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

Case 3:01-cv-02158-WWE

Document 172

Filed 08/08/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DONALD WAINRIGHT, ET AL., Plaintiffs, v. OSM COMMUNICATIONS, INC., ET AL., Defendants. : : : : : : : : :

CIVIL ACTION NO. 3:01-CV-02158 (WWE)

AUGUST 8, 2006

MOTION FOR EXTENSION OF TIME

Defendants OSM Communications, Inc. and Robert E. Polansky move for an extension of time to file their Pre-trial Memorandum currently due on August 14, 2006 to September 30, 2006 and a three month adjournment of the trial in this matter which is currently scheduled to commence the week of September 11, 2006. The request is made at this time due to the fact that the pre-trial settlement conference is scheduled to take place on Friday August 11, 2006, the parties have engaged in good faith discussions to resolve the disputes between them and there is a reasonable possibility that a settlement can be reached with the assistance and involvement of Magistrate Holly Fitzsimmons.

I have spoken with both Michael Culkin, Esq., plaintiffs' counsel and J. Michael Sulzbach, Esq., defendant Israel Polansky's counsel, and both attorneys have expressed not only their consent but join in this application for the requested extension of time to serve the pre-trial memoranda and adjournment of the scheduled trial of the matter.

Case 3:01-cv-02158-WWE

Document 172

Filed 08/08/2006

Page 2 of 2

DEFENDANT OSM COMMUNICATIONS, INC. ROBERT E. POLANSKY By: _______________________________ Michael P. Goldsmith Attorney for Defendants OSM Communications, Inc. and Robert E. Polansky 21 East 40th Street ­ 22nd Floor New York, NY 10016 Telephone: (212) 292-2000 Fed. Bar No. phv0219 [email protected]
Michael P. Goldsmith
Digitally signed by Michael P. Goldsmith DN: cn=Michael P. Goldsmith, c=US, o=Michael P. Goldsmith, Esq., email=michael.p.goldsmith@verizon. net Date: 2006.08.08 16:26:31 -04'00'

CERTIFICATE OF SERVICE

This is to certify that on this 8th day of August 2006, a copy of the foregoing motion was served electronically by sending it to: Michael J. Culkin, Esq. Attorney for Plaintiffs Law Offices of Jason L. McCoy, LLC 280 Talcottville Road Vernon, CT 06066 [email protected] J. Michael Sulzbach, Esq. Attorney for defendant Israel Polansky 385 Orange Street New Haven, CT 06511 [email protected]
Michael P. Goldsmith
Digitally signed by Michael P. Goldsmith DN: cn=Michael P. Goldsmith, c=US, o=Michael P. Goldsmith, Esq., [email protected] Date: 2006.08.08 16:26:49 -04'00'

_____________________________ Michael P. Goldsmith, Esq.