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

Case 3:03-cv-00644-CFD Document 212 Filed O9/27/2006 Page 1 of 4
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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BRUCE CHARLES RYAN, RUSSELL )
WILLIAM NEWTON, ROBERT FITZPATRICK, )
and MERIT CAPITAL ASSOCIATES, INC., )
Plaintiffs, )
) CIVIL ACTION NO. i
v. ) 3 :03CVOO644(CFD)
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NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants. )
I DAVID W. GWYNN and RAQUEL GWYNN, )
. Plaintiffs, ) CIVIL ACTION NO.
v. ) 3:03CVOI I 54(CFD)
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NATIONAL UNION FIRE INSURANCE )
` COMPANY OF PITTSBURGH, PA., and )
s AIG TECHNICAL SERVICES, INC., )
Defendants. )
_ ) SEPTEMBER 27, 2006
DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
. THE GWYNN PLAINTIFFS' FIRST REQUEST FOR ADMISSIONS
Defendants, National Union Fire Insurance Company of Pittsburgh, PA. and AIG
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Teclmical 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 twenty (20) days, through and
including October 19, 2006, to serve responses to The Gwynn Plaintiffs' First Request for
Admissions Directed to Defendant AIG Technical Services, Inc. ("First Request for
Ad1nissions"), and in support thereotj state as follows:

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Case 3:03-cv-OO644-CFD Document 212 Filed O9/27/2006 Page 2 of 4
1. AIG’s response to the Gwynn Plaintift`s’ First Request for Admissions is due on
or before September 28, 2006.
2. Additional time is needed for AIG to complete and serve its responses to the

requests for admission due to the sudden severe illness of the responsible attorneys father.
3. The Gwynn Plaintiffs' counsel, Mario DiNatale, has represented that he has no
objection to an enlargement of time of twenty (20) days for AIG to serve its responses to the
requests for admission.
4. This is the {rst request for an enlargement of time for AIG with respect to the
Gwynn Plaintiffs First Request for Admissions.
WHEREFORE, AIG respectfully requests that this Court to enter an order granting an
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enlargement of time of twenty (20) days, through and including October 19, 2006, for AIG to
serve its responses to The Gwynn Plaintiffs First Request for Admissions Directed to Defendant
AIG Technical Services, Inc.

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Case 3:03-cv-OO644-CFD Document 212 Filed O9/27/2006 Page 3 of 4
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‘ Respectfully Submitted,
DEFENDANTS/COUNTERPLAHQTIFFS
NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, PA.
and AIG TECHNICAL SERVICES, IN C. t
BY THEIR ATTORNEYS,
Edwards An odge LLP
By: J
Mark B. Seiger
Fed. Bar No. ct05580
David S. Samuels
Fed. Bar No. ct 24460
90 State House Square
Hartford, CT 06103-2715
Tel: (860) 525-5065
Fax: (860) 527-4198
Email: mseiger@,eapd1aw.com
John D. Hughes
Bso # 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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Case 3:03-cv-00644-CFD Document 212 Filed 09/27/2006 Page 4 of 4
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CERTIFICATION OF SERVICE
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I hereby certify that on September 27, 2006, a copy ofthe foregoing Defendant’s Motion
For Enlargement Of Time To Respond To The Gwynn Plaintiffs' First Request For Admissions
was tiled electronically and served by mail on anyone unable to accept electronic tiling. Notice
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of this tiling will be sent by email to all parties by operation ofthe cou1t’s electronic tiling
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, 93] Floor
Hartford, CT 06103
Phone: $60525.5065
Fax: $60527.4198
Email: [email protected]

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