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

Case 3:03-cv-00644-CFD Document 307 Filed 09/11/2007 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BRUCE CHARLES RYAN, RUSSELL WILLIAM ) C
NEWTON, ROBERT FITZPATRICK, and MERIT ) CIVIL ACTION NO. {
CAPITAL ASSOCIATES, INC. ) 3:03 CV 00644 (CFD) L
Plaintiffs, ) Q
l
) j
vs. ) .
)
NATIONAL UNION FIRE INSURANCE ) i
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., ) ,
Defendants )
) 2
DAVID W. GW Y N N and RAQUEL GW Y NN ) CIVIL ACTION NO.
Plaintiffs, ) 3:03 CV Ol 154 (CFD)
) I
) I
vs. )
) ¢
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and ) I
AIG TECHNICAL SERVICES, INC., ) ._
Defendants )
) SEPTEMBER 11, 2007 Q
THE GWYNN PLAINTIFFS’ MOTION FOR MODIFICATION OF SCHEDULING
ORDER S
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 has some continued personal health issues that need to continue to be l
monitored and treated within the next few weeks or months. This is the seventh request for

Case 3:03-cv-00644-CFD Document 307 Filed 09/11/2007 Page 2 of 3
modification of the Scheduling Order.
Plaintiffs request for the following modified schedule:
(1) December 15, 2007: Plaintiffs to Disclose Expert Witnesses.
(2) January 15, 2008: Depositions of Plaintiffs’ Experts Completed.
(3) February 15, 2008: Defendants to Disclose Expert Witnesses.
(4) March 15, 2008: Depositions of Defendant’s Experts Completed.
(5) April 9, 2008, or thirty
(30) days following the ruling r
on any dispositive motions,
whichever is later: Joint Trial Memorandum Filed. q
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 Plaintiffs respectfully request that the Court grant their Motion for r
Modification of the Scheduling Order, as outlined above.
PLAINTIFFS, DAVID GVVYNN and
RAQUEL G NN Y;
By *`·"‘
Mario iNatale (ct 12449)
Silver Golub & Teitell, LLP A
184 Atlantic Street
Stamford, CT 06904
(203) 325-4491
(203) 325-3769 (Fax)
mdinatalegagsgtlawcom

Case 3:03-cv-00644-CFD Document 307 Filed 09/11/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on September 11, 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-mail to all parties by
operation of the Court’s electronic tiling system or by mail to anyone unable to accept electronic i
filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the g
Court’s CM/ECF System. I
MARIO DINATALE (ct 12449) l
SILVER GOLUB & TEITELL LLP I
184 Atlantic Street E
P. O. Box 389
Stamford, CT 06904 P
Telephone: 203-325-4491 —
Fax: 203-325-3769 A
E-mail: [email protected]