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

Case 3:03-cv-00644-CFD Document 216 Filed 10/17/2006 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL )
WILLIAM NEWTON, ROBERT FITZPATRICK, ) [
and MERIT CAPITAL ASSOCIATES, INC., )
Plaintiffs, )
) CIVIL ACTION NO.
v. ) 3:03CV00644(CFD)
>
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants. )
>
DAVID W. GWYNN and RAQUEL GWYNN, )
Plaintiffs, ) CIVIL ACTION NO.
v. ) 3 :03 CV0l l54(CFD) |
l
NATIONAL UNION FIRE INSURANCE ) ‘
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., ) g
Defendants. )
) OCTOBER 17, 2006
DEFENDANT’S CONSENTED TO MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO THE GVVYNN PLAINTIFFS’ FIRST REQUEST FOR ADMISSIONS
Defendants, National Union Fire Insurance Company of Pittsburgh, PA. and AIG {
Technical Services, Inc. (collectively, "AIG" or “Defendants"), through its undersigned attorneys
and pursuant to Federal Rule of Civil Procedure 36(a) and Local Rule 7(b)(l), hereby
respectfully move this Court for an enlargement of time of fourteen (14) days, through and
including November 2, 2006, to serve responses to The Gwynn Plaintiffs’ First Request for
Admissions Directed to Defendant AIG Technical Services, Inc. ("First Request for
` Admissions”), and in support; thereof, state as follows:

Case 3:03-cv-00644-CFD Document 216 Filed 10/17/2006 Page 2 of 4
I. AIG, via its unobjected-to motion for extension of time, requested an extension
until October I9, 2006 to respond to the Gwynn P1aintiffs’ First Request for Admissions.;
2. Additional time is needed for AIG to complete and serve its responses to the
requests for admissions due to the responsible attorney’s family member being severely ill.
3. The Gwynn Plaintiffs’ counsel, Mario DiNatale, has represented that he has no l
objection to an enlargement of time of fourteen (I4) days for AIG to serve its responses to the
requests for admission.
4. This is the second request for an enlargement of time for AIG with respect to the
t
Gwynn Plaintiff’s First Request for Admissions.
WHEREFORE, AIG respectfully requests that this Court to enter an order granting an
enlargement of time of fourteen (I4) clays, through and including November 2, 2006, for AIG to
serve its responses to The Gwynn Plaintiffs’ First Request for Admissions Directed to Defendant U
AIG Technical Services, Inc.
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‘ The com has not yet ruled on the motion for extension oftime.
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Case 3:03-ov-00644-CFD Document 216 Filed 10/17/2006 Page 3 of 4
Respectfully Submitted,
DEFENDANTS/COUNTERPLAINTIFF S
NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, PA.
and AIG TECHNICAL SERVICES, INC.
BY THEIR ATTORNEYS,
Edwards Angell Palmer & Dodge LLP
BY
Mark B. Seiger 1
Fed. Bar No. ct05 5 80
David S. Samuels
Fed. Bar No. ct 24460 (
90 State House Square 1
Hartford, CT 06103-2715
Tel: (860) 525-5065
Fax: (860) 527-4198
Email: [email protected]
John D. Hughes
BBO # 243660
101 Federal Street
Boston, MA 02110 (
Tel: (617) 439-4444
Fax: (617) 439-4170
Email: [email protected]
Donna M. Greenspan
Florida Bar No.: 059110
One North Clematis Street
Suite 400
West Palm Beach, FL 33401
Tel: (561) 833-7700
Fax: (561) 655-8719
Email: [email protected]
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I
Case 3:03-cv-00644-CFD Document 216 Filed 10/17/2006 Page 4 of 4
CERTIFICATION OF SERVICE
I hereby certify that on October 17, 2006, a copy ofthe foregoing Defendant’s Motion
For Enlargement Of Time To Respond To The Gwynn Plaintiffs’ First Request For Admissions
was filed electronically and served by mail on anyone unable to accept electronic filing. Notice
of this tiling will be sent by email to all parties by operation ofthe court’s electronic filing
system or by mail to anyone unable to accept electronic filing as indicated on the Notice of
Electronic Filing. Parties may access this document through the court’s CM/ECF System.
David S. Samuels, Esq. (ct24460)
Edwards Angell Palmer & Dodge LLP
90 State House Square, 9th Floor
Hartford, CT 06103
Phone: $60525.5065
Fax: $60527.4198
Email: [email protected]

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