Lomaz’s defense against the default judgment is based on his incredible claim that First Financial is not related to either Pacific or Midwest, and therefore neither Pacific nor Midwest should be held liable for damages assessed against First Financial. First Financial shared the same office address as Pacific and Midwest, and Pacific was listed as “D/B/A First Financial” on the customs bond. Both Midwest and Pacific had numerous contacts with Customs and a “reasonable time” and the moving party must show “extraordinary circumstances” to warrant relief. Rodriguez v. Mitchell, 252 F.3d 191, 201 (2d Cir.2001) (citation and internal quotation marks omitted); Fed.R.Civ.P. 60(b). We find no extraordinary circumstances that warrant the thirteen-year delay in this case. See id. at 201 (<HOLDING>). CONCLUSION For the foregoing reasons, the
holding a three and onehalf year delay was unreasonable holding that by itself three and onehalf months was insufficient to prove causation holding that delay for three and onehalf years was unreasonable under rule 60b6 holding based on similar facts and a delay of three and onehalf years that it would have been an abuse of discretion for the district court to have held that these circumstances resulted in laches holding a plaintiffs rule 60b3 motion untimely where a three and onehalf month delay had occurred with no explanation as to the reason for the delay