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

Case 3:03-cv-00644-CFD

Document 193

Filed 06/16/2006

Page 1 of 3

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 ) ________________________________________________) JUNE 14, 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-eight (28) days to and including July 14, 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 193

Filed 06/16/2006

Page 2 of 3

1.

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

respect to this time limitation. 2. Counsel to plaintiffs has conferred with counsel to defendants, and defendants do

not object to the requested extension. Plaintiff has been unable to ascertain, as of the time this is being filed, whether counsel to the co-plaintiffs objects to the requested extension. Accordingly, for the above-stated reasons, the Gywnn plaintiffs respectfully request that this court grant an extension of time to and including July 14, 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__________________________________ 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 193

Filed 06/16/2006

Page 3 of 3

CERTIFICATE OF SERVICE THIS IS TO CERTIFY that a copy of the foregoing was sent via U.S. Mail, postage prepaid, on this 14th day of June, 2006, to: 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 ______________________________ MARIO DiNATALE