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

Case 3:03-cv-00644-CFD

Document 273

Filed 01/31/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE 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. ) __________________________________________)

CIVIL ACTION NO. 3:03CV00644(CFD)

CIVIL ACTION NO. 3:03CV01154(CFD)

JANUARY 31, 2007

DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY TO PLAINTIFFS' RESPONSE TO DEFENDANTS' MOTION TO DETERMINE THE SUFFICIENCY OF PLAINTIFFS' ANSWERS TO DEFENDANTS' REQUESTS FOR ADMISSIONS AND TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION Pursuant to Fed. R. Civ. P. 6(b) and Local Rule 7(b)(1), Defendants, National Union Fire Insurance Company of Pittsburgh, PA. and AIG Technical Services, Inc., now known as AIG Domestic Claims, Inc. (collectively, "Defendants"), respectfully request an Order extending the time to file a combined reply to the oppositions of Plaintiffs Bruce Charles Ryan, Russell William Newton, Robert Fitzpatrick, and Merit Capital Associates, Inc., ("the Ryan Plaintiffs") and Plaintiffs David W. Gwynn and Raquel Gwynn ("the Gwynn Plaintiffs," collectively, "Plaintiffs") to Defendant's Motion to Determine the Sufficiency of Plaintiffs' Answers to

HFD_SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME

Case 3:03-cv-00644-CFD

Document 273

Filed 01/31/2007

Page 2 of 4

Defendants' Requests for Admissions and to Compel Answers to Interrogatories and Production ("Motion to Determine Sufficiency") by seven (7) days, up through and including, February 8, 2007. In support of this motion, Defendants state as follows: 1. On November 16, 2006, Defendants filed their Motion to Determine Sufficiency against both the Ryan Plaintiffs and the Gwynn Plaintiffs. 2. On December 15, 2006, the Ryan Plaintiffs responded with their opposition to the Motion to Determine Sufficiency. 3. On December 21, 2006, the Court granted an extension of time until January 5, 2007 for the Gwynn Plaintiffs to respond to the Motion to Determine Sufficiency. The Gwynn Plaintiffs filed their response on January 5, 2007. Accordingly, the reply to the Gwynn's Plaintiffs' response is due on or before January 19, 2007. On January 8, 2007 the Court ordered that the combined reply to both the Gwynn Plaintiffs' response and the Ryan Plaintiffs' response would be due on January 19, 2007. 4. On January 22, 2007 the Court granted Defendants' request for an additional ten (10) days to file its combined reply setting a new deadline of February 1, 2007. 5. Defendants require a further extension of time in order to appropriately research and file a combined reply that addresses both the Ryan Plaintiffs and the Gwynn Plaintiffs respective responses. 6. Counsel to both the Ryan Plaintiffs and the Gwynn Plaintiffs have no objections to this motion. 7. This is the second request for extension of time made by Defendants with respect to the deadline for filing a response.

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Case 3:03-cv-00644-CFD

Document 273

Filed 01/31/2007

Page 3 of 4

Accordingly, for the reasons stated above, Defendants respectfully request an Order extending the time to file a combined reply to the Plaintiffs' Oppositions to the Motion to Determine Sufficiency by seven (7) days, up through and including, February 8, 2007. Respectfully submitted, DEFENDANTS/COUNTERPLAINTIFFS NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA. and AIG TECHNICAL SERVICES, INC. BY THEIR ATTORNEYS, Edwards Angell Palmer & Dodge LLP By: /s/ David S. Samuels Mark B. Seiger Fed. Bar No. ct05580 David S. Samuels Fed. Bar No. ct 24460 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 111 Huntington Ave. Boston, MA 02199 Tel: (617) 951-3373 Fax: (617) 439-4170 Email: [email protected] Donna M. Greenspan Florida Bar No.: 059110 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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Case 3:03-cv-00644-CFD

Document 273

Filed 01/31/2007

Page 4 of 4

CERTIFICATION I hereby certify that on January 31, 2007, the foregoing Unopposed Motion for Extension of Time was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by email to all parties by operation of the court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this document through the court's CM/ECF System. /s/ David S. Samuels David S. Samuels

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