Transamerica Life Insurance Company v. Caramadre et al

Filing 160

MOTION for an Extension of Time to File Reply to Defendant Caramadre's Objection to Motion to Attach to March 28, 2013 by Western Reserve Life Assurance Co. of Ohio, Transamerica Life Insurance Company, Western Reserve Life Assuance Co. of Ohio. Responses due by 4/1/2013 Associated Cases: 1:09-cv-00470-S-PAS et al.(Daly, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
____________________________________
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
C.A. No. 09-470-S
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., HARRISON CONDIT, )
and FORTUNE FINANCIAL SERVICES,
)
INC.,
)
Defendants;
)
____________________________________ )
)
TRANSAMERICA LIFE INSURANCE
)
COMPANY,
)
Plaintiff,
)
)
vs.
)
)
C.A. No. 09-471-S
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., ESTELLA
)
RODRIGUES, EDWARD MAGGIACOMO, )
JR., LIFEMARK SECURITIES CORP., and )
PATRICK GARVEY,
)
Defendants;
)
____________________________________ )
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
C.A. No. 09-472-S
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., ADM ASSOCIATES, )
LLC, EDWARD HANRAHAN, THE
)
LEADERS GROUP, INC., and CHARLES )
BUCKMAN,
)
Defendants;
)
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____________________________________
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., DK LLC, EDWARD
)
HANRAHAN, THE LEADERS GROUP,
)
INC., and JASON VEVEIROS,
)
Defendants;
)
)
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., NATCO PRODUCTS )
CORP., EDWARD HANRAHAN, and THE )
LEADERS GROUP, INC.,
)
Defendants;
)
)
)
TRANSAMERICA LIFE INSURANCE
)
COMPANY,
)
Plaintiff,
)
)
vs.
)
)
LIFEMARK SECURITIES CORP., JOSEPH )
CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC. and EDWARD
)
MAGGIACOMO, JR.,
)
Defendants; and
)
)

C.A. No. 09-473-S

C.A. No. 09-502-S

C.A. No. 09-549-S

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2

____________________________________
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., HARRISON CONDIT, )
and FORTUNE FINANCIAL SERVICES,
)
INC.,
)
Defendants.
)
)

C.A. No. 09-564-S

PLAINTIFFS’ MOTION TO EXTEND TIME TO FILE REPLY TO DEFENDANT
CARAMADRE’S OBJECTION TO MOTION TO ATTACH
Plaintiffs Western Reserve Life Assurance Co. of Ohio and Transamerica Life Insurance
Company (together “Plaintiffs”) move pursuant to Fed. R. Civ. P. 6 to extend the deadline to file
their reply to defendant Joseph Caramadre’s Objection to Motion to Attach (“Objection,” filed as
Doc. 148 in C.A. No. 09-470).
Caramadre filed his Objection on March 4, 2013. Plaintiffs request a two week
extension, to March 28, 2013, to file their reply. This extension is necessary to allow Plaintiffs
the opportunity to fully and succinctly address the issues Caramadre raises in his Objection.
The requested extension will not have an impact on the progress of these civil actions. A
focal point of Plaintiff’s motion to attach and Caramadre’s Objection thereto is Caramadre’s
guilty plea in the related criminal action pending in this Court, Criminal No. 11-186/S.
Caramadre has moved to withdraw his plea. On March 12, 2013, the Government filed its
objection to Caramadre’s motion. Caramadre has argued that the resolution of that motion may
have a bearing on Plaintiff’s motion to attach. It is unlikely Caramadre’s motion to withdraw
will be ruled upon prior to March 28, 2013.

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For these reasons, Plaintiffs respectfully request that the deadline for filing their reply to
Caramadre’s Objection be extended to March 28, 2013.

Dated: March 13, 2013

Respectfully submitted,
/s/ Brooks R. Magratten
Brooks R. Magratten, Esq., No. 3585
David E. Barry, Esq., pro hac vice admitted
Michael J. Daly, Esq. No. 6729
PIERCE ATWOOD LLP
Attorneys for Plaintiffs
10 Weybosset St., Suite 400
Providence, RI 02903
[phone] [Tel.]
[phone] [Fax]
[e-mail]
[e-mail]
[e-mail]

Certificate of Service
I certify that the foregoing motion was electronically filed with the Clerk of the Court on
March 13, 2013, and that it is are available for viewing and downloading from the Court’s
CM/ECF system. All counsel of record have been served by electronic means.
/s/ Brooks R. Magratten
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