ Case 3:02-cv-02234-AWT Document 98 Filed 01/15/2008 Page 1 of 3 I 1
UNITED STATES.DISTRICT COURT .
· DISTRICT OF CONNECTICUT
(HARTFORD)
I ROBERT PAYNE and PAYNE :
INVESTMENTS LLC, : CIV. ACTION NO.:
4 Plaintiffs, : 3:02C\/02234 (AWT)
v.
TAYLOR VISION RESOURCES, .
TAYLOR STRATEGIC ACQUISITIONS, :
TAYLOR STRATEGIC DIVESTITURES, : 4
and TAYLOR FINANCIAL SERVICES A : l
LLC, all defendants collectively :
operating under the name _ :
TAYLOR COMPANIES, 4 : t
Defendants. :
: JANUARY 15, 2008
MOTION FOR EXTENSION OF TIME
Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 7(b) of the
Local Rules of the United States District Court for the District of Connecticut, the Plaintiffs
Robert Payne and Payne Investments LLC (collectively, "Plaintiffs"), hereby move for an
extension of time of twenty-one (21) days to file the Joint Trial Memorandum, from the date
U that it is currently due to be tiled (January 2l, 2008), to and including February ll, 2008. In
support hereof, the Plaintiffs respectfully represent as follows:
F"' 1. The Joint Trial Memorandum is presently scheduled to be tiled by January 2l,
I 2008. I

Case 3:02-cv-02234-AWT Document 98 Filed 01/15/2008 Page 2 of 3 t
. 2. Undersigned counsel has been dealing with the discovery of cancer by a
. member of his immediate family, which included emergency surgeiy in Hartford Hospital, on
January 2nd. Because of this unexpected and unfortunate turn of events, undersigned counsel
has not been available during the past three (3) weeks to put foith the requisite amount of time
with which to complete Plaintiffs’ poition of the Joint Trial Memorandum. ·
3. Counsel for the Defendants has consented to this extension of time.
In light of this, it is respectfully submitted, that an extension of the time for
` filing the Joint Trial Memorandum be granted.
WHEREFORE, the Plaintiffs respectfully request an extension of time, to and
including Febiuary ll, 2008, by which to tile their Joint Trial Memorandum. ‘
THE PLAINTIF FS,
ROBERT PAYNE and
PAYNE INVESTMENTS LLC q
By: /s/
KEVIN W. GILLEN
` Federal Bar No.: ot0 1 502
‘ MICHAEL P. BERMAN
Federal Bar No.: ct05624
_ Berman and Sable LLC
` One Financial Plaza, 20°h Floor
Hartford, CT 06103
Tel: (860) 527-9699
· ‘ Fax: (860) 527-9077
Their Attorneys
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Case 3:02-cv-02234-AWT Document 98 Filed 01/15/2008 Page 3 of 3 l
CERTIFICATION OF SERVICE
This is to certify that on this 15th day of January, 2008, a copy ofthe foregoing
"Motion for Extension of Time" was sent by electronic tiling, or mailed, via U.S. mail, first
class, postage prepaid, on all counsel and pro se parties of record as follows:
Douglas J. Varga, Esq.
Zeldes, Needle & Cooper, P.C.
1000 Lafayette Boulevard .
Bridgeport, CT 0660l-1740
/s/
Kevin W. Gillen

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