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

Case 3:03-cv-00644-CFD Document 278 Filed 02/15/2007 Page 1 of 3
UNITED STATES DISTRICT COURT i
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, ) o
) f
) i
vs. )
) A
NATIONAL UNION FIRE INSURANCE ) 7
COMPANY OF PITTSBURGH, PA., and ) I
AIG TECHNICAL SERVICES, INC., ) f
Defendants ) [
) .
DAVID W. GWYNN and RAQUEL GWYNN ) CIVIL ACTION NO. y
Plaintiffs, ) 3:03 CV 01154 (CFD) A
)
) .
vs. )
_
NATIONAL UNION FIRE INSURANCE ) P
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., ) (
Defendants ) _
) FEBRUARY 15, 2007
MOTION FOR TIME TO RESPOND AND OR OBJECT TO DEFENDANTS’ MOTION ,
TO STRIKE PLAINTIFFS’ RULE 56(A),2 STATEMENTS, OR ALTERNATIVELY, FOR
LEAVE TO FILE A RESPONSE TO PLAINTIFFS’ STATEMENT OF PURPORTEDLY I
UNDISPUTED MATERIAL FACTS CONTAINED THEREIN, AND INCORPORATED 7
MEMORANDUM OF LAW
The Plaintiffs David W. Gwynn and Raquel Gwynn (collectively, "the Gwynn A
plaintiffs"), through counsel, respectfully move this Court, pursuant to Fed. R. Civ. P. 6(b) and I
Local Rule 7(b)(l) for an extension of time of two weeks, up to and including March 1, 2007, to if

Case 3:03-cv-00644-CFD Document 278 Filed 02/15/2007 Page 2 of 3
file a response or objection to Defendants’ January 23, 2007 Motion to Strike Plaintiffs’ Rule
56(a)2 Statements, or Alternatively, For Leave to File A Response to Plaintif`fs’ Statement of
Purpoitedly Undisputed Material Facts Contained Therein, And Incorporated Memorandum of
Law ("defendants’ motion"). In support of this motion, undersigned counsel states as follows:
1. This is the first request for extension of time made by the Gwyrm plaintiffs with
respect to this time limitation.
2. The additional time is required because counsel to the Gwynn plaintiffs has had a
number of personal matters to attend to that has necessitated his being away from the office for a
substantial period of time.
3. Counsel to defendants and to co-plaintiffs have no objections to this motion.
Accordingly, for the above-stated reasons, the Gywnn plaintiffs respectfully request that Y
this court grant an extension of time to and including March 1, 2007 for plaintiffs to file a
response or objection to defendants’ motion.
PLAINTIFFS, DAVID GVVYNN and
RAQUEL GWYNN
Mario iNatale (ct 12449)
Silver Golub & Teitell, LLP
184 Atlantic Street is
Stamford, CT 06904
(203) 325-4491
(203) 325-3769 (Fax)
mdinatale@,sgtlaw.com

Case 3:03-cv-00644-CFD Document 278 Filed 02/15/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on February 15, 2007, a copy of foregoing Motion for Time to }
Respond and or Object to Defendants’ Motion to Strike Plaintiffs’ Rule 56(a)2 Statements, S
or Alternatively, For Leave to File A Response to Plaintiffs’ Statement of Purportedly
Undisputed Material Facts Contained Therein, And Incorporated Memorandum of Law
was filed 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 filing as indicated on the Notice of >
Electronic Filing. Parties may access this tiling through the Court’s CM/ECF System.
MARIO DINATALE (ct 12449) I
SILVER GOLUB & TEITELL LLP T
184 Atlantic Street
P. O. Box 389
Stamford, CT 06904 s
Telephone: 203-325-4491 ?
Fax: 203-325-3769 f
E-mail: [email protected]