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

Case 3:03-cv-00644-CFD

Document 195

Filed 07/13/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ) ) 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 ) ________________________________________________) JULY 13, 2006 PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO REPLY TO DEFENDANTS' ANSWER, SPECIAL DEFENSES AND COUNTERCLAIMS The Plaintiffs David W. Gwynn and Raquel Gwynn ("the Gwynn plaintiffs"), through counsel, hereby respectfully move pursuant to Fed. R. Civ. P. 6(b) and Local Rule 7(b)(1) for an extension of time of twenty-one (21) days to and including August 4, 2006, to reply and/or file motions with respect to defendants' May 24, 2006 Answer, Special Defenses and Counterclaims. In support of this motion, undersigned counsel states as follows: BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITOL ASSOCIATES, INC. Plaintiffs,

Case 3:03-cv-00644-CFD

Document 195

Filed 07/13/2006

Page 2 of 3

1.

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

with respect to this time limitation. 2. The additional time is required for the parties to discuss the counterclaims, to

possibly limit the issues for adjudication, and for counsel to conclude the necessary legal research. 3. The undersigned has inquired of counsel to co-plaintiffs and counsel to defendants

to determine their position with respect to this Motion. Counsel to co-plaintiffs does not object; the undersigned has been unable to determine whether counsel to defendants objects. Accordingly, for the above-stated reasons, the Gywnn plaintiffs respectfully request that this court grant an extension of time to and including August 4, 2006 for plaintiffs to reply and/or file motions with respect to defendants' Answer, Special Defenses and Counterclaims,.

PLAINTIFFS, DAVID GWYNN and RAQUEL GWYNN

By____/s/ Jonathan M. Levine__________ Jonathan M. Levine (ct 07584) Mario DiNatale (ct 12449) Silver 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 195

Filed 07/13/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on July 13, 2006, a copy of foregoing Plaintiffs' Motion for Extension of Time to Reply to Defendants' Answer, Special Defenses and Counterclaims 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. Mark B. Seiger, Esq. Charles F. Gfeller, Esq. Edwards Angell Palmer & Dodge LLP 90 State House Square Hartford, CT 06103 Peter M. Nolin, Esq. Stephanie McLaughlin, Esq. Sandak Hennessey & Greco LLP 707 Summer Street Stamford, CT 06905 ____/s/ Jonathan M.Levine_____________ Jonathan Levine (ct 07584) Mario DiNatale (ct 12449) Silver Golub & Teitell, LLP 184 Atlantic Street Stamford, CT 06904 (203) 325-4491 (203) 325-3769 (Fax) [email protected]