Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:01-cv-00872-JBA

Document 105

Filed 10/19/2005

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT Travelers Casualty & Surety Co. (f/k/a The Aetna Casualty and Surety Co., Plaintiff, vs. Gerling Global Reinsurance Corp. of America (f/k/a Constitution Reinsurance Corp.), Defendant. ) ) ) ) ) ) ) ) ) ) ) ) CIVIL ACTION NO. 3:01-cv-872 (JBA)

October 19, 2005

MOTION FOR EXTENSION OF TIME Pursuant to Federal Rule of Civil Procedure 6(b) and Local Rule 7(b), Plaintiff Travelers Casualty & Surety Co. (f/k/a The Aetna Casualty and Surety Co.) ("Travelers") respectfully requests an extension of time from October 24, 2005 to October 31, 2005 to file its reply in further support of its Motion for Entry of Judgment. In support of this motion, Travelers states as follows: 1. 2. On September 16, 2005, Travelers filed a Motion for Entry of Judgment. On October 7, 2005, Defendant Gerling Global Reinsurance Corp. of

America (f/k/a Constitution Reinsurance Corp.) ("Gerling") filed an Opposition to Travelers' Motion for Entry of Judgment. 3. In connection with the arguments raised in Gerling's Opposition, Travelers

has brought certain facts to the attention of Gerling, and the parties are considering their positions and arguments as a result thereof. The parties request additional time to address these matters prior to the time that any reply brief is due.

Case 3:01-cv-00872-JBA

Document 105

Filed 10/19/2005

Page 2 of 3

4.

Pursuant to Local Rule 7(b), on October 19, 2005, Defendant's co-

counsel, Mark Sheridan, was advised of this request, and he consents and joins in this motion for extension of time. 5. Pursuant to Local Rule 7(b), the undersigned counsel states that this is

the first such Motion for Extension of Time to respond to Gerling opposition. Travelers respectfully requests that the Court grant its motion for extension of time and extend the deadline for filing its reply brief in further support of its Motion for Entry of Judgment by one week, from October 24, 2005 to October 31, 2005. THE PLAINTIFF, Travelers Casualty & Surety Co. By: //ss// Thomas F. Maxwell, Jr. (00132) Pullman & Comley, LLC 850 Main Street, P.O. Box 7006 Bridgeport, CT 06601-7006 Telephone (203) 330-2000 Facsimile (203) 576-8888 E-mail: [email protected] Its Attorneys - and ­ Mary Kay Vyskocil (ct02814) Simpson, Thacher & Bartlett, LLP 425 Lexington Avenue New York, NY 10017 Telephone: (212)455-2000 Facsimile: (212)455-2502

-2-

Case 3:01-cv-00872-JBA

Document 105

Filed 10/19/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on October 19, 2005,a copy of the foregoing Plaintiff's Motion on Consent for Extension of Time 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. //ss// Thomas F. Maxwell, Jr. [ct 00132] Pullman & Comley, LLC 850 Main Street, P.O. Box 7006 Bridgeport, CT 06601-7006 Phone: (203) 330-2000 Fax: (203) 576-8888 E-mail: [email protected]

Bridgeport/67606.3/TXM/576057v1

-3-