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

Case 3:03-cv-00644-CFD Document 292 Filed 05/08/2007 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL WILLIAM )
NEWTON, ROBERT FITZPATRICK, and ) CASE NUMBER:
MERIT CAPITAL ASSOCIATES, INC., ) 3:03 CV 00644 (CFD)
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Plaintiffs, ) I
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v. g I
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
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Defendants, )
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DAVID W. GWYNN and RAQUEL GWYNN, )
) CASE NUMBER:
Plaintiffs, ) 3:03 CV 1154 (CFD)
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NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
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Defendants. ) May 8, 2007
DEFENDANTS’ REQUEST FOR AN EXTENTION OF TIME TO SUBMIT
OBJECTIONS TO THE APRIL 24, 2007 AND APRIL 25, 2007 ORDERS
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Defendants, National Union Fire Insurance Company of Pittsburgh, PA -and AIG
Technical Services, Inc., n/l undersigned counsel, hereby respectfully move both for an extension of time of (10) ten days, up
through and including May 18, 2007 to tile an objection to Magistrate Judge Smith’s April 24,
2007 Order and an extension of time of ten (10) days, up through and including May 21, 2007 to
file an objection to Magistrate Judge Smith’s April 25, 2007 Order. In support thereof,
Defendants state as follows:
HF D_l 7729l_l.DOC

Case 3:03-cv-00644-CFD Document 292 Filed 05/08/2007 Page 2 of 4
1. On April 24, 2007, Magistrate Judge Smith issued an order denying Defendants’ rnotion
to strike the Ryan Plaintiffs’ submission of a statement of undisputed material facts ("April 24,
2007 Order").
2. The current deadline to object to the April 24, 2007 Order is May 8, 2007.
3. On April 25, 2007, Magistrate Judge Smith issued a ruling denying, in part, Defendants’
motion to determine the sufficiency of plaintiffs’ answers to defendants’ request for admissions
and to compel answers to interrogatories and production (“April 25, 2007 Order") (collectively,
the April 24, 2007 Order and the April 25, 2007 Order referred to as the "Orders").
4. The deadline to object to the April 25, 2007 Order is May 9, 2007.
5. Due to personal issues of counsel, Defendants require an additional extension of time to
tile objections to the Orders. `
6. Counsel for both the Ryan Plaintiffs and the Gwynn Plaintiffs have no objection to the
motion for extension of time.
7. This is the first request for extension of time made by Defendants in connection with
i filing objections to the Orders.
WHEREFORE, Defendants hereby respectfully request that the Court grant this motion
and extend the deadline by which Defendants must file its objections to the Orders up to and
including May 18, 2007 and May 21, 2007 respectively.
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Case 3:03-cv-00644-CFD Document 292 Filed 05/08/2007 Page 3 of 4
DEFENDAN TS! COUNTERPLAINTIFF S
NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, PA.
and AIG TECHNICAL SERVICES, INC.
By: /s/ David S. Samuels
Donna M. Greenspan
Florida Bar No.: 059110
Edwards Angell Palmer & Dodge LLP ‘
One North Clematis Street, Suite 400
West Palm Beach, FL 33401
Tel: (561) 833-7700
Fax: (561) 655-8719
Email: [email protected]
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Mark B. Seiger
Fed. Bar No. ct05580
David S._ Samuels
Fed. Bar No. ct 24460
Edwards Angell Palmer & Dodge LLP
90 State House Square
Hartford, CT 06103-2715
Tel: (860) 525-5065
Fax: (860) 527-4198
. Email: [email protected]
dsamuels@eapdlaw. com I
John D. Hughes
Massachusetts BBO # 243660
Edwards Angell Palmer & Dodge LLP
11 1 Huntington Avenue
Boston, MA 02199
Tel: (617) 951-3373
Fax: (617) 439-4170
Email: [email protected]
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Case 3:03-cv-00644-CFD Document 292 Filed 05/08/2007 Page 4 of 4
CERTIFICATION
I hereby certify that on May 8, 2007, a copy of the foregoing document was filed
electronically and served by mail on anyone unable to accept electronic filing. Notice of this
filing will be sent by e-mail to all parties by operation of the Court’s electronic filing system or
by mail on anyone unable to accept electronic filing. Parties may access this filing through the
Court’s system.
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fsf David S. Samuels
David S. Samuels
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