Sanborn v Viridian Class Action Extension

1. UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
LORI SANBORN, BDK ALLIANCE LLC,
IRON MAN LLC, STEPHANIE SILVER,
DAVID STEKETEE, SUSANNA MIRKIN,
BORIS MIRKIN, ELIZABETH
HEMBLING, PATRICIA KULESA,
STEWART CONNARD and STEVEN
LANDAU on behalf of themselves and all
others similarly situated,
Plaintiffs,
v.
VIRIDIAN ENERGY, INC. and
VIRIDIAN ENERGY PA, LLC,
Defendants.
No: 3:14-cv-01731 (SRU)
CONSENT MOTION FOR EXTENSION OF TIME
Pursuant to Rule 7(b)(2) of the Local Rules of Civil Procedure, Defendants Viridian
Energy, Inc. and Viridian Energy PA, LLC (collectively “Viridian”), by and through the
undersigned counsel, and with the consent of Plaintiffs, respectfully request an extension of
thirty (30) days to answer, move or otherwise respond to the Plaintiffs’ Amended Consolidated
Class Action Complaint (“Amended Complaint”) filed on December 7, 2017 [ECF Doc.143]
from January 30, 2018 up to and including March 1, 2018. In support of this motion, Viridian
submits the following:
1. Good cause exists for the requested extension of time because the parties are
continuing negotiations to finalize a settlement to resolve all claims in this action to be submitted
to the Court for preliminary approval.
Case 3:14-cv-01731-SRU Document 151 Filed 01/25/18 Page 1 of 3

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2. Accordingly, Viridian requests an additional thirty (30) day extension of time,
from Tuesday, January 30, 2018 to Thursday March 1, 2018, to answer, move or otherwise
respond to Plaintiffs’ Amended Complaint.
3. This is Viridian’s third request for modification of the deadline at issue.
4. Counsel for Viridian has discussed this matter with Plaintiffs’ counsel, and
Plaintiffs’ counsel consents to Viridian’s requested extension.
WHEREFORE, Viridian respectfully requests that this Court extend the deadline for
Viridian to answer, move or otherwise respond to Plaintiffs’ Amended Complaint from January
30, 2018 up to and including March 1, 2018.
DATED: January 25, 2018
DEFENDANTS
s Maura Barry Grinalds
By: Maura Barry Grinalds
Stephen C. Robinson
Richard T. Bernardo
Skadden, Arps, Slate, Meagher & Flom LLP
Four Times Square
New York, NY 10036
Phone: (212) 735-3000
Fax: (212) 735-2000
Daniel S. Blynn
Eric S. Berman
Venable LLP
600 Massachusetts Avenue, N.W.
Washington, D.C. 20001
Phone: (202) 344-4000
Case 3:14-cv-01731-SRU Document 151 Filed 01/25/18 Page 2 of 3

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CERTIFICATE OF SERVICE
The undersigned hereby certify that on this 25th day of January 2018, a copy of the
foregoing Consent Motion For Extension Of Time was filed electronically and served by mail on
anyone unable to accept electronic filing. Notice of this filing will be sent by email 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. Parties may access this filing
through the Court’s CM/ECF System.
By: s Maura Barry Grinalds
Maura Barry Grinalds
Case 3:14-cv-01731-SRU Document 151 Filed 01/25/18 Page 3 of 3