Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00644-CFD

Document 280

Filed 02/23/2007

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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)

February 23, 2007

DEFENDANTS' CONSENTED TO MOTION FOR EXTENSION OF TIME TO REPLY TO THE RYAN PLAINTIFFS' MEMORANDUM 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, up through and including March 16, 2007, to reply to the Ryan Plaintiffs' Memorandum in Opposition to Defendants' Motion to Strike Plaintiffs' Rule 56(a) Statements or,

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Case 3:03-cv-00644-CFD

Document 280

Filed 02/23/2007

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Alternatively, for Leave to File a Response to Plaintiffs' Undisputed Material Facts Contained Therein, and in support thereof, state as follows: 1. Defendants filed their Motion to Strike Plaintiffs' Rule 56(a) Statements or, Alternatively, for Leave to File a Response to Plaintiffs' Undisputed Material Facts Contained Therein ("Motion to Strike") on January 23, 2007. 2. On February 15, 2007, the Gwynn Plaintiffs filed an unobjected-to motion for extension of time to respond to the Motion to Strike. 3. On February 16, 2007, the Court granted the Gwynn Plaintiffs' motion for extension. The Gwynn Plaintiffs' response to the Motion to Strike is currently due on March 1, 2007. 4. Meanwhile, on February 12, 2007, the Ryan Plaintiffs filed a Memorandum in Opposition to the Motion to Strike ("Ryan Plaintiffs' Opposition"). 5. Defendants desire to reply to the Ryan Plaintiffs' Opposition simultaneously with its reply to the Gywnn Plaintiffs' response, which is due March 1, 2007. Accordingly, Defendants request an extension of time until March 16, 2007. 6. Counsel for both the Ryan Plaintiffs and the Gwynn Plaintiffs have consented to this motion for extension. 7. This is the first 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 a response to the Ryan Plaintiffs' Opposition to the Motion to Strike, up through and including March 16, 2007.

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Case 3:03-cv-00644-CFD

Document 280

Filed 02/23/2007

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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]

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Case 3:03-cv-00644-CFD

Document 280

Filed 02/23/2007

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CERTIFICATION I hereby certify that on February 23, 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

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