Case 3:03-cv-00644-CFD
Document 245
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, ) ) CIVIL ACTION NO. ) 3:03 CV 00644 (CFD) ) ) ) vs. ) ) NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA., and ) AIG TECHNICAL SERVICES, INC., ) Defendants ) ) DAVID W. GWYNN and RAQUEL GWYNN ) CIVIL ACTION NO. Plaintiffs, ) 3:03 CV 01154 (CFD) ) ) vs. ) ) NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA., and ) AIG TECHNICAL SERVICES, INC., ) Defendants ) ________________________________________________) DECEMBER 21, 2006 PLAINTIFFS' MOTION FOR TIME TO RESPOND TO DEFENDANTS' MOTION TO DETERMINE THE SUFFICIENCY OF PLAINTIFFS' ANSWERS TO DEFENDANTS' REQUESTS FOR ADMISSIONS, AND TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION
The Plaintiffs David W. Gwynn and Raquel Gwynn (collectively, "the Gwynn plaintiffs"), through counsel, respectfully move this Court, pursuant to Fed. R. Civ. P. 6(b) and Local Rule 7(b)(1) for an extension of time of two weeks, up to and including January 5, 2007, to
Case 3:03-cv-00644-CFD
Document 245
Filed 12/21/2006
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file a response to Defendants' November 16, 2006 Motion to Determine the Sufficiency of Plaintiffs' Answers to Defendants' Requests for Admissions, and to Compel Answers to Interrogatories and Production, and Incorporated Memorandum of Law ("defendants' motion"). In support of this motion, undersigned counsel states as follows: 1. This is the second request for extension of time made by the Gwynn plaintiffs
with respect to this time limitation. 2. The requested time is necessary in order to review the various discovery
defendants reference in their motion, and determine a response. 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 this court grant an extension of time to and including January 5, 2007 for plaintiffs to file a response to defendants' motion. PLAINTIFFS, DAVID GWYNN and RAQUEL GWYNN
By /s/ Mario DiNatale Mario DiNatale (ct 12449) Silver Golub & Teitell, LLP 184 Atlantic Street Stamford, CT 06904 (203) 325-4491 (203) 325-3769 (Fax) [email protected]
Case 3:03-cv-00644-CFD
Document 245
Filed 12/21/2006
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CERTIFICATE OF SERVICE
I hereby certify that on December 21, 2006, a copy of foregoing Motion for Time to Respond to Defendants' Motion to Determine the Sufficiency of Plaintiffs' Answers to Defendants' Requests for Admissions, and to Compel Answers to Interrogatories and Production 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 to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.
/s/ Mario DiNatale MARIO DINATALE (ct 12449) SILVER GOLUB & TEITELL LLP 184 Atlantic Street P. O. Box 389 Stamford, CT 06904 Telephone: 203-325-4491 Fax: 203-325-3769 E-mail: [email protected]