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`M&T BANK
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`PAYNE, SIMEON, ET AL
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`SUPERIOR COURT
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`J.D. OF STAMFORD/NORWALK
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`AT STAMFORD
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`MAY 9, 2019
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`MOTION FOR EXTENSION OF TIME TO PLEAD AND TO RESPOND
`TO PLAINTIFF’S DEMAND FOR DISCLOSURE OF DEFENSE
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`The defendants, Simeon Payne and Pamela A. Payne (“Defendants”), and undersigned counsel
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`hereby request, pursuant to Practice Book § 10-1, et seq., for a thirty (30) day extension of time up to
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`and including May 9, 2019, within which to file a responsive request, motion, or pleading in response to
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`the Plaintiff’s Complaint and to respond to the Plaintiff’s Demand for Disclosure of Defense. The
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`present action was commenced with a return date of February 12, 2019, which reflects that the case is
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`relatively new.
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`The extension of time requested is appropriate in order to permit the undersigned counsel and the
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`Defendants to fully and fairly respond to the Plaintiff’s Complaint and to ascertain whether any viable
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`defenses exist. The undersigned counsel was retained in March, yet has been focused primarily on
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`resolving purported discrepancies in reinstatement amounts provided by the Plaintiff. The Defendants
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`just received an updated reinstatement amount within the last week that was requested over a month ago
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`in an effort to resolve this without protracted litigation. The Defendants fully intend on reinstating,
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`however, would like the additional time to review itemized amounts in the Reinstatement provided and
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`to cross-reference that with an escrow analysis also recently provided by Plaintiff. This is the first
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`motion for an extension of time to plead and to respond to the Demand for Disclosure of Defense. This
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`matter has not yet been assigned for trial.
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`WHEREFORE, the Defendants move for an extension of time up to and including June 9, 2019
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`to file a responsive request, motion, or pleading to the Plaintiff’s complaint and to respond to the
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`Plaintiff’s Demand for Disclosure of Defense, if necessary in light of the Defendant’s intentions with
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`reinstatement.
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`THE DEFENDANTS,
`SIMEON PAYNE AND PAMELA A. PAYNE
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`By: /s/ Joshua Pedreira
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`Joshua Pedreira, Esq.
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`Cohen and Wolf, P.C.
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`657 Orange Center Road
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`Orange, CT 06477
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`(203) 368-0211
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`Fax: 203-337-5544
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`Email: jpedreira@cohenandwolf.com
` Juris No. 010032
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`ORDER
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`The foregoing Motion for Extension of Time, having been duly heard, it is hereby ordered:
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`GRANTED / DENIED.
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`The Court,
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`By:
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`CERTIFICATION
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`I hereby certify that a copy of the above was mailed on the date hereof by postage prepaid, U.S. mail or
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`via electronic delivery to parties consenting to same, to the following addresses on May 9, 2019:
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`BENDETT & MCHUGH PC
`270 FARMINGTON AVENUE
`SUITE 151
`FARMINGTON, CT 06032
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` /s/ Joshua Pedreira
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`Joshua Pedreira, Esq.
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