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

Case 3:03-cv-00644-CFD Document 221 Filed 11/06/2006 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL WILLIAM )
NEWTON, ROBERT FITZPATRICK, and MERIT ) CIVIL ACTION NO.
CAPITOL ASSOCIATES, INC. ) 3:03 CV 00644 (CFD) ?
Plaintiffs, )
>
) q
vs. ) .
> .
NATIONAL UNION FIRE INSURANCE ) ;
COMPANY OF PITTSBURGH, PA., and ) f
AIG TECHNICAL SERVICES, INC., ) ]
Defendants ) [
) .
DAVID W. GWYNN and RAQUEL GW Y N N ) CIVIL ACTION NO.
Plaintiffs, ) 3:03 CV 01154 (CFD)
l .
) .
vs. ) {
>
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants )
) NOVEMBER 6, 2006
PLAINTIFFS’ JOINT MOTION FOR EXTENSION OF TIME TO REPLY TO
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT i
The Plaintiffs David W. Gwynn and Raquel Gwynn (collectively, "the Gwynn
plaintiffs"), and Bruce Charles Ryan, Russell William Newton, Robert Fitzpatrick, and Merit
Capitol Associates, Inc. (collectively, "the Ryan 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 l0
days, up to and including November 20, 2006, to file a Memorandum of Law in Opposition to

Case 3:03-cv-00644-CFD Document 221 Filed 1 1/06/2006 Page 2 of 4
Defendants’ August 17, 2006 Motion for Summary Judgment ("defendants’ motion"). In support
of this motion, undersigned counsel states as follows:
1. This is the third request for extension of time made by the Gwynn and Ryan
plaintiffs with respect to this time limitation.
2. Defendants’ Memorandum in support of their motion is 36 pages long. It
identities 101 alleged "Undisputed Material Facts." It makes numerous references to the
voluminous factual record in this case, including citations to the transcript of the NASD
arbitration ("the arbitration") which forms the basis of the Gwynn and Ryan plaintiffs’ claimsof
defendants’ bad faith. it
3. To date, approximately 15 depositions have been taken in this matter. Document
production by all parties has exceeded 10,000 pages. The transcript of the arbitration is over
1,000 pages long. It will take substantial time and effort to carefully review this material for
inclusion within plaintiffs’ Memorandum in Opposition.
4. The additional time is also required because of a serious illness within the family
of the undersigned.
5. Counsel to the Gwynn plaintiffs has communicated with counsel to defendants,
who has indicated he does not object to this requested extension.
Accordingly, for the above-stated reasons, the Gywnn and Ryan plaintiffs respectfully
request that this court grant an extension of time to and including November 20, 2006 for
plaintiffs to file a memorandum in opposition to defendants’ Motion.

Case 3:03-cv-00644-CFD Document 221 Filed 1 1/06/2006 Page 3 of 4
PLAINTIFFS, DAVID GWYNN and
RAQUEL GWYNN
By ·/ ;»
ario DiNata1e (ct 12449)
Silver Golub & Teitell, LLP 5
184 Atlantic Street
Stamford, CT 06904
(203) 325-4491
(203) 325-3769 (Fax) 1
mdinatale(@‘sg;law.com ;

Case 3:03-cv-00644-CFD Document 221 Filed 1 1/06/2006 Page 4 of 4
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that a copy of the foregoing was sent via facsimile and U.S. Mail,
postage prepaid, on this 6*h day of November, 2006, to: l
Mark B. Seiger, Esq.
Charles F. Gfeller, Esq.
Edwards Angell Palmer & Dodge LLP
90 State House Square 9
Hartford, CT 06103 g
Peter M. Nolin, Esq.
Stephanie McLaughlin, Esq. i
Sandak Hennessey & Greco LLP
707 Summer Street Q
Stamford, CT 06905
Donna M. Greenspan, Esq.
Edwards Angell Palmer & Dodge LLP
One North Clematis Street - Suite 400
West Palm Beach, FL 33401
MARIO DiNATALE