On January 09, 2019 a
Order
was filed
involving a dispute between
Islamic American Society Of Connecticut, Inc.,
and
Abdel Hamed,
Ahmed Abdulrazak,
Ashraf Ibrahim,
Ayesha Tarar,
Hussein Ahmad,
Jane Doe,
Jawad Ashraf,
John Doe,
Kamal Rekaby,
Ossama Elawad,
Rizwan Tarar,
Sumera Ghazi,
Waterbury Islamic Cultural Center, Inc.,
William Colson,
for M00 - Misc - Injunction
in the District Court of Hartford County.
Preview
DOCKET NO. UWY-19-6045396 S : SUPERIOR COURT
: JUDICIAL DISTRICT OF
ISLAMIC AMERICAN SOCIETY : WATERBURY
OF CONNECTICUT : AT WATERBURY
PLAINTIFF :
VS. :
JAWAD ASHRAF, ET AL :
DEFENDANTS : MAY 21, 2021
MOTION FOR EXTENSION OF TIME
The counterclaim Plaintiffs move the Court for an extension of time or postponement of a
hearing and final determination on a Motion to Dismiss, Doc. 167 and 168, and Documents 105
and 106 in the companion case, Elawad v. Galal UWY-CV-21-6058848-S so that discovery can
be completed, and so that the Court can rule on Document 112, Motion to add the Islamic
American Society of Connecticut (“IASC”) as a party.
The counterclaim Plaintiffs have been pressing for compliance with discovery since
January, about 6 months. IASC has thwarted efforts to proceed with discovery and development
of evidence. The discovery on which the counterclaim Plaintiffs have been pressing is
specifically directed to issues of membership and standing on which the present Motion to
Dismiss is largely based.
Barring the counterclaim Plaintiffs from conducting thorough discovery prior to a hearing
would unfairly compromise the Counterclaim Plaintiffs’ ability to fully and fairly defend IASC’s
Motion to Dismiss, violating fundamental due process. In the companion case, adding IASC as a
party, in accordance with pending Document 112, Motion to Cite in IASC, as was permitted in
Colson v. Galal, will promote efficiency and prevent piecemeal litigation.
WHEREFORE, prior to scheduling any hearing and prior to a final determination, the
counterclaim Plaintiffs respectfully request permission to proceed with and complete discovery
and be heard on pending discovery motions so that they can address the jurisdictional challenges
asserted in Documents 167 and 168, and in Documents 105 and 106 in the companion case of
Elawad v. Galal. They further seek an extension of time for scheduling a hearing and final
determination on a motion to dismiss until the Motion to Cite in IASC as a party is heard and
decided in Elawad v. Galal.
Following a determination on adding IASC as a party in Elawad v. Galal, and following
the completion of all necessary discovery, the counterclaim Plaintiffs furthermore seek leave to
supplement their memorandum of law in support of their objections to Documents 167 and 168
and Documents 105 and 106 in the companion case of Elawad v. Galal.
FOR THE DEFENDANTS AKA
CONTERCLAIM PLAINTIFFS
Mr. Ossama Elawad et al
/400893/
By:______________________________
MERYL ANNE SPAT, ESQ.
Attorney for the Plaintiffs
27 First Ave.
Waterbury CT 06710
Telephone 203.805 8256
Facsimile 866 979-0939
Juris No. 400893
2
CERTIFICATION
On May 21, 2021, the foregoing document was filed electronically and served by mail on
anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties
by operation of the Court's electronic filing system or by mail to anyone unable to accept
electronic filing as indicated on the Notice of Electronic Filing. Partiers may access this filing
through the Court's electronic filing System.
Attorney Refai Arefin
Law Office of Refai Arefin, LLC
1224 Mill St. Bldg B
East Berlin CT 06023
refai@rarefinlaw.com
Jonathan A. Kaplan, Esq.
90 Statehouse Square
Hartford CT 06103-3702
T 860 424 4300
F 860 424 4370
JKaplan@pullcom.com
Attorney Keith Rudzik
Howard Kohn Sprague & Fitzgerald
PO Box 261798
Hartford CT 06126
krr@hksflaw.com
By:________/04575/__________________
MERYL ANNE SPAT
3
Document Filed Date
May 21, 2021
Case Filing Date
January 09, 2019
Category
M00 - Misc - Injunction
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in Hartford County
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DOCKET NO. UWY-19-6045396 S : SUPERIOR COURT : JUDICIAL DISTRICT OF ISLAMIC AMERICAN SOCIETY : WATERBURY OF CONNECTICUT : AT WATERBURY PLAINTIFF : VS. : JAWAD ASHRAF, ET AL : DEFENDANTS : MAY 21, 2021 MOTION FOR EXTENSION OF TIME The counterclaim Plaintiffs move the Court for an extension of time or postponement of a hearing and final determination on a Motion to Dismiss, Doc. 167 and 168, and Documents 105 and 106 in the companion case, Elawad v. Galal UWY-CV-21-6058848-S so that discovery can be completed, and so that the Court can rule on Document 112, Motion to add the Islamic American Society of Connecticut (“IASC”) as a party. The counterclaim Plaintiffs have been pressing for compliance with discovery since January, about 6 months. IASC has thwarted efforts to proceed with discovery and development of evidence. The discovery on which the counterclaim Plaintiffs have been pressing is specifically directed to issues of membership and standing on which the present Motion to Dismiss is largely based. Barring the counterclaim Plaintiffs from conducting thorough discovery prior to a hearing would unfairly compromise the Counterclaim Plaintiffs’ ability to fully and fairly defend IASC’s Motion to Dismiss, violating fundamental due process. In the companion case, adding IASC as a party, in accordance with pending Document 112, Motion to Cite in IASC, as was permitted in Colson v. Galal, will promote efficiency and prevent piecemeal litigation. WHEREFORE, prior to scheduling any hearing and prior to a final determination, the counterclaim Plaintiffs respectfully request permission to proceed with and complete discovery and be heard on pending discovery motions so that they can address the jurisdictional challenges asserted in Documents 167 and 168, and in Documents 105 and 106 in the companion case of Elawad v. Galal. They further seek an extension of time for scheduling a hearing and final determination on a motion to dismiss until the Motion to Cite in IASC as a party is heard and decided in Elawad v. Galal. Following a determination on adding IASC as a party in Elawad v. Galal, and following the completion of all necessary discovery, the counterclaim Plaintiffs furthermore seek leave to supplement their memorandum of law in support of their objections to Documents 167 and 168 and Documents 105 and 106 in the companion case of Elawad v. Galal. FOR THE DEFENDANTS AKA CONTERCLAIM PLAINTIFFS Mr. Ossama Elawad et al /400893/ By:______________________________ MERYL ANNE SPAT, ESQ. Attorney for the Plaintiffs 27 First Ave. Waterbury CT 06710 Telephone 203.805 8256 Facsimile 866 979-0939 Juris No. 400893 2 CERTIFICATION On May 21, 2021, the foregoing document was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Partiers may access this filing through the Court's electronic filing System. Attorney Refai Arefin Law Office of Refai Arefin, LLC 1224 Mill St. Bldg B East Berlin CT 06023 refai@rarefinlaw.com Jonathan A. Kaplan, Esq. 90 Statehouse Square Hartford CT 06103-3702 T 860 424 4300 F 860 424 4370 JKaplan@pullcom.com Attorney Keith Rudzik Howard Kohn Sprague & Fitzgerald PO Box 261798 Hartford CT 06126 krr@hksflaw.com By:________/04575/__________________ MERYL ANNE SPAT 3