Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:03-cv—O0644-CFD Document 316 Filed O3/05/2008 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL WILLIAM )
NEWTON, ROBERT FITZPATRICK, and MERIT ) CIVIL ACTION NO.
CAPITAL ASSOCIATES, INC. ) 3:03 CV 00644 (CFD)
Plaintiffs, )
>
vs. )
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants )
>
DAVID W. GW YNN and RAQUEL GW YNN ) CIVIL ACTION NO.
Plaintiffs, ) 3:03 CV 01154 (CFD)
)
)
vs. )
l
‘ NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., )
Defendants )
) MARCH 5, 2008
THE GWYNN PLAINTIFFS’ MOTION FOR MODIFICATION OF SCHEDULING
Plaintiffs, David Gwynn and Raquel Gwynn, by and through their undersigned counsel,
hereby move for a modification of the Scheduling Order. Fact discovery is complete, and the
proposed modification relates to expert disclosure and other matters. The reason for this request
is that undersigned counsel had health issues within the past several months that have required s
limited his ability to work. This is the eighth request for modification of the Scheduling Order.

Case 3:03-cv—O0644-CFD Document 316 Filed O3/05/2008 Page 2 of 3
The Gwynn Plaintiffs request the following modified schedule:
(1) May 15, 2008: Plaintiffs to Disclose Expert Witnesses.
(2) June 15, 2008: Depositions of Plaintiffs’ Experts Completed.
(3) July 15, 2008: Defendants to Disclose Expert Witnesses.
(4) August 15, 2008: Depositions of Defendant’s Experts Completed.
(5) September 9, 2008, or thirty
(30) days following the ruling
on any dispositive motions,
whichever is later: Joint Trial Memorandum Filed.
I have communicated with counsel to all other parties in this matter, and there is no
objection to this request.
WHEREFORE, the Gwynn Plaintiffs respectfully request that the Court grant their
Motion for Modification of the Scheduling Order, as outlined above.
PLAINTIFFS, DAVID GVVYNN and
RAQUEL WYNN
M `o DiNatale (ct 12449)
Silver Golub & Teitell, LLP
184 Atlantic Street
Stamford, CT 06904
(203) 325-4491
(203) 325-3769 (Fax)
mdinata1e@,sgtlaw.com

Case 3:03-cv—O0644-CFD Document 316 Filed O3/05/2008 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on March 5, 2008, a copy of foregoing Motion for Modification of
the Scheduling Order 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
Cou1t’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 Cou1t’s
CMJECF System.
MARI DINATALE (ct 12449)
SILVER GOLUB & TEITELL LLP
184 Atlantic Street
P. O. Box 389
Stamford, CT 06904
Telephone: 203—325—449l
Fax: 203-325-3769
E-mail: [email protected]