Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:03-cv-00644-CFD

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Filed 02/10/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITOL ASSOCIATES, INC. Plaintiffs, ) ) CIVIL ACTION NO. ) 3:03 CV 00644 (CFD) ) ) ) ) ) ) ) ) ) ) )

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.

) ) CIVIL ACTION NO. ) 3:03 CV 01154 (CFD) Plaintiffs, ) ) vs. ) ) NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA., and ) AIG TECHNICAL SERVICES, INC., ) ) Defendants ) ________________________________________________) FEBRUARY 8, 2005 MOTION FOR EXTENSION OF TIME Plaintiffs David Gwynn, Raquel Gwynn, and Gwynn Financial Services (hereinafter referred to collectively as "Plaintiffs") respectfully move, pursuant to Fed. R. Civ. P. 6(b)(1) and D. Conn. L. Civ. R. 7(b)(3) for an extension of time of thirty (30) days up to and including March 11, 2005 to respond and/or object to Defendant National Unions' First Request Set of Interrogatories dated January 10, 2005 In support of this Motion, undersigned counsel states as follows:

Case 3:03-cv-00644-CFD

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1. This is the first request for an extension of time to respond and/or object to Defendants' First Set of Interrogatories. 2. Plaintiffs reside in the State of Oregon. The additional time is needed for counsel to

consult with plaintiffs to review the requests and determine the appropriate response. 3. Plaintiffs do not believe that any party would be prejudiced by the delay. The parties

have only recently begun to exchange documents with each other, and depositions have not yet been taken. 4. The undersigned counsel has contacted counsel to defendants. Counsel to defendants may object to this motion. Accordingly, for the reasons stated above, plaintiffs respectfully request that the Court grant an extension of time to and including March 11, 2005, for plaintiffs to respond and/or object to Defendants' First Set of Interrogatories. PLAINTIFFS, DAVID GWYNN, RAQUEL GWYNN AND GWYNN FINANCIAL SERVICES, INC.

By__________________________________ Mario DiNatale (ct 12449) Jonathan M. Levine (ct 07584) Silver Golub & Teitell, LLP 184 Atlantic Street Stamford, CT 06904 (203) 325-4491 (203) 325-3769 (Fax) Email: [email protected] [email protected]

Case 3:03-cv-00644-CFD

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CERTIFICATE OF SERVICE THIS IS TO CERTIFY that a copy of the foregoing was U.S. mail on this 8th day of February, 2005, postage prepaid, to: James R. Hawkins, II, Esq. Finn Dixon & Herling LLP One Landmark Square Stamford CT 06901 Peter M. Nolin, Esq. Sandak Hennessey & Greco LLP 707 Summer Street Stamford, CT 06905 ______________________________ MARIO DiNATALE