North River Insurance Company v. O & G Industries, Inc.MOTION to Continue Hearing on January 3, 2014 to new dateD. Conn.December 31, 2013UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT THE NORTH RIVER INSURANCE COMPANY Plaintiff, v. O&G INDUSTRIES, INC. KEYSTONE CONSTRUCTION AND MAINTENANCE SERVICES, INC. Defendants. CIVIL ACTION NO.: 3:13-cv-00589 (RNC) DECEMBER 31,2013 MOTION TO RESCHEDULE HEARING The North River Insurance Company ("North River") respectfully moves to reschedule the hearing on Keystone Construction and Maintenances Services, Inc. ("Keystone") and O&G Industries, Inc. 's ("O&G") respective motions to dismiss North River's First Amended Complaint presently scheduled for Friday, January 3, 2014. As grounds for this motion, North River respectfully submits that a significant snow storm is forecast for the morning of Friday, January 3, 2014, the time of the scheduled hearing. North River has consulted with counsel for Keystone and O&G and all parties are available to argue the motions on the afternoon of Wednesday, January 8, 2014, if that date is convenient for the Court. 993104-1 RESPECTFULL Y SUBMITTED, THE NORTH RIVER INSURANCE COMPANY BY lsi R. Cornelius Danaher, Jr. R. Cornelius Danaher, Jr. (ct5350) Calum B. Anderson (ct07611) DANAHERLAGNESE, PC 21 Oak Street Hartford, CT 06106 CERTIFICATE OF SERVICE I hereby certify that on December 31, 2013, a copy of the foregoing Motion was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent bye-mail to all parties by operation of the Court's electronic filing system of by mail as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CMIECF System. lsi R. Cornelius Danaher, Jr. R. Cornelius Danaher, Jr. (ct5350) 993104-1