MOTION for Further Extension of Time to File Motion to Dismiss the Third Party Action and Statement of ReasonsWITH ATTACHED MEMO by Churchill & Banks, Churchill & Banks, LLC and Cottage Plaza, LLC. Responses due by 10/3/2005. (Leyva, Lucia)
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Case 1:04-cv-00048-T Document 62 Filed 09/19/2005 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND PENNSYLVANIA GENERAL INSURANCE COMPANY, ds/o John Sirois, and SAFEGUARD INSURANCE COMPANY ds/o 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 Partv Defendants THIRD PARTY PLAINTIFFS' MOTION FOR FURTHER 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 a further extension of time for third-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.
On September 12, 2005, this Court granted third-party plaintiffs' motion to extend the time for third-party plaintiffs to file a Motion to Dismiss the Third Party Action without Prejudice, on the grounds that third-party plaintiffs and third-party defendants were in the process of trymg to resolve the issue of dismissal by agreement; 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 defendants' attorneys were expected to have a iinal response this week; 4.
As of today, Friday, September 16, 2005, the attorneys for third-party defendants indicated that they still do not yet have a response from those who had to be consulted with respect to their client and that another week extension should provide sufficient time to decide whether the issue presented by the third party action can be resolved without court intervention.
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Case 1:04-cv-00048-T 5.
Document 62 Filed 09/19/2005 Page 2 of 2 As a result, third party plaintiffs are requesting an additional 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; 6.
The third party defendants' attorneys have assented to the extension until September 26, 2005. Third party defendants' opposition would then be due ten days later, on October 6,2005. WHEREFORE, third party plaintiffs request that they be allowed until September 26, 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 October 6, 2005; and that a reply be filed, if necessary, no later than October 11,2005.
CHURCHILL & BANK. LLC
CHURCHILL & BANKS, Ltd.
COTTAGE PLAZA ASSOCIATES, LLC
By their Attorneys, Deborah ~ o h n s o n ' ~ o 1 l i n(#7080) s Law Offices of Faith A. LaSalle One Turks Head Place Suite 1010 Providence, RI 02903 Telephone: (401) 421-8080 Facsimile (40 1) 42100677 Certification of Service I hereby cerufy that on this &$day attorneys of record:
Craig R. Waksler, Esq.
Stephen Adam, Esq.
Taylor Duane Barton & Gilman, LLP 10 Dorrance Street, Suite 700 Providence, RI 02903 Robert Qlllgley, Esquire McKenney, Jeffrey & Qlllgley 95 Chestnut Street, 6~ Floor Providence, RI 02908 of b&h, n 2005, I mailed a copy of this Motion to the
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Case 1:04-cv-00048-T
Document 62
Filed 09/19/2005
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
PENNSYLVANIA GENERAL INSURANCE
COMPANY, ds/o John Sirois, and SAFEGUARD
INSURANCE COMPANY ds/o 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 Partv Defendants
THIRD PARTY PLAINTIFFS' MOTION FOR FURTHER 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 a further extension of time for third-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.
On September 12, 2005, this Court granted third-party plaintiffs' motion to extend the
time for third-party plaintiffs to file a Motion to Dismiss the Third Party Action without Prejudice, on the
grounds that third-party plaintiffs and third-party defendants were in the process of trymg to resolve the
issue of dismissal by agreement;
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 defendants' attorneys were expected to have a iinal response this week;
4.
As of today, Friday, September 16, 2005, the attorneys for third-party defendants
indicated that they still do not yet have a response from those who had to be consulted with respect to
their client and that another week extension should provide sufficient time to decide whether the issue
presented by the third party action can be resolved without court intervention.
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Case 1:04-cv-00048-T
5.
Document 62
Filed 09/19/2005
Page 2 of 2
As a result, third party plaintiffs are requesting an additional 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;
6.
The third party defendants' attorneys have assented to the extension until September 26,
2005. Third party defendants' opposition would then be due ten days later, on October 6,2005.
WHEREFORE, third party plaintiffs request that they be allowed until September 26, 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 October 6, 2005; and that a reply be filed, if necessary,
no later than October 11,2005.
CHURCHILL & BANK. LLC
CHURCHILL & BANKS, Ltd.
COTTAGE PLAZA ASSOCIATES, LLC
By their Attorneys,
Deborah ~ o h n s o n ' ~ o 1 l i n(#7080)
s
Law Offices of Faith A. LaSalle
One Turks Head Place
Suite 1010
Providence, RI 02903
Telephone: (401) 421-8080
Facsimile (40 1) 42100677
Certification of Service
I hereby cerufy that on this &$day
attorneys of record:
Craig R. Waksler, Esq.
Stephen Adam, Esq.
Taylor Duane Barton & Gilman, LLP
10 Dorrance Street, Suite 700
Providence, RI 02903
Robert Qlllgley, Esquire
McKenney, Jeffrey & Qlllgley
95 Chestnut Street, 6~ Floor
Providence, RI 02908
of
b&h,
n
2005, I mailed a copy of this Motion to the
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