MOTION for Extension of Time to File a Motion to Dismiss the Third Party Action and Statement of ReasonsWITH ATTACHED MEMO by Churchill & Banks, Churchill & Banks, LLC, Cottage Plaza, LLC. Responses due by 9/26/2005 (Leyva, Lucia)
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Case 1:04-cv-00048-T Document 60 Filed 09/12/2005 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND PENNSYLVANIA GENERAL INSURANCE COMPANY, a/slo John Sirois, and SAFEGUARD INSURANCE COMPANY atdo Rui Henriques Plaintiffs C.A. NO.: 04-48 T COTTAGE PLAZA, LLC, CHURCHILL & BANKS, LTD, and CHURCHILL & BANKS, LLC Defendants J.H. LYNCH & SONS, INC.
Third Party Defendants THIRD PARTY PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO FILE MOTION TO DISMISS THE THIRD PARTY ACTION AND STATEMENT OF REASONS Third party plaintiffs, Churchill & Banks, LLC; Churchill & Banks, Ltd.; and Cottage Associates, LLC; hereby request an extension of time for defendantslthird-party plaintiffs to file a Motion to Dismiss the Third Party Action without Prejudice. In support of this motion, third party plaintiffs state the following:
1.
At the court conference, the date set for the third party plaintiffs to file a motion for the court to dismiss the third party action without prejudice was set for September 12, 23005. In the meantime, the parties were going to explore other avenues of resolution of the issue; 2.
The attorneys for the third party defendants are still considering a proposal of the third party plaintiffs regarding the disposition of the third party action, which would not involve court involvement; 3.
Third party defendant attorneys are expected to have a final response next week; 4.
Third party plaintiffs are requesting a one-week extension for the filing date for its motion and supporting memorandum in order to allow time for the third party defendants to make a final decision on a proposal not involving court intervention;.
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Case 1:04-cv-00048-T 5.
Document 60 Filed 09/12/2005 Page 2 of 2 The third party defendants' attorneys have assented to the extension until September 19, 2005. Third party defendants' opposition would then be due ten days later, on September 29,2005. WHEREFORE, third party plaintiffs request that they be allowed until September 19, 2005, to file their Motion to Dismiss and Memorandum of Law; that the third party defendants be allowed to file their Objection and Supporting Memorandum by September 29, 2005; and that a reply be filed, if necessary, no later than October 3,2005.
CHURCHILL & BANK LLC
CHURCHILL & BANKS,Ltd.
COTTAGE PLAZA ASSOCIATES,LLC
By their Attorneys, Deborah Johnson Collins (467080) Law Offices of Faith A LaSalle One Turks Head Place Suite 1010 Providence,RI 02903 Telephone: (401) 421-8080 Facsimile (401) 4210067'7 Certification of service I hereby certify that on this the attorneys of record:
/zfi Cra* R Waksler,Esq.
Stephen Adams, Esq.
Taylor Duane Barton & Gilman,LLP 10Dorrance Street,Suite 700 Providence, RI 02903 Robert Qu*ley, Ekpire McKenney,Jeffrey & Qui~ley 95 Chestnut Street,6* Floor Providence. RI 02908 day o ,2005, I mailed a copy of this Motion to
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Case 1:04-cv-00048-T
Document 60
Filed 09/12/2005
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
PENNSYLVANIA GENERAL INSURANCE
COMPANY, a/slo John Sirois, and SAFEGUARD
INSURANCE COMPANY atdo Rui Henriques
Plaintiffs
C.A. NO.: 04-48 T
COTTAGE PLAZA, LLC,
CHURCHILL & BANKS, LTD, and
CHURCHILL & BANKS, LLC
Defendants
J.H. LYNCH & SONS, INC.
Third Party Defendants
THIRD PARTY PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO FILE MOTION TO
DISMISS THE THIRD PARTY ACTION AND STATEMENT OF REASONS
Third party plaintiffs, Churchill & Banks, LLC; Churchill & Banks, Ltd.; and Cottage Associates,
LLC; hereby request an extension of time for defendantslthird-party plaintiffs to file a Motion to Dismiss
the Third Party Action without Prejudice. In support of this motion, third party plaintiffs state the
following:
1.
At the court conference, the date set for the third party plaintiffs to file a motion for the
court to dismiss the third party action without prejudice was set for September 12, 23005. In the
meantime, the parties were going to explore other avenues of resolution of the issue;
2.
The attorneys for the third party defendants are still considering a proposal of the third
party plaintiffs regarding the disposition of the third party action, which would not involve court
involvement;
3.
Third party defendant attorneys are expected to have a final response next week;
4.
Third party plaintiffs are requesting a one-week extension for the filing date for its
motion and supporting memorandum in order to allow time for the third party defendants to make a final
decision on a proposal not involving court intervention;.
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Case 1:04-cv-00048-T
5.
Document 60
Filed 09/12/2005
Page 2 of 2
The third party defendants' attorneys have assented to the extension until September 19,
2005. Third party defendants' opposition would then be due ten days later, on September 29,2005.
WHEREFORE, third party plaintiffs request that they be allowed until September 19, 2005, to
file their Motion to Dismiss and Memorandum of Law; that the third party defendants be allowed to file
their Objection and Supporting Memorandum by September 29, 2005; and that a reply be filed, if
necessary, no later than October 3,2005.
CHURCHILL & BANK LLC
CHURCHILL & BANKS,Ltd.
COTTAGE PLAZA ASSOCIATES,LLC
By their Attorneys,
Deborah Johnson Collins (467080)
Law Offices of Faith A LaSalle
One Turks Head Place
Suite 1010
Providence,RI 02903
Telephone: (401)
421-8080
Facsimile (401)
4210067'7
Certification of service
I hereby certify that on this
the attorneys of record:
/zfi
Cra* R Waksler,Esq.
Stephen Adams, Esq.
Taylor Duane Barton & Gilman,LLP
10Dorrance Street,Suite 700
Providence, RI 02903
Robert Qu*ley, Ekpire
McKenney,Jeffrey & Qui~ley
95 Chestnut Street,6* Floor
Providence. RI 02908
day o
,2005, I mailed a copy of this Motion to
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