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

Case 3:03-cv-00644-CFD Document 300 Filed 06/11/2007 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT Q
BRUCE CHARLES RYAN, RUSSELL WILLIAM )
NEWTON, ROBERT FITZPATRICK, and MERIT ) CIVIL ACTION NO.
CAPITAL ASSOCIATES, INC. ) 3:03 CV 00644 (CFD) ?
Plaintiffs, )
I
) 2
vs. )
)
NATIONAL UNION FIRE INSURANCE )
COMPANY OF PITTSBURGH, PA., and ) 2
AIG TECHNICAL SERVICES, INC., ) ‘
Defendants ) .
)
DAVID W. GW Y NN and RAQUEL GW Y NN ) CIVIL ACTION NO. j
Plaintiffs, ) 3:03 CV Ol 154 (CFD) i
I
) {
vs. ) I
) f
NATIONAL UNION FIRE INSURANCE ) p
COMPANY OF PITTSBURGH, PA., and )
AIG TECHNICAL SERVICES, INC., ) i
Defendants )
) JUNE ll, 2007
THE GVVYNN 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 has some continued personal health issues that need to be monitored
and treated within the next few weeks. This is the sixth request for modification of the

Case 3:03-cv-00644-CFD Document 300 Filed 06/11/2007 Page 2 of 3
Scheduling Order.
Plaintiffs request the following schedule:
(1) September 15, 2007: Plaintiffs to Disclose Expert Witnesses.
(2) October 15, 2007: Depositions of Plaintiffs’ Experts Completed.
(3) November 15, 2007: Defendants to Disclose Expert Witnesses.
(4) December 15, 2007: Depositions of Defendant’s Experts Completed.
(5) January 9, 2008, or thirty
(30) days following the ruling 1
on any dispositive motions,
whichever is later: Joint Trial Memorandum Filed. Y
I have communicated with counsel to all other parties in this matter, and there is no
objection to this Motion being granted.
WHEREFORE, the Plaintiffs respectfully request that the Court grant their Motion for
Modification of the Scheduling Order, as outlined above.
PLAINTIFFS, DAVID GWYNN and
RAQUEL GWYNN
By ’
Mar o DiNatale (ct 12449)
Sil er 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 300 Filed 06/11/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on June 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 filing system or by mail to anyone unable to accept electronic filing as
indicated on the Notice of Electronic Filing. Parties may access this tiling through the Court’s
CM/ECF System.
MARIO DINATALE (ct 12449) Q
SILVER GOLUB & TEITELL LLP P?
184 Atlantic Street §
P. O. Box 389
Stamford, CT 06904
Telephone: 203—325—4491 E
Fax: 203-325-3769 1
E-mail: [email protected]