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

Case 3:03-cv-00644-CFD

Document 175

Filed 04/06/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

__________________________________________ BRUCE CHARLES RYAN, RUSSELL ) WILLIAM NEWTON, ROBERT FTIZPATRICK ) and MERIT CAPITAL ASSOCIATES, INC., ) Plaintiffs, ) ) v. ) ) NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA., and ) AIG TECHNICAL SERVICES, INC., ) Defendants. ) __________________________________________) DAVID W. GWYNN, RAQUEL GWYNN and ) GWYNN FINANCIAL SERVICES, INC., ) Plaintiffs, ) v. ) ) NATIONAL UNION FIRE INSURANCE ) COMPANY OF PITTSBURGH, PA., and ) AIG TECHNICAL SERVICES, INC., ) Defendants. )

CIVIL ACTION NO. 3:03CV00644(CFD)

CIVIL ACTION NO. 3:03CV01154(CFD)

APRIL 6, 2006

PLAINTIFFS= MOTION FOR EXTENSION OF TIME NUNC PRO TUNC Plaintiffs Bruce Charles Ryan, Russell William Newton, Robert Fitzpatrick, and Merit Capital Associates, Inc. (collectively "Plaintiffs") hereby move for an extension of time nunc pro tunc to file a response to Defendants' Rule 72 Objections to Magistrate's Ruling on Plaintiffs' Motion to Compel and for sanctions and Defendants' Motion for Protective Order dated March 14, 2006 (the "Objection"). Plaintiffs seek an extension through and including Monday, April 10, 2006. Pursuant to Local Rule 7, Plaintiffs should have filed their response to the Objection on April 4, 2006. Plaintiffs submit that they inadvertently failed to file a timely response due to a calendaring error. This brief extension will not prejudice any of the parties.

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Case 3:03-cv-00644-CFD

Document 175

Filed 04/06/2006

Page 2 of 3

The undersigned contacted Defendants' counsel to inquire as to whether he would consent to this motion for extension of time. Defendants' counsel has not yet responded to that inquiry. Therefore, at this point, Plaintiffs cannot represent whether Defendants' counsel consents or objects to this motion. Wherefore, Plaintiffs move for an extension of time to file a response to Defendants' Rule 72 Objections to Magistrate's Ruling on Plaintiffs' Motion to Compel and for sanctions and Defendants' Motion for Protective Order to April 10, 2006. PLAINTIFFS, BRUCE CHARLES RYAN, RUSSELL WILLIAM NEWTON, ROBERT FITZPATRICK, and MERIT CAPITAL ASSOCIATES INC.,

By_________/s/____________________ Peter M. Nolin (ct06223) Stephanie A. McLaughlin (ct22774) Sandak Hennessey & Greco LLP 707 Summer Street Stamford, CT 06901 (203) 425-4200 (203) 325-8608 (fax) [email protected] [email protected]

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Case 3:03-cv-00644-CFD

Document 175

Filed 04/06/2006

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on April 6, 2006, a copy of the foregoing document 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 on anyone unable to accept electronic filing. Parties may access this filing through the Court's system.

_______/s/_______________ Stephanie A. McLaughlin

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