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

Case 3:03-cv-00644-CFD

Document 242

Filed 12/14/2006

Page 1 of 3

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 12, 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 7 days, up to and including December 22, 2006, to

Case 3:03-cv-00644-CFD

Document 242

Filed 12/14/2006

Page 2 of 3

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 December 22, 2006 for plaintiffs to file a response to defendants' motion. PLAINTIFFS, DAVID GWYNN and RAQUEL GWYNN

By__________________________________ 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 242

Filed 12/14/2006

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on December 8, 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]