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`ALX PRODUCTS AND SERVICES, LLC
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`V.
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`OHIO CASUALTY INSURANCE CO., AND
`LIBERTY MUTUAL GROUP, INC.
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`DEFENDANT, OHIO CASUALTY INSURANCE COPMANY’S, UNOPPOSED MOTION
`FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S
`AMENDED COMPLAINT
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`Defendant, Ohio Casualty Insurance Company hereby moves for a seven (7) day extension
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`of time, up to and including February 13, 2025, to respond to Plaintiff ALX Products and Services,
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`LLC’s Amended Complaint bearing return date January 7, 2025. The undersigned counsel needs
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`additional time to evaluate the Amended Complaint, collaborate with their client, and prepare a
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`responsive pleading. This is Defendant’s first request for an extension of time to plead, trial is not
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`scheduled, and Plaintiff does not oppose the relief sought.
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`WHEREFORE, Defendant, Ohio Casualty Insurance Company requests an extension of
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`time, up to and including February 13, 2025, to respond to Plaintiff’s Amended Complaint.
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`DEFENDANT, OHIO CASUALTY
`INSURANCE COMPANY
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`By: /s/ Gerald P. Dwyer, Jr. Esq.
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`Gerald P. Dwyer, Jr.
`
`Nikolaos M. Hernandez
`
`Robinson & Cole LLP
`
`One State Street
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`Hartford, CT 06103
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`Main: (860) 275-8200
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`Fax: (860) 275-8299
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`Juris No. 415728
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`Email: gdwyer@rc.com
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`nhernandez@rc.com
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`Attorneys for Defendant
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`SUPERIOR COURT
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`J.D. OF HARTFORD
`AT HARTFORD
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`FEBRUARY 4, 2025
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` :
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`:
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`:
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`:
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that a true and correct copy of the foregoing was or will immediately
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`
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`be mailed or delivered electronically or non-electronically on February 4, 2025 to the following
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`counsel of record and that written consent for electronic delivery was received from counsel.
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`Paul A. Keily, Esq.
`KEILY MIRA LAW
`968 Farmington Ave, Suite 208
`West Hartford, CT 06107
`Tel.: 860-251-9552
`Fax: 860-561-9870
`Firm Juris no. 433252
`paul@kmlegalct.com
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`/s/ Gerald P. Dwyer Jr.
` Gerald P. Dwyer, Jr.
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