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

Case 3:03-cv-00644-CFD

Document 327

Filed 04/29/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITAL ASSOCIATES, INC. Plaintiffs, ) ) 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 ) ________________________________________________) APRIL 29, 2007 PLAINTIFFS' JOINT MOTION FOR EXTENSION OF TIME TO RESPOND AND/OR OBJECT TO DEFENDANTS' MOTION FOR RECONSIDERATION AND INCORPORATED MEMORANDUM OF LAW The plaintiffs, David W. Gwynn and Raquel Gwynn (collectively, "the Gwynn plaintiffs"), and plaintiffs, Bruce Charles Ryan, Russell William Newton, Robert Fitzpatrick and Merit Capital Associates, Inc. (collectively, "the Ryan 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 ten days, up to and including May 15, 2008, to file a response and/or objection to Defendants' April 14, 2008 Motion for Reconsideration and Incorporated Memorandum of Law ("defendants' motion"). In support of this motion, undersigned counsel states as follows:

Case 3:03-cv-00644-CFD

Document 327

Filed 04/29/2008

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This is the first request for extension of time made by the Gwynn plaintiffs and

the Ryan plaintiffs with respect to this time limitation. 2. The additional time is required because counsel for the Gwynn plaintiffs has a

number of competing deadlines limiting the time available to prepare an objection or response. 3. Prior to filing this Motion, counsel for the Gwynn plaintiffs confirmed that

counsel to defendants has no objection to this Motion. Accordingly, for the above-stated reasons, the Gwynn plaintiffs and the Ryan plaintiffs respectfully request that this court grant an extension of time to and including May 15, 2008 for plaintiffs to file a response or objection to defendants' motion. PLAINTIFFS, DAVID GWYNN and RAQUEL GWYNN By Jonathan M. Levine (ct07584) Silver Golub & Teitell, LLP 184 Atlantic Street Stamford, CT 06904 (203) 325-4491 (203) 325-3769 (Fax) [email protected] PLAINTIFFS, BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITAL ASSOCIATES, INC. By /s/ Stephanie A. McLaughlin (ct22774) Sandak Hennessey & Greco LLP 707 Summer Street Stamford, CT 06901-1026 (203) 425-4200 (203) 325-8608 (fax) [email protected]

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Case 3:03-cv-00644-CFD

Document 327

Filed 04/29/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on April 29, 2008, a copy of foregoing Joint Motion for Time to Respond and/or Object to Defendants' Motion for Reconsideration and Incorporated Memorandum of Law 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]

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