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

Case 3:03-cv-00644-CFD

Document 260

Filed 01/16/2007

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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)

JANUARY 16, 2007

DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO THE RYAN PLAINTIFFS' MEMORANDUM IN OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT 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., through the undersigned counsel, hereby move for an extension of time of seven (7) days, up through and including January 23, 2007, to serve a combined reply to The Ryan Plaintiffs' Memorandum in Opposition to Defendants' Motion for Summary Judgment ("Ryan Plaintiffs Opposition") and to The Gwynn Plaintiffs' Memorandum in Opposition to Defendants' Motion for Summary

BOS_BOS_568220_1 (2)/JLEE

Case 3:03-cv-00644-CFD

Document 260

Filed 01/16/2007

Page 2 of 4

Judgment ("Gwynn Plaintiffs' Opposition") (collectively, "Plaintiffs' Opposition"). In support of this motion, Defendants state as follows: 1. This is the third request for extension of time made by Defendants with respect to the deadline for filing a reply. 2. Defendants' Reply to the Plaintiffs' Opposition is due on or before January 16, 2007. 3. Defendants require a one-week additional extension of time to complete its Reply to Plaintiffs' Opposition, which consists of ninety (90) pages of combined Memoranda of Law. 4. Counsel to both the Ryan Plaintiffs and the Gwynn Plaintiffs consent to the requested extension. WHEREFORE, Defendants hereby request that the Court grant this motion and extend the deadline by which Defendants must serve a reply to Plaintiffs' Opposition by seven (7) days up through and including January 23, 2007.

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BOS_BOS_568220_1 (2)/JLEE

Case 3:03-cv-00644-CFD

Document 260

Filed 01/16/2007

Page 3 of 4

DEFENDANTS/COUNTERPLAINTIFFS NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA. and AIG TECHNICAL SERVICES, INC. By:/s/ David S. Samuels 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] 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]

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BOS_BOS_568220_1 (2)/JLEE

Case 3:03-cv-00644-CFD

Document 260

Filed 01/16/2007

Page 4 of 4

CERTIFICATION I hereby certify that on January 16, 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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BOS_BOS_568220_1 (2)/JLEE