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

Case 3:03-cv-00644-CFD Document 129 Filed 11/O4/2005 Page 1 of 3 I
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE C
NEWTON, ROBERT FITZPATRICK, and MERIT ) CASE NUMBER: i`
CAPITAL _ SSOCIATES, INC., ) 3:03 CV 00644 (CFD)
)
Plaintiffs, )
Y
vs. )
)
NATION UNION FIRE INSURANCE )
COMP OF PITTSBURGH, PA., and )
AIG TEC p CAL SERVICES, INC., )
)
Defendants. )
DAVID W.1GWYNN, RAQUEL GWYNN AND )
GWYNN FINANCIAL SERVICES, INC. ) CASE NUMBER:
) 3:03 CV 1154 (CFD)
» Plaintiffs, )
V
vs. )
)
NATION UNION FIRE INSURANCE )
COMP OF PITTSBURGH, PA., and )
AIG TEC p CAL SERVICES, H\IC., ) November 4, 2005
)
Defendants. )
MOTION FOR EXTENSION OF TIME
Defendants National Union Fire Insurance Company of Pittsburgh, Pa. and AIG
Technical $ervices, Inc., now known as AIG Domestic Claims, Inc. ("AIGTS") (hereinafter
referred to collectively as "National Union"), by their attomeys Finn Dixon & Herling LLP,
hereby respectfully move this Court pursuant to FED. R. CIV. P. 6(b)(l) and D. CONN. L. CIV. R.
7(b)(3) for an extension of time of fourteen (14) days, to and including November 18, 2005, to

Case 3:03-cv-00644-CFD Document 129 Filed 11/O4/2005 Page 2 of 3
respond td the Second Amended Complaint of the Plaintiffs in the above-captioned Gwynn i
Action (the "Gwynn Action"). In support of this motion, undersigned counsel states as follows: 7
1. This is National Union’s first request for an extension of time with regard to this
time limitation.
2. Counsel for National Union has spoken with the Gwynn Plaintiffs’ counsel, and
he has consented to this extension.
3. On October 22, 2005, National Union received electronic notice from the Court of
the iiling ofthe Gwynn Plaintiffs’ Second Amended Complaint. .
4. The requested extension is necessary to research and adequately respond to the
issues raisdd by the Second Amended Complaint and to address additional facts that have come
to light since the Gwynn Plaintiffs’ prior amendment on or about September 29, 2003. V
WHEREFORE, for the reasons stated above, National Union respectfully requests that
this Court grant an extension of time of fourteen (14) days, to and including November 18, 2005,
to respond to the Second Amended Complaint of the Plaintiffs in the above-captioned Gwynn
Action (the "Gwynn Action”), along with such other and further relief as the Court may deem
just and proper.
DEFENDANTS NATIONAL UNION FIRE
INSURANCE COMPANY OF PI SB GH, PA.
and AIG TECHNICAL SERVIC , IN .
By: _ ‘ T'
es R. H wkins H (ct00l28)
illiam M. Tong (ct25304)
Finn Dixon & Herling LLP
One Landmark Square, Suite 1400
Stamford, CT 06901-2689
Tel: (203) 325-5000
p F3X2 (203) 348-5777
Email: [email protected]
2
{00168541; l;O(140-3}

Case 3:03-cv-00644-CFD Document 129 Filed 11/04/2005 Page 3 of 3
CERTIFICATION
This is to certify that a true and correct copy of the foregoing was sent by United
States mail, iirst class, postage prepaid to the following this 4th day of November, 2005:
Peter M. Nolin, Esq.
Jay H. Sandak, Esq.
Sandak Hennessey & Greco LLP
707 Summer Street
Stamford, CT 06905
(203) 425-4200
(203) 325-8608 (fax)
Mario DiNatale, Esq.
Jonathan M. Levine, Esq.
Silver Golub & Teitell LLP
184 Atlantic Street
Stamford, CT 06904
(203) 325-4491
(203) 325-3769 (fax)
<` -
William M. Tong
3
{00168541; 1; 0040-3} ‘