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

Case 3:03-cv-00644-CFD Document 108 Filed 09/21/2005 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE C ` ES RYAN, RUSSELL WILLIAM )
NEWTON, OBERT FITZPATRICK, and MERIT ) CASE NUMBER:
CAPITAL SSOCIATES, INC., ) 3:03 CV 00644 (CFD)
)
Plaintiffs, )
)
vs. )
)
NATIONAII UNION FIRE INSURANCE )
COMPANY i OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, H~IC., )
)
Defendants. )
DAVID W. GWYNN, RAQUEL GWYNN AND )
GWYNN FINANCIAL SERVICES, INC. ) CASE NUMBER:
) 3:03 CV 1154 (CFD)
Plaintiffs, )
)
vs. )
)
NATIONAL UNION FIRE INSURANCE )
COMPANY i OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., ) September 20, 2005
A )
Defendants. )
MOTION FOR EXTENSION OF TIME
Defendants National Union Fire Insurance Company of Pittsburgh, Pa. and AIG
Technical Services, Inc., now known as AIG Domestic Claims, Inc. ("AIGTS") (hereinafter
referred to collectively as "National Uni0n"), by their attorneys 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) to extend the discovery deadlines as set forth in the Modified Scheduling Order as listed
below:
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Case 3:03-cv-00644-CFD Document 108 Filed O9/21/2005 Page 2 of 4
January 3, 2006 Fact Discovery to be completed
January 16, 2006 Plaintiffs to disclose their expert witnesses
February 28, 2006 Depositions of Plaintiffs’ experts to be completed
February 28, 2006 Defendants to disclose their expert witnesses
April 14, 2006 Depositions of Defendants’ experts to be completed
May 12, 2006 Dispositive motions to be filed
July 5, 2006 Joint Trial Memorandtun to be filed (if no dispositive
motions; otherwise, 60 days alter all dispositive motions
have been ruled on)
In support of this motion, undersigned counsel states as follows:
l. This is National Union’s first request for an extension of time with regard to this
time limitation.
2. Counsel for National Union has contacted counsel for Plaintiffs in both the
consolidated Ryan and Gwynn actions regarding this extension. Counsel for Plaintiffs in both
actions have consented to this extension.
3. The requested extension is necessary to complete discovery in this matter.
National Union has been working diligently to conduct discovery that, due to the complex nature
of this matter, requires additional time.
4. Additional witnesses still need to be deposed, several of whom are located
throughout the country. In addition, some of the witnesses include several third parties with
whom we need to coordinate scheduling.
5. There are a number of jurisdictional motions pending before the Court that may
affect the scope of discovery.
6. National Union has just recently filed an Amended Answer, Affirmative Defenses
and Counterclaims to the Ryan Amended Complaint which may necessitate additional discovery.
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Case 3:03-cv-00644-CFD Document 108 Filed 09/21/2005 Page 3 of 4
For the reasons stated above, National Union respectfully requests that this Court extend
the deadlines to complete discovery and other pretrial proceedings from the dates set forth in the
Modified Scheduling Order granted June 22, 2005 to the dates set forth above and for such other
and further relief that the Court may deem just and proper.
DEFENDANTS NATIONAL UN N FIRE
INSURANCE COMPANY OF PITT URG A.
and ICAL SER ES C.
By:) ` *
s R. Hawkins II (ct00128)
1lliam M. Tong (ct25304)
irm Dixon & Herling LLP
r “ One Landmark Square, Suite 1400
Stamford, CT 06901-2689
Tel: (203) 325-5000
Fax: (203) 348-5777
Email: [email protected]
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Case 3:03-cv-00644-CFD Document 108 Filed 09/21/2005 Page 4 of 4
CERTIFICATION
This is to certify that a true and correct copy of the foregoing was sent by United
States mail, first class, postage prepaid to the following this 20"` day of September, 2005:
Peter M. Nolin, Esq.
Jay H. Sandak, Esq.
Sandak Hemiessey & 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)
i gées R. Hawkins II
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