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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT CARLOS A. ARREDONDO, in his capacity as Trustee of The 2000 Trust for the Grandchildren of Carlos A. Arredondo and Mari V. Arredondo, General Partner of Arredondo Properties Limited Partnership, Plaintiff, CIVIL ACTION FILE v. NO. 3:02 CV 2200 (CFD) CAESAR A. ARREDONDO, individually and in his capacity as Trustee of The 2000 Trust for the Grandchildren of Caesar A. Arredondo and Carolyn Abad Arredondo; THE 2000 TRUST FOR THE GRANDCHILDREN OF CAESAR A. ARREDONDO AND CAROLYN ABAD ARREDONDO, in its capacity as General Partner of Arredondo Properties Limited Partnership; and ARREDONDO & CO., LLC, Defendants. PLAINTIFF'S THIRD UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR LEAVE TO AMEND ANSWER Plaintiff respectfully moves the Court for an additional extension of time to respond to Defendants' Motion for Leave to Amend Answer. In support of this Motion, Plaintiff shows the Court as follows: 1. 115). 2. On August 17, 2007, Plaintiff filed a motion for extension of time (Dkt. 117) to On July 27, 2007, Defendants filed a Motion for Leave to Amend Answer (Dkt. Filed: December 13, 2007
respond to Defendants' Motion for Leave to Amend Answer so that it could focus its attention on the October 30, 2007 settlement conference. The Court granted Plaintiff's motion, allowing
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Plaintiff until November 9, 2007 to respond to Defendants' Motion for Leave to Amend Answer. (Dkt. 118). 3. The October 30, 2007 settlement conference between the parties, mediated by
Judge Smith, proved productive and the parties are currently working out the terms of a settlement. 4. Plaintiff filed a second motion for extension of time on November 7, 2007 (Dkt.
122) so that the parties could continue to focus on the terms of the settlement with the assistance of Judge Smith. The Court granted Plaintiff's motion (Dkt. 123), allowing Plaintiff until December 17, 2007 to respond to Defendants' Motion for Leave to Amend Answer. 5. Though the parties are working diligently to agree on settlement terms, a final
agreement has not yet been reached. 6. To that end, the parties are planning to hold an additional settlement conference
with Judge Smith, which is in the process of being scheduled. 7. Accordingly, the parties are hopeful that this matter can be resolved in the near
future without need for further litigation between them. 8. Plaintiff requests that its time to respond to Defendants' motion be extended until
February 15, 2008, so that, in the intervening period (60 days), the parties can continue to focus their attention on attempts to settle and resolve this matter short of trial. 9. 10. Defendants have been consulted and consent to the proposed extension. This request is not submitted for the purpose of delay, and the requested
enlargement of time will not unduly delay the Court's judgment in this matter.
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WHEREFORE, Plaintiff respectfully requests that the Court grant this motion and that the deadline for Plaintiff to respond to Defendants' Motion for Leave to Amend Answer be extended to and including February 15, 2008.
Respectfully submitted, this 13th day of December, 2007. /s/ Jason D. Rosenberg MARTIN J. ELGISON (ct24759) DAVID J. STEWART (ct24757) JASON D. ROSENBERG (phv01770) ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, Georgia 30309-3424 Ph (404) 881-7000; Fx (404) 881-7777 ROBERT P. DOLIAN (ct04278) CUMMINGS & LOCKWOOD LLC Four Stamford Plaza, P.O. Box 120 Stamford, Connecticut 06904-0120 Ph (203)327-1700; Fx (203) 708-5647 Counsel for Plaintiff
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CERTIFICATE OF SERVICE I certify that on this 13th day of December, 2007, a true and correct copy of the foregoing PLAINTIFF'S THIRD UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR LEAVE TO AMEND ANSWER was served upon counsel for Defendants through the CM/ECF system: CRAIG A. RAABE EDWARD HEATH Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103 HUBERT J. SANTOS Santos & Steeley, P.C. 51 Russ Street Hartford, CT 06106 Phone: (860) 249-6548 [email protected] DAVID M. KELLY, pro hac vice Finnegan, Henderson, Farabow, Garrett & Dunner, LLP 1300 I Street, NW Washington, DC 20005-3315 Phone: (202) 408-4000 [email protected] /s/ Jason D. Rosenberg ______________________________ Jason D. Rosenberg