Free Motion for Leave to File Excess Pages - District Court of Connecticut - Connecticut

Case 3:03-cv-00644-CFD

Document 225

Filed 11/20/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

____________________________________________ BRUCE CHARLES RYAN, RUSSELL ) WILLIAM NEWTON, ROBERT FTIZPATRICK, ) 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. )

CIVIL ACTION NO. 3:03CV00644(CFD)

CIVIL ACTION NO. 3:03CV01154(CFD)

NOVEMBER 20, 2006

MOTION FOR PERMISSION TO FILE BRIEF IN EXCESS OF 40 PAGES Pursuant to Local Rule 7(2), Plaintiffs Bruce Charles Ryan, Russell William Newton, Robert Fitzpatrick and Merit Capital Associates Inc. (hereinafter collectively referred to as the "Ryan Plaintiffs") hereby move for permission to file its Memorandum in Opposition to Defendants' Motion for Summary Judgment ("Memorandum") which exceeds the 40 page limit by approximately 10 pages. The Memorandum is being simultaneously submitted herewith.

Case 3:03-cv-00644-CFD

Document 225

Filed 11/20/2006

Page 2 of 3

The Ryan Plaintiffs submit that good cause exists to allow them to file the Memorandum in that: Defendants have moved for summary judgment on all counts in the Ryan Plaintiffs' complaint, including breach of the duty to defend, breach of the duty to indemnify, bad faith and violation of CUTPA/CUIPA. The legal and factual issues raised in the motion for summary judgment are complex and required the Ryan Plaintiffs to provide the Court with a detailed legal analysis and factual accounting. Thus, the Ryan Plaintiffs move the Court for permission to file its Memorandum in excess of 40 pages. 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 (203) 425-4200 (203) 325-8608 (fax) [email protected] [email protected]

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Case 3:03-cv-00644-CFD

Document 225

Filed 11/20/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on November 20, 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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