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

Case 3:03-cv-00644-CFD

Document 285

Filed 03/15/2007

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITAL ASSOCIATES, INC., Plaintiffs, v. NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA., and AIG TECHNICAL SERVICES, INC., Defendants, DAVID W. GWYNN and RAQUEL GWYNN, Plaintiffs, v. NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA., and AIG TECHNICAL SERVICES, INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NUMBER: 3:03 CV 00644 (CFD)

CASE NUMBER: 3:03 CV 1154 (CFD)

March 15, 2007

DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY TO THE RYAN PLAINTIFFS' AND THE GWYNN PLAINTIFFS' MEMORANDA IN OPPOSITION TO DEFENDANTS' MOTION TO STRIKE PLAINTIFFS' RULE 56(A) STATEMENTS OR ALTERNATIVELY, FOR LEAVE TO FILE A RESPONSE TO PLAINTIFFS' STATEMENTS OF PURPORTEDLY UNDISPUTED MATERIAL FACTS CONTAINED THEREIN Pursuant to Fed. R. Civ. Proc. 6(b) and Local Rule 7(b), Defendants, National Union Fire Insurance Company of Pittsburgh, PA and AIG Technical Services, Inc., n/k/a AIG Domestic Claims Inc. ("Defendants"), through the undersigned counsel, hereby respectfully move for an extension of time of (10) ten days, up through and including March 26, 2007, to reply to both the Ryan Plaintiffs' and the Gwynn Plaintiffs' memoranda in opposition to Defendants' Motion to Strike Plaintiffs' Rule 56(a) Statements or, Alternatively, for Leave to File a Response to

175251_1

Case 3:03-cv-00644-CFD

Document 285

Filed 03/15/2007

Page 2 of 4

Plaintiffs' Undisputed Material Facts Contained Therein ("Motion to Strike"), and in support thereof, state as follows: 1. On February 12, 2007, the Ryan Plaintiffs filed a Memorandum in Opposition to the Motion to Strike ("Ryan Plaintiffs' Opposition.") 2. On February 23, 2007, Defendants filed a motion for extension of time to file a reply to the Ryan Plaintiffs' Opposition simultaneously with its reply to the Gywnn Plaintiffs' Opposition, which was due on March 1, 2007. 3. Defendants' replies to the Ryan Plaintiffs' and the Gwynn Plaintiffs' Oppositions are currently due March 16, 2007. 4. Due to personal issues of counsel, Defendants require an additional extension of time to file replies to both the Ryan Plaintiffs' and the Gwynn Plaintiffs' Oppositions. 5. Counsel for both the Ryan Plaintiffs and the Gwynn Plaintiffs have consented to this motion for extension. 6. This is the second request for extension of time made by Defendants in connection with their Motion to Strike. WHEREFORE, Defendants hereby respectfully request that the Court grant this motion and extend the deadline by which Defendants must serve replies to both the Ryan Plaintiffs' and the Gwynn Plaintiffs' Oppositions to the Motion to Strike by (10) ten days, up through and including March 26, 2007.

175251_1

Case 3:03-cv-00644-CFD

Document 285

Filed 03/15/2007

Page 3 of 4

DEFENDANTS/COUNTERPLAINTIFFS 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] 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] [email protected] John D. Hughes Massachusetts BBO # 243660 Edwards Angell Palmer & Dodge LLP 111 Huntington Avenue Boston, MA 02199 Tel: (617) 951-3373 Fax: (617) 439-4170 Email: [email protected]

175251_1

Case 3:03-cv-00644-CFD

Document 285

Filed 03/15/2007

Page 4 of 4

CERTIFICATION I hereby certify that on March 15, 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.

/s/ David S. Samuels David S. Samuels

175251_1