Free Motion to Continue - District Court of Federal Claims - federal

Case 1:03-cv-02033-NBF

Document 22

Filed 09/27/2004

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS COMMERCIAL CASUALTY ) INSURANCE COMPANY OF GEORGIA, ) ) Plaintiff, ) ) v. ) ) UNITED STATES GOVERNMENT, ) DEPARTMENT OF THE NAVY, ) ) Defendant. ) )

CIVIL ACTION FILE NO. 03-2033C (Judge Firestone)

PLAINTIFF'S UNOPPOSED MOTION FOR CONTINUANCE COMES NOW, Commercial Casualty Insurance Company of Georgia ("Commercial Casualty") and files this its Unopposed Motion for Continuance, and states as follows: As described in Commercial Casualty's previous Motion for Continuance, and acknowledged in the Court's subsequent Order, on April 2, 2004, the Wade County Superior Court, State of North Carolina issued a Liquidation Order declaring Commercial Casualty Insurance Company of North Carolina be liquidated ("Liquidation Order"). The Liquidation Order invokes the process whereby a claims and submittal and evaluation system will be set up by the appropriate North Carolina officials. In addition, a process by which affirmative claims will be pursued and funds collected has recently been created. This process is extensive in both its procedures and requirements. As this is a matter where Commercial Casualty is seeking payment, counsel anticipates the case will go forward. Commercial Casualty requests additional time to adequately seek guidance in this matter from the appropriate officials of the North Carolina Department of

Case 1:03-cv-02033-NBF

Document 22

Filed 09/27/2004

Page 2 of 2

Insurance, which now controls Commercial Casualty. As a result, Commercial Casualty requests an additional 60 days to seek such guidance, by which time it expects to be able to resume activity in this case. This Motion has been discussed with opposing counsel and no opposition will be filed. This 27th day of September, 2004. Respectfully submitted, THOMPSON & SLAGLE, P.C. s/DeWitte Thompson DeWitte Thompson Georgia Bar No. 707688 12000 Findley Road Suite 250 Duluth, Georgia 30097 (770) 662-5999 (770) 447-6063 Facsimile [email protected]

Attorney for Plaintiff Dated: September 27th, 2004