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

Case 3:02-cv-02234-AWT

Document 87

Filed 05/03/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT (HARTFORD) ROBERT PAYNE and PAYNE INVESTMENTS LLC,

CIV. ACTION NO.: 3:02CV02234 (AWT)

Plaintiffs, v. TAYLOR VISION RESOURCES, TAYLOR STRATEGIC ACQUISITIONS, TAYLOR STRATEGIC DIVESTITURES, and TAYLOR FINANCIAL SERVICES LLC, all defendants collectively operating under the name TAYLOR COMPANIES, Defendants. MAY 3, 2007 PLAINTIFFS' MOTION FOR EXTENSION OF TIME Pursuant to Rule 6(b) of the Federal Rules of CiviI 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 oftime of fourteen (14) days, to and including May 21,2007, to file ajoint proposed scheduling order. In support hereof, Plaintiffs respectfully represent as follows: 1. On May 3,2007, by telephone, Plaintiffs' counsel inquired of Sarah W.

: :

Poston, Esq., counsel for the Defendants, as to Attorney Poston's position on the instant

BERMAN AND SABLE LLC ONE FINANCIAL PLAZA, HARTFORD, CONNECTICUT (860) 527-9699 . JURIS NO. 03840

06103

Case 3:02-cv-02234-AWT

Document 87

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Motion, and on May 3,2007, by telephone, Attorney Poston consented to the extension of time sought herein. 2.
The conference pursuant to Fed.R.Civ.P. 26(f) occurred on November 11, and February 6,2004 and a report pursuant to Rule 26(f) was

2003, and on January 21,22,23

filed with this Court on February 27, 2004. The dates agreed upon by counsel at that time

have now elapsed. The Court has asked that the parties submit a joint proposed scheduling order. Thus, new dates must now be agreed upon by counsel in order to submit a joint
proposed scheduling order. 3. Counsel for Plaintiffs (Michael P. Berman and Jose A. Aguiar) just

recently filed their appearances on behalf of Plaintiffs (on April 24, 2007 and April 26, 2007, respectively). 4. In addition, counsel for Plaintiffs just recently obtained the file and boxes of

documents, transcripts, pleadings and materials from previous counsel for the Plaintiffs and has only recently started to review said file. 5.

This request for an extension of time is necessary for Plaintiffs' counsel to

review and analyze the necessary documents to become familiar with the case, to confer with the Plaintiff regarding potential discovery to undertake, to confer with defense counsel regarding remaining discovery, and in turn to properly assess proposed dates that are reasonable and realistic. Consequently, the undersigned does not yet have the required

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ONE FINANCIAL BERMAN PLAZA,

AND SABLE LLC
HARTFORD,

(860) 527-9699

.

CONNECTICUT

06103

JURIS NO. 03840

Case 3:02-cv-02234-AWT

Document 87

Filed 05/03/2007

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knowledge of the case in order to discuss dates with Defendants' counsel in order to submit a
joint proposed scheduling order. 6.

This is Plaintiffs' first request for an extension of time to file a revised joint

proposed scheduling order. WHEREFORE, the Plaintiffs respectfully request an extension of time, to and
including May 21,2007, by which to file a joint proposed scheduling order.

THE PLAINTIFFS, ROBERT PAYNE and PAYNE INVESTMENTS

LLC

By:

Isl MICHAELP. BERMAN Federal Bar No.: ct05624 JOSE A. AGUIAR Federal Bar No.: ct24658 Berman 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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BERMAN AND SABLE LLC

ONE FINANCIAL PLAZA, HARTFORD, CONNECTICUT 06103 (860) 527-9699 . JURIS NO. 03840

Case 3:02-cv-02234-AWT

Document 87

Filed 05/03/2007

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CERTIFICATION OF SERVICE
This is to certify that on this 3rd day of May, 2007, a copy of the foregoing "Plaintiffs' Motion for Extension of Time" was sent by electronic filing 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. Sarah W. Poston, Esq. Jacob D. Zeldes, Esq. Zeldes, Needle & Cooper, P.c. 1000 Lafayette Boulevard Bridgeport, CT 06601-1740 David Crystal, II, Esq. James P. Donohue, Jr., Esq. Crystal & Donohue 708 Third Avenue, 26thFloor New York, New York 10017
Jacob A. Stein, Esq. Stein, Mitchell & Mezines 1100 Connecticut Avenue, N. W. Washington, D.C. 20336

/s/ Michael P. Berman

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BERMAN AND SABLE LLC ONE FINANCIAL PLAZA, HARTFORD, CONNECTICUT (860) 527-9699 . JURIS NO. 03840 06103