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

Case 3:03-cv—00644-CFD Document 314 Filed 12/12/2007 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. 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 )
) DECEMBER 12, 2007
THE GWYNN PLAINTIFFS’ MOTION FOR MODIFICATION OF SCHEDULING
ORDER
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 three months that have required two
separate surgeries. His hospitalizations and subsequent medical treatment has limited his ability

Case 3:03-cv—00644-CFD Document 314 Filed 12/12/2007 Page 2 of 3
to work. His condition, however, has improved within the last two weeks. This is the eighth
request for modification of the Scheduling Order.
The Gwynn Plaintiffs request the following modified schedule:
(1) March 15, 2008: Plaintiffs to Disclose Expert Witnesses.
(2) April 15, 2008: Depositions of Plaintiffs’ Experts Completed.
(3) May 15, 2008: Defendants to Disclose Expert Witnesses.
(4) June 15, 2008: Depositions of Defendant’s Experts Completed.
(5) July 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. All counsel to all
other parties do not obj ect 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 GWYNN and
RAQUEL GWYNN
ario DiNatale (ct 12449)
ilver Golub & Teitell, LLP
184 Atlantic Street
Stamford, CT 06904
(203) 325~449l
(203) 325-3769 (Fax)
mdinatale@,sgtlaw.com

Case 3:03-cv—00644-CFD Document 314 Filed 12/12/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on December 12, 2007, 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—mai1 to all parties by
operation of the Court’s electronic tiling system or by mailto 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.
MEQO DINATALE (ct 12449)
SILVER GOLUB & TEITELL LLP
184 Atlantic Street
P. O. Box 389
Stamford, CT 06904
Telephone: 203-325-4491
Fax: 203-325-3769
E-mail: mdinatale s law.com