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

Case 3:03-cv-00644-CFD Document 217 Filed 10/23/2006 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, )
)
)
vs. )
) ;
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and ) §
AIG TECHNICAL SERVICES, INC., )
Defendants )
)
DAVID W. G and RAQUEL G ) CIVIL ACTION NO.
Plaintiffs, ) 3:03 CV Ol 154 (CFD)
)
) t
vs. ) .
) S
NATIONAL UNION FIRE INSURANCE ) Q
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants )
) OCTOBER 23, 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 14
days, up to and including November l0, 2006, to file a Memorandum of Law in Opposition to

Case 3:03-cv-00644-CFD Document 217 Filed 10/23/2006 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 second 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
identifies 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’ claims of
defendants’ bad faith.
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 undersigned counsel to the Gwynn Plaintiffs filed Requests to Admit ("the
Requests") on defendants. The Court recently granted defendants further time to respond to the
Requests. The undersigned expects that at least several of defendants’ responses to the Requests
will be included as facts within the Memorandum in Opposition. Accordingly, the Gwynn
Plaintiffs should be permitted to file their Memorandum after receiving the defendants’ responses
to the Requests.

Case 3:03-cv-00644-CFD Document 217 Filed 10/23/2006 Page 3 of 4
5. The additional time is also required because of a serious illness within the family
of the undersigned.
6. Counsel to the Gwynn plaintiffs has communicated with counsel to defendants,
who has indicated he does not obj ect 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 l0, 2006 for
plaintiffs to file a memorandum in opposition to defendants’ Motion.
PLAINTIFFS, DAVID GVVYNN and i
RAQUEL GVVYNN
_¤j;g! i
By { \/ & _~ t
Mario DiNatale (ct 12449) g
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 217 Filed 10/23/2006 Page 4 of 4
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that a copy of the foregoing was sent via U.S. Mail, postage
prepaid, on this 23'd day of October, 2006, to:
Mark B. Seiger, Esq.
Charles F. Gfeller, Esq. {
Edwards Angell Palmer & Dodge LLP
90 State House Square
Hartford, CT 06103 Q
Peter M. Nolin, Esq. ,
Stephanie McLaughlin, Esq. pi
Sandak Hennessey & Greco LLP
707 Summer Street A g
Stamford, CT 06905 ,4
gf V {!\`_
M O DiNATALE €