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

Case 3:03-cv-00644-CFD Document 16 Filed O1/15/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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BRUCE CHARLES RYAN, RUSSELL WILLIAM :
NEWTON, ROBERT FITZPATRICK, and MERIT :
CAPITAL ASSOCIATES, INC., : 3:03 CV 00644(CFD)
Plaintiffs, E
vs.
NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, PA., and :
AIG TECHNICAL SERVICES, INC., : January 14, 2004
Defendants.
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MOTION FOR EXTENSION OF TIME
Defendants National Union Fire Insurance Company of Pittsburgh, PA.("National
Union") and AIG Technical Services, Ir1c.("AIGTS") hereby respectfully move pursuant to Fed.
R. Civ. P. 6(b)(l) and D. Conn. L. Civ. R. 7 (b)(3) for an extension of time of seven (7) days Hom
January 16, 2004 to and including January 23, 2004 to answer, move against, or otherwise
respond to the amended complaint filed by plaintiffs in this action. In support of this motion,
undersigned counsel states as follows:
l. This is the second request for an extension of time made by defendants National
Union and AIGTS with respect to this time limitation.
2. By order of the Court dated October 14, 2003, this case has been consolidated
with Gwynn, et al v. National Union, et al, Docket Nmnber 3:03 CV 01154 (CFD)("Qw}nm").
3. A simultaneous motion for extension of time is being filed in Gwyn.
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Case 3:03-cv-00644-CFD Document 16 Filed O1/15/2004 Page 2 of 3
4. Plaintiffs served an Amended Complaint on December 15, 2003. The
undersigned had hoped to complete defendants’ responses by January 16, 2004. Unfortimately
due to unexpected accidents and illnesses of close friends and relatives, the responses can not be
completed before January 23, 2004. ‘
5. Counsel for plaintiffs in this case and in @$2 consent to the requested
extension. A V
For the above-stated reasons, defendants National Union and AIGTS respectfully
requests that this court grant an extension of time to and including to and including January 23,
2004 for National Union & AIGTS to answer, move against, or otherwise respond to the
amended complaint tiled by plaintiffs in this action.
DEFENDANTS
NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, P . and
, AL SERVICES C.
//
By; — c ’ —-··· ‘<¢.
ames . Hawkins II (ct 00128)
FINN DIXON _& HERLING LLP
One Landmark Square
‘ y Stamford, CT 06901-2689
Tel: (203) 325-5000
Fax: (203) 348-5777
Email: [email protected]
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Case 3:03-cv-00644-CFD Document 16 Filed O1/15/2004 Page 3 of 3
CERTIFICATION
I hereby certify that a true and correct copy of the foregoing was mailed, United States
mail, first class, postage prepaid to the following on this the 14th day of January, 2004:
Mario DiNata1e, Esq.
Silver, Golub and Teitell
184 Atlantic Street
P.O. Box 389 A
‘ Stamford, CT 06904
Peter M. Nolin, Esq.
Sandak Hennessey & Greco
970 Summer Street M
Stamford, CT 069O_§,...r~r·7”“"”
q ~ Q7
ames R. Hawkins II
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