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

Case 3:03-cv-00644-CFD Document 230 Filed 12/04/2006 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL WILLIAM )
NEWTON, ROBERT FITZPATRICK, and MERIT ) CIVIL ACTION NO.
CAPITAL ASSOCIATES, INC. ) 3:03 CV 00644 (CFD)
Plaintiffs, )
>
)
vs. )
)
NATIONAL UNION FIRE INSURANCE ) f
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., ) I
Defendants ) Q
é
DAVID W. GWYNN and RAQUEL GWYNN ) CIVIL ACTION NO.
Plaintiffs, ) 3:03 CV 01154 (CFD)
)
) S
vs. ) .
)
NATIONAL UNION FIRE INSURANCE ) (
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants )
) DECEMBER 4, 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)(l) for an extension of time of 8 days, up to and including December 15, 2006, to

Case 3:03-cv-00644-CFD Document 230 Filed 12/04/2006 Page 2 of 4
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:
I. This is the first 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. This is especially so because
undersigned counsel will be in the state of Oregon in connection with a deposition in this matter
from December 5-7, 2006 including travel to and from Oregon).
3. On November 30, 2006, I sent an email to counsel to the defendants to inquire
whether they consented or objected to this motion. The email was sent to both Mark Seiger,
Esq., and Donna Greenspan, Esq. Neither of them have responded to this email as of this time.
Accordingly, for the above-stated reasons, the Gywnn plaintiffs respectfully request that
this court grant an extension of time to and including December I5, 2006 for plaintiffs to file a
response to defendants’ motion.

Case 3:03-cv-00644-CFD Document 230 Filed 12/O4/2006 Page 3 of 4
PLAINTIFFS, DAVID GWYNN and
RAQUEL GWYNN
By C2
Ma o DiNata1e (ct 12449)
Sil er Golub & Teitell, LLP
184 Atlantic Street
Stamford, CT 06904
(203) 325-4491
(203) 325-3769 (Fax)
mdinata1e(wLs&rtlaw,c0m

Case 3:03-cv-00644-CFD Document 230 Filed 12/O4/2006 Page 4 of 4
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that a copy of the foregoing was sent via facsimile, on this 4* day
of December, 2006, to:
Mark B. Seiger, Esq.
Charles F. Gfeller, Esq.
Edwards Angell Palmer & Dodge LLP
90 State House Square
Hartford, CT 06103
Peter M. Nolin, Esq.
Stephanie McLaughlin, Esq. {
Sandak Hennessey & Greco LLP }
707 Summer Street
Stamford, CT 06905
Donna M. Greenspan, Esq.
Edwards Angell Palmer & Dodge, LLP
One North Clematis Street - Suite 400
West Palm Beach, F L 33401
MARIO DiNATALE