Free Motion to Withdraw - District Court of Connecticut - Connecticut

Case 3:03-cv-00644-CFD Document 99 Filed 08/24/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL WILLLAM )
NEWTON, ROBERT F ITZPATRICK, and MERIT ) CASE NUMBER:
CAPITAL ASSOCIATES, INC., ) 3:03 CV 00644 (CFD)
)
Plaintiffs, )
)
vs. )
)
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
)
Defendants. )
DAVID W. GWYNN, RAQUEL GWYNN AND )
GWYNN FINANCIAL SERVICES, INC. ) CASE NUMBER:
) 3:03 CV 1154 (CFD)
Plaintiffs, )
)
vs. )
)
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
)
Defendants. ) August 24, 2005
MOTION TO WITHDRAW
Pursuant to FED. R. Civ. P. 7(b) and D. CONN. L. Civ. R. 83.6(a), Defendants National
Union Fire Insurance Company of Pittsburgh, Pa. and AIG Teclmical Services, Inc., now known
as AIG Domestic Claims, Inc. (collectively, "National Union"), respectfully move that this Court
withdraw its prior Motion for Leave to File an Amended Answer, Affirmative Defenses and
Counterclaims, dated August 23, 2005 (the "Motion for Leave"), in the above-captioned action
Ryan, etal. v. National Union Fire Insurance Company of Pittsburgh, Pa., etal., Case No. 3:03
CV 00644 (CFD) (the "Ryan action"). The prior Motion for Leave was filed in error at Docket
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Case 3:03-cv-00644-CFD Document 99 Filed 08/24/2005 Page 2 of 2
No. 98 and will be replaced by another Motion for Leave to File an Amended Answer,
Affirmative Defenses and Counterclaims, tiled by National Union concurrently herewith.
WHEREFORE, Defendants National Union Fire Insurance Company of Pittsburgh, Pa.,
and AIG Technical Services, Inc., now known as AIG Domestic Claims, Inc., respectfully
request that the Court withdraw National Union’s prior Motion for Leave to File an Amended
Answer, Affirmative Defenses and Counterclaims, dated August 23, 2005 (the "Motion for
Leave"), and such other and further relief as the Court may deem just and proper.
DEFENDANT NATIONAL A IO FIRE
INSURANCE COMPANY OF P TS : ' GH, Pa.
and AIG CHNIC ERVI S, |··
' .24/ v LM
- { es R. Hawkins H (ct00l28)
illiam M. Tong (ct25304)
Finn Dixon & Herling LLP
One Landmark Square, Suite 1400
Stamford, CT 06901-2689
Tel: (203) 325-5000
Fax: (203) 348-5777
Email: [email protected]
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