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

Case 3:03-cv-00644-CFD

Document 231

Filed 12/05/2006

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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 ) ________________________________________________)

CIVIL ACTION NO. 3:03 CV 00644 (CFD)

DECEMBER 5, 2006

PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION TO DETERMINE SUFFICIENCY OF PLAINTIFFS' ANSWERS TO DEFENDANTS' REQUESTS FOR ADMISSIONS AND TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION

Plaintiffs Bruce Charles Ryan, Russell William Newton, Robert Fitzpatrick, and Merit Capital Associates, Inc. (collectively "Plaintiffs") hereby move for a 8 day extension of time to and including December 15, 2006 in which to file a response to Defendants' Motion to Determine Sufficiency of Plaintiffs' Answers to Defendants' Requests for Admissions and to Compel Answers to Interrogatories and Production dated November 16, 2006. Plaintiffs require this short period of time in order to fully review the discovery responses with which Defendants have taken issue. In addition, Plaintiffs counsel, Peter Nolin, is in route to Oregon to attend the deposition of David Gwynn. David Gwynn is a plaintiff in the case consolidated with this case

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Case 3:03-cv-00644-CFD

Document 231

Filed 12/05/2006

Page 2 of 3

for all discovery, Gwynn et al v. National Union Fire Ins. Co. of Pittsburg, PA et al, DN 3:03 CV 01154 (CFD). Mr. Gwynn's deposition is scheduled to take place on December 5-7, 2006. This is Plaintiffs first request for an extension of time to respond to Defendants' motion. Neither Gwynn's counsel nor Defendants' counsel object to this request. Wherefore Plaintiffs move for an 8 day extension of time to an including December 15, 2006 to respond to Defendants' motion. PLAINTIFFS, BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITAL ASSOCIATES INC.,

By_________/S/_Stephanie A. McLaughlin Peter M. Nolin (ct06223) Stephanie A. McLaughlin (ct22774) Sandak Hennessey & Greco LLP 707 Summer Street Stamford, CT 06901-1026 (203) 425-4200 (203) 325-8608 (fax) [email protected]

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Case 3:03-cv-00644-CFD

Document 231

Filed 12/05/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on December 5, 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.

____/s/ Stephanie A. McLaughlin__ Stephanie A. McLaughlin

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