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

Case 3:03-cv-00644-CFD

Document 249

Filed 12/21/2006

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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)

DECEMBER 21, 2006

CONSENTED TO MOTION FOR EXTENSION OF TIME TO FILE RESPONSE 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) the Defendants, National Union Fire Insurance Company of Pittsburgh, PA and AIG Technical Services, Inc., through the undersigned counsel, hereby respectfully move for an extension of time of twenty (20) days, up through and including January 16, 2007, to file a response to The Ryan Plaintiffs' Memorandum in Opposition to Defendants' Motion for Summary Judgment (hereinafter referred to as "Opposition.") In support of this motion, the undersigned counsel aver as follows:

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Case 3:03-cv-00644-CFD

Document 249

Filed 12/21/2006

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1. This is the second request for extension of time made by Defendants with respect to the deadline for filing a response. 2. The requested extension is necessary in order to fully and properly respond to the Opposition. 3. Counsel to Plaintiffs in this case consent to the requested extension. WHEREFORE, Defendants hereby respectfully request that the Court grant this motion and extend the deadline by which Defendants must file a response to the Ryan Plaintiffs' Opposition by twenty (20) days up through and including January 16, 2007.

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Case 3:03-cv-00644-CFD

Document 249

Filed 12/21/2006

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DEFENDANTS/COUNTERPLAINTIFFS NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA. and AIG TECHNICAL SERVICES, INC. By:_/d/ 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 249

Filed 12/21/2006

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CERTIFICATION I hereby certify that on December 21, 2006, 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.

/d/ David S. Samuels David S. Samuels

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