Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cv-00644-CFD Document 283 Filed O3/07/2007 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL WILLIAM )
NEWTON, ROBERT FITZPATRICK, and MERIT ) CIVIL ACTION NO.
CAPITAL ASSOCIATES, INC. ) 3:03 CV 00644 (CFD)
Plaintiffs, )
) Y
)
vs. )
>
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants ) 2
)
DAVID W. GWYNN and RAQUEL GW Y NN ) CIVIL ACTION NO.
Plaintiffs, ) 3:03 CV 01154 (CFD)
) ;
) J
vs. )
J
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and ) ;
AIG TECHNICAL SERVICES, INC., )
Defendants )
) MARCH 7, 2007
THE GWYNN PLAINTIFFS’ MOTION FOR MODIFICATION OF SCHEDULING
ORDER
Plaintiffs, David Gwynn and Raquel Gwynn, by and through their undersigned counsel,
hereby move for a modification of the Scheduling Order. Fact discovery is complete, and the
proposed modification relates to expert disclosure and other matters. The reason for this request
is that undersigned counsel has some personal health issues that need to be resolved within the
next few weeks. This is the fifth request for modification of the Scheduling Order.

Case 3:03-cv-00644-CFD Document 283 Filed O3/07/2007 Page 2 of 3
Plaintiffs request the following schedule:
(1) June 15, 2007: Plaintiffs to Disclose Expert Witnesses.
(2) July 16, 2007: Depositions of Plaintiffs’ Experts Completed.
(3) August 16, 2007: Defendants to Disclose Expert Witnesses.
(4) September 16, 2007: Depositions of Defendant’s Experts Completed.
(5) October 9, 2007, or thirty
(30) days following the ruling Q
on any dispositive motions,
whichever is later: Joint Trial Memorandum Filed.
WHEREFORE, the Plaintiffs respectfully request that the Court grant their Motion for f
Modification of the Scheduling Order, as outlined above.
Peter Nolin, Esq., Counsel to co-plaintiffs, and Mark Seiger, Esq., counsel for the
defendants, do not obj ect to this Motion.
PLAINTIFFS, DAVID GWYNN and
RAQUEL G NN
;
Mario DiNatale (ct 12449)
Silver Golub & Teitell, LLP
184 Atlantic Street
Stamford, CT 06904
(203) 325-4491 {
(203) 325-3769 (Fax)
mdinata1e{aQ,sg_tlaw.com

Case 3:O3—cv-00644-CFD Document 283 Filed O3/07/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on March 7, 2007, a copy of foregoing Motion for Modification of
the Scheduling Order was tiled electronically and served by mail on anyone unable to accept
electronic tiling. Notice of this tiling will be sent by e-mail to all parties by operation of the
Court’s electronic tiling system or by mail to anyone unable to accept electronic tiling as
indicated on the Notice of Electronic Filing. Parties may access this tiling through the Court’s
CM/ECF System. _
MARIO DINATALE (ct 12449) s
SILVER GOLUB & TEITELL LLP
184 Atlantic Street
P. O. Box 389
Stamford, CT 06904
Telephone: 203-325-4491
Fax: 203—325—3769
E-mail: [email protected]