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

Case 3:03-cv-00644-CFD

Document 335

Filed 05/15/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ) ) CIVIL ACTION NO. ) 3:03 CV 00644 (CFD) ) ) ) vs. ) ) NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA., and ) AIG TECHNICAL SERVICES, INC., ) Defendants ) ) DAVID W. GWYNN and RAQUEL GWYNN ) CIVIL ACTION NO. Plaintiffs, ) 3:03 CV 01154 (CFD) ) ) vs. ) ) NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA., and ) AIG TECHNICAL SERVICES, INC., ) Defendants ) ________________________________________________) MAY 15, 2008 PLAINTIFFS' CORRECTED MOTION FOR EXTENSION OF TIME TO DISCLOSE EXPERTS (superseding Dkt. # 332) The plaintiffs, David W. Gwynn and Raquel Gwynn (collectively, "the Gwynn plaintiffs"), through counsel, respectfully move this Court, pursuant to Fed. R. Civ. P. 6(b) and Local Rule 7(b)(1) for an extension of time of thirty days, up to and including June 14, 2008, to file the Gwynn plaintiffs' expert disclosures. The additional time requested is necessary in order to prepare the required disclosures, and will not delay the trial date of this matter. Counsel for the Gwynn plaintiffs has confirmed that the Ryan plaintiffs have no objection to the granting of this Motion and that counsel for defendants have no objection to this Motion BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITAL ASSOCIATES, INC. Plaintiffs,

Case 3:03-cv-00644-CFD

Document 335

Filed 05/15/2008

Page 2 of 3

provided that defendants are granted a comparable extension of the time for the disclosure of their experts. Accordingly, plaintiffs request that the Scheduling Order in this matter be modified as follows: Plaintiffs to Disclose Expert Witnesses: Depositions of Plaintiffs' Experts Completed: Defendants to Disclose Expert Witnesses: Depositions of Defendants' Experts Completed: June 14, 2008 July 14, 2008 August 14, 2008 September 14, 2008

This is the tenth Motion for the extension of deadlines in the Scheduling Order.

PLAINTIFFS, DAVID GWYNN and RAQUEL GWYNN By /s/ Jonathan M. Levine (ct07584) Silver Golub & Teitell, LLP 184 Atlantic Street Stamford, CT 06904 (203) 325-4491 (203) 325-3769 (Fax) [email protected]

Case 3:03-cv-00644-CFD

Document 335

Filed 05/15/2008

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CERTIFICATE OF SERVICE I hereby certify that on May 15, 2008, a copy of foregoing Motion for Extension of Time to Disclose Experts was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the 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 filing through the Court's CM/ECF System.

/s/ Jonathan M. Levine (ct 07584) SILVER GOLUB & TEITELL LLP 184 Atlantic Street P. O. Box 389 Stamford, CT 06904 203-325-4491 (telephone) 203-325-3769 (fax) [email protected]