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 10/7/2005 (Leyva, Lucia)
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Case 1:04-cv-00048-T Document 64 Filed 09/23/2005 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND PENNSYLVANIA GENERAL INSURANCE COMPANY, dslo John Sirois, and SAFEGUARD INSURANCE COMPANY dslo Rui Henriques Plaintiffs C.A. No.: 04-48 T COlTAGE PLAZA, LLC, CHURCHILL & BANKS, LTD, and CHURCHILL & BANKS, LLC Defendants J.H. LYNCH & SONS, INC.
Third Party 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 additional time for third-party plaintiffs to file a Motion to Dismiss the Third Party Action without Prejudice and its Supporting Memorandum In support of this motion, third party plaintiffs state the following:
1.
On Friday, September 23, 2005, at about 2:30 p.m, attorneys for the third party defendants finally gave the definitive answer to inquiries and proposals for resolving the third party action without court involveme t and informed the attorney for the third party plaintiffs that they will not be 1 signing the proposed dismissal and the third party plaintiffs would need to file a motion to dismiss the third party action.
2.
Since the final decision was only conveyed the day before the present due date for a motion, the third party defense attorneys indicated that they would assent to a one week extension to file the motion and memorandum by the third party plaintiffs; 3.
Third party plaintiffs are requesting an additional one-week extension for the filing date for their motion and supporting memorandum in order to allow time to complete the memorandum and also to circulate the documents to representatives for the insurers of its clients, some of whom are out of
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Case 1:04-cv-00048-T Document 64 Filed 09/23/2005 Page 2 of 2 the ofice today and most of the upcoming week, and to inform them of the final outcome of discussions among counsel; 4.
The third party defendants' attorneys have assented to the extension until October 3, 2005. Third party defendants' opposition would then be due ten days later, on October 13,2005. WHEREFORE, third party plaintiffs request that they be allowed until October 3, 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 13, 2005; and that a reply be filed, if necessary, no later than October 18, 2005.
CHURCHILL & BANK. LLC
CHURCHILL & BANKS, Ltd.
COTTAGE PLAZA ASSOCIATES, LLC
By their Attorneys, Faith A. ~ a ~ a l(#2212) le Deborah Johnson Collins (#7080) Law Offices of Faith A. LaSalle One Turks Head Place Suite 1010 Providence, RI 02903 Telephone: (401) 421-8080 Facsimile (40 1) 421 00677 Certification o f Service I hereby certify that on this &y attorneys of record:
Craig R. Waksler, Esq.
Stephen Adams. Esq.
Taylor Duane Barton & Gilman. LLP 10 Dorrance Street. Suite 700 Providence. RI 02903 Robert Quigley, Esquire McKenney, Jeffrey & Quigley 95 Chestnut Street. 6'hFloor Providence, RI 02908 of , 2005, I mailed a copy of this Motion to the
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Case 1:04-cv-00048-T
Document 64
Filed 09/23/2005
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
PENNSYLVANIA GENERAL INSURANCE
COMPANY, dslo John Sirois, and SAFEGUARD
INSURANCE COMPANY dslo Rui Henriques
Plaintiffs
C.A. No.: 04-48 T
COlTAGE PLAZA, LLC,
CHURCHILL & BANKS, LTD, and
CHURCHILL & BANKS, LLC
Defendants
J.H. LYNCH & SONS, INC.
Third Party 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 additional time for third-party plaintiffs to file a Motion to Dismiss the Third Party
Action without Prejudice and its Supporting Memorandum In support of this motion, third party
plaintiffs state the following:
1.
On Friday, September 23, 2005, at about 2:30 p.m, attorneys for the third party
defendants finally gave the definitive answer to inquiries and proposals for resolving the third party action
without court involveme t and informed the attorney for the third party plaintiffs that they will not be
1
signing the proposed dismissal and the third party plaintiffs would need to file a motion to dismiss the
third party action.
2.
Since the final decision was only conveyed the day before the present due date for a
motion, the third party defense attorneys indicated that they would assent to a one week extension to file
the motion and memorandum by the third party plaintiffs;
3.
Third party plaintiffs are requesting an additional one-week extension for the filing date
for their motion and supporting memorandum in order to allow time to complete the memorandum and
also to circulate the documents to representatives for the insurers of its clients, some of whom are out of
PDF Page 3
Case 1:04-cv-00048-T
Document 64
Filed 09/23/2005
Page 2 of 2
the ofice today and most of the upcoming week, and to inform them of the final outcome of discussions
among counsel;
4.
The third party defendants' attorneys have assented to the extension until October 3,
2005. Third party defendants' opposition would then be due ten days later, on October 13,2005.
WHEREFORE, third party plaintiffs request that they be allowed until October 3, 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 13, 2005; and that a reply be filed, if necessary, no
later than October 18, 2005.
CHURCHILL & BANK. LLC
CHURCHILL & BANKS, Ltd.
COTTAGE PLAZA ASSOCIATES, LLC
By their Attorneys,
Faith A. ~ a ~ a l(#2212)
le
Deborah Johnson Collins (#7080)
Law Offices of Faith A. LaSalle
One Turks Head Place
Suite 1010
Providence, RI 02903
Telephone: (401) 421-8080
Facsimile (40 1) 421 00677
Certification o f Service
I hereby certify that on this &y
attorneys of record:
Craig R. Waksler, Esq.
Stephen Adams. Esq.
Taylor Duane Barton & Gilman. LLP
10 Dorrance Street. Suite 700
Providence. RI 02903
Robert Quigley, Esquire
McKenney, Jeffrey & Quigley
95 Chestnut Street. 6'hFloor
Providence, RI 02908
of
, 2005, I mailed a copy of this Motion to the
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