Free Motion to Expedite - District Court of Connecticut - Connecticut

Case 3:01-cv-02198-PCD

Document 388

Filed 10/29/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SECURITY INSURANCE COMPANY OF HARTFORD, Plaintiff, -againstTRUSTMARK INSURANCE COMPANY, Defendant. TRUSTMARK INSURANCE COMPANY, Third-Party Plaintiff, -againstTIG INSURANCE COMPANY, Third-Party Defendant. October 29, 2004 Civil No. 3:01CV2198 (PCD)

MOTION OF THIRD PARTY PLAINTIFF TIG INSURANCE COMPANY FOR EXPEDITED CONSIDERATION OF ITS MOTION FOR LEAVE TO SERVE ADDITIONAL INTERROGATORIES AND TO REQUIRE THIRD PARTY DEFENDANT TRUSTMARK INSURANCE COMPANY TO RESPOND TO THE INTERROGATORIES ON AN EXPEDITED BASIS Third Party Defendant TIG Insurance Company ("TIG"), through its counsel, hereby moves this Court For Expedited Consideration of its Motion for Leave to Serve Additional Interrogatories and to Require Third Party Defendant Trustmark Insurance Company ("Trustmark") to Respond to the Interrogatories on an Expedited Basis. The bases for this motion are set forth in TIG's memorandum of law in support of its motion to compel discovery from Trustmark, which TIG has filed on this same date.

Case 3:01-cv-02198-PCD

Document 388

Filed 10/29/2004

Page 2 of 3

There is good cause for expedited consideration of this matter since the parties have recently submitted a Joint Motion for Entry of a Scheduling Order, pursuant to which the deadline in this action could be as early as January 7, 2005. WHEREFORE, TIG respectfully requests that the Court consider its Motion on an expedited basis for good cause shown and issue an order: (a) granting TIG's motion for leave to serve on Trustmark its Second Set of Interrogatories; and (ii) requiring Trustmark to respond to TIG's Second Set of Interrogatories by no later than November 26, 2004.

THIRD PARTY DEFENDANT By: J. Daniel Sagarin CT 04289 David Slossberg CT 13116 Brian C. Fournier CT 16272 Hurwitz, Sagarin & Slossberg, LLC 147 North Broad Street Milford, Connecticut 06460-0112 Tel.: (203) 877-8000 Fax: (203) 878-9800 -andLawrence I. Brandes, CT 23789 Harry P. Cohen, CT 20446 Brian J. O'Sullivan CT 23790 Cadwalader, Wickersham & Taft 100 Maiden Lane New York, NY 10038 Telephone: 212-504-6000 Facsimile: 212-504-6666 Attorneys for Third-Party Defendant TIG Insurance Company

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Case 3:01-cv-02198-PCD

Document 388

Filed 10/29/2004

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that on October 29, 2004, a true and correct copy of the foregoing was sent via facsimile and mailed, postage prepaid, first class mail, to:

Frank F. Coulom, Jr., Esq. Marion B. Manzo, Esq. Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103-3597 Attorneys for Plaintiff

Alia L. Smith Christine Y. Wong, Esq. Mark B. Holton, Esq. James L. Hallowell, Esq. Kathryn E. Nealon, Esq. Gibson, Dunn & Crutcher LLP 200 Park Avenue, 47th Floor New York, NY 10166-0193 Attorneys for Plaintiff

David J. Grais, Esq. Erick M. Sandler, Esq. Robert J. Morrow, Esq. Kathryn C. Ellsworth, Esq. Dewey Ballantine LLP 1301 Ave of the Americas New York, NY 10019-6092 Attorneys for Plaintiff

David R. Schaefer, Esq. Rowena A. Moffett, Esq. Brenner, Saltzman & Wallman 271 Whitney Avenue P.O. Box 1746 New Haven, CT 06511-1746 Attorneys for Defendant, Third Party Plaintiff

David M. Spector, Esq. Everett J. Cygal, Esq. Ronald S. Safer, Esq. Amy M. Rubenstein, Esq. Michael Mullins, Esq. Paula J. Morency, Esq. William E. Meyer, Jr., Esq. Dennis G. LaGory, Esq. Sharon A. Doherty, Esq. Schiff Hardin & Waite 6600 Sears Tower Chicago, IL 60606-6473 Attorneys for Defendant, Third Party Plaintiff

____________________________________ Brian C. Fournier