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

Case 3:02-cv-022%.:AWT Document 93 Filed 1 1/ J2/2007 Page 1 of 3 m
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L U UNITED STATES DISTRICT COURT I
. DISTRICT OF CONNECTICUT _
(HARTFORD)
ROBERT PAYNE and PAYNE 1 I . ‘ ,
INVESTMENTS LLC, : CIV. ACTION NO.: I _
Plaintiffs, : 3:02CV02234 (AWT)
TAYLOR VISION RESOURCES, A
TAYLOR STRATEGIC ACQUISITIONS, :
TAYLOR STRATEGIC DIVESTITURES, : ;
and TAYLOR FINANCIAL SERVICES :.
LLC, all defendants collectively : _
operating under the name : A .
_ TAYLOR COMPANIES, :
Defendants. :
: NOVEMBER l2, 2007 `
JOINT 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"), and defendants Taylor
Vision Resources, Taylor Strategic Acquisitions, Taylor Strategic Divestitures and Taylor
Financial Services, LLC, (collectively, "The Taylor Companies" or "Defendants"), hereby_
move for an extension of time of forty—five (45) days to file their Joint Trial Memorandum,
from the current date of the scheduled settlement conference (December 6, 2007), to and
including January 21, 2008. In support hereof, the parties respectfully represent as follows:
'L mamvmm AND SABLE u.c
om; FINANCIAL PLAZA, HARTFORD, cowmzcrncur 06102
(9901527-9699 · Jums No. 02.940

ase 3:02-cv-O22?4—AWT Document 93 Filed 1 1/{-2/2007 Page 2 of 3 `
I 1. I The settlement conference is scheduled for December 6, 2007.
l 2. The Joint Trial Memorandum is presently scheduled to be filed by November
l5, 2007. ‘
3. In participating in the above-referenced settlement conference, the parties are
committed to directing all of the time and effort; they will expend on this case toward a
resolution of their dispute. Inlight of this, it is respectfully submitted, that an extension of the
time for tiling the Joint Trial Memorandtun be granted.
WHEREFORE, the parties respectfully request an extension of time, to and including
_ January 21, 2008, by which to file their Joint Trial Memorandtun.
THE PLAINTIFFS, _ A i
ROBERT PAYNE and I
PAYNE INVESTMENTS LLC
By: /s/
MICHAEL P. BERMAN
Federal Bar No.: ct05624
JOSE A. AGUIAR
Federal Bar No.: ct24658
Bennan and Sable LLC _
One Financial Plaza, 20th Floor
Hartford, CT 06103
Tel: (860) 527-9699 »
Fax: (860) 527-9077
Their Attorneys
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ase 3:O2—cv-O22(34—AWT Document 93 Filed 1 14,12/2007 Page 3 of 3 \
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I I I I THE DEFENDANTS, »
THE TAYLOR COMPANIES
‘ By: /s/ ‘
DOUGLAS J. VARGA ‘
Federal Bar No.: ct18885 - I
I SARAH W. POSTON
Federal Bar No.: ct19702
t ZELDES, NEEDLE & COOPER, P.C.
1000 Lafayette Boulevard ‘
Bridgeport, CT 06601-1740
CERTIFICATION OF SERVICE
This is to certify that on this 12th day of November, 2007, a copy of the foregoing
I "Joint 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: I
David Crystal, II, Esq. I
. James P. Donohue, Jr., Esq.
Crystal & Donohue _
708 Third Avenue, 26th Floor
NewYork, New York 10017 » . _
Jacob A. Stein, Esq. ‘
Stein, Mitchell & Mezines
1100 Connecticut Avenue, N.W. _
Washington, D.C. 20336
/s/ “
Michael P. Bennan
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