On April 24, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Lrc Funding, Llc,
New Era Mechanical Corporation,
and
170 Glover Avenue, Llc,
Atlantic Specialty Insurance Company,
Commingled Pension Trust Fund,
for P00 - Property - Foreclosure
in the District Court of Fairfield County.
Preview
DOCKET NO.: FST-CV23-6060966-S
------------------------------------ x
NEW ERA MECHANICAL CORPORATION, ET : SUPERIOR COURT
AL, :
: JUDICIAL DISTRICT OF
Plaintiffs,
: STAMFORD-NORWALK
- vs. - :
: AT STAMFORD
170 GLOVER AVENUE, LLC AND ATLANTIC :
SPECIALTY INSURANCE COMPANY :
(“ATLANTIC SPECIALTY”), :
: OCTOBER 10, 2023
Defendants.
------------------------------------ x
MOTION FOR EXTENSION OF TIME TO PLEAD
The Defendant, Atlantic Specialty Insurance Company hereby moves for an extension of
time up to and including November 9, 2023, in which to file a responsive pleading, as counsel
requires additional time to confirm with their client, and to continue to investigate the Plaintiff’s
claims, so that an appropriate responsive pleading can be filed.
Dated: Greenwich, Connecticut IVEY, BARNUM & O’MARA, LLC
October 10, 2023
By: /s/ Sean M. Hamill
Michael J. Jones, Esq.
Sean M. Hamill, Esq.
170 Mason Street
Greenwich, Connecticut 06830
Telephone: (203) 661-6000
Email: mjones@ibolaw.com
shamill@ibolaw.com
Attorneys for Defendant
CERTIFICATION
This is to certify that a copy of the above was or will immediately be mailed postage pre-
paid or electronically delivered on October 10, 2023 to all counsel and self-represented parties of
record and that written consent for electronic delivery was received from all counsel and self-
represented parties of record who were or will immediately be electronically served, as follows:
Thomas G. Librizzi, Esq.
McElroy, Deutsch, Mulvaney & Carpenter
One State Street
14th Floor
Hartford, CT 06103
Email: tlibrizzi@mdmc-law.com
By: /s/ Sean M. Hamill
Sean M. Hamill
Juris No.: 434010
Commissioner of the Superior Court
Document Filed Date
October 10, 2023
Case Filing Date
April 24, 2023
Category
P00 - Property - Foreclosure
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DOCKET NO.: FST-CV23-6060966-S ------------------------------------ x NEW ERA MECHANICAL CORPORATION, ET : SUPERIOR COURT AL, : : JUDICIAL DISTRICT OF Plaintiffs, : STAMFORD-NORWALK - vs. - : : AT STAMFORD 170 GLOVER AVENUE, LLC AND ATLANTIC : SPECIALTY INSURANCE COMPANY : (“ATLANTIC SPECIALTY”), : : OCTOBER 10, 2023 Defendants. ------------------------------------ x MOTION FOR EXTENSION OF TIME TO PLEAD The Defendant, Atlantic Specialty Insurance Company hereby moves for an extension of time up to and including November 9, 2023, in which to file a responsive pleading, as counsel requires additional time to confirm with their client, and to continue to investigate the Plaintiff’s claims, so that an appropriate responsive pleading can be filed. Dated: Greenwich, Connecticut IVEY, BARNUM & O’MARA, LLC October 10, 2023 By: /s/ Sean M. Hamill Michael J. Jones, Esq. Sean M. Hamill, Esq. 170 Mason Street Greenwich, Connecticut 06830 Telephone: (203) 661-6000 Email: mjones@ibolaw.com shamill@ibolaw.com Attorneys for Defendant CERTIFICATION This is to certify that a copy of the above was or will immediately be mailed postage pre- paid or electronically delivered on October 10, 2023 to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self- represented parties of record who were or will immediately be electronically served, as follows: Thomas G. Librizzi, Esq. McElroy, Deutsch, Mulvaney & Carpenter One State Street 14th Floor Hartford, CT 06103 Email: tlibrizzi@mdmc-law.com By: /s/ Sean M. Hamill Sean M. Hamill Juris No.: 434010 Commissioner of the Superior Court