Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:02-cv-02200-CFD

Document 117

Filed 08/17/2007

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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 UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR LEAVE TO AMEND ANSWER Plaintiff respectfully moves the Court for an 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. On July 27, 2007, Defendants filed a Motion for Leave to Amend Answer. Filed: August 17, 2007

Plaintiff's response to the motion is due on or before August 17, 2007. 2. The parties are currently scheduled for a settlement conference before Judge

Smith on October 30, 2007. The parties are hopeful that this matter can be resolved at or before the conference without need for further litigation between them.

Case 3:02-cv-02200-CFD

Document 117

Filed 08/17/2007

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3.

Plaintiff requests that its time to respond to Defendants' motion be extended until

ten days after the settlement conference, or until November 9, 2007, so that, in the intervening period, Plaintiff can focus its attention on attempts to settle and resolve this matter short of trial. 4. 5. Defendants have been consulted and consent to the proposed extension. Plaintiff has not previously requested an extension to the deadline for the filing of

its response to Defendants' motion. 6. 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. Accordingly, 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 November 9, 2007. Respectfully submitted, this 17th day of August, 2007.

/s/ DAVID J. STEWART 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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Case 3:02-cv-02200-CFD

Document 117

Filed 08/17/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on this 17th day of August, 2007, a true and correct copy of the foregoing PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR LEAVE TO AMEND ANSWER was served upon counsel for Defendants, by the manner indicated, addressed as follows: Craig A. Raabe (First Class Mail) ROBINSON & COLE LLP 280 Trumbull Street Hartford, CT 06103 _/s David J. Stewart__________________ David J. Stewart

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