Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:03-cv-01036-DJS Document 31 Filed 04/01/2004 Page 1 of 5

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CALL CENTER TECHNOLOGIES, Plaintiff,
V.

CIVIL ACTION NO. 3:03CV1036 (SRU)

GRAND ADVENTURES TOUR & TRAVEL PUBLISHING CORPORATION, INTERLINE TRAVEL & TOUR, INC. Defendants. MARCH 31, 2004

DEFENDANT INTERLINE TRAVEL & TOUR INC.'S MOTION FOR EXTENSION OF TIME AND MOTION TO MODIFY THE STANDING ORDER Interline Travel & Tour, Inc. (''Interline''), a defendant in the above-captioned matter, respectfully requests a fifteen (15) day extension of time (until April 15, 2004) to disclose any expert witness(es) in this case. This is an alleged breach of contract action in which the plaintiff, Call Center Technologies, Inc. (''CCTI''), claims that Interline is somehow obligated to compensate the plaintiff for certain parts and equipment provided to co-defendant, Grand Adventures Tour & Travel Publishing NO ORAL ARGUMENT REQUESTED/ TESTIMONY NOT REQUIRED

LAw OFFICES OF LAuRA FLYNN BALDINI, LLC
2 Batterson Park Road, 2nd Floor * Farmington, CT 06032 juris No. 421267 0 (860) 874-8483 * Fax: (860) 561-9823

Case 3:03-cv-01036-DJS

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Corporation (''GATT''), The gravaman of the plaintiff's complaint against Interline is that Interline is a successor in interest to GATT and should therefore be liable for the alleged debts of GATT. Interline has denied the substantive allegations of the Plaintiff s Second Amended Complaint. On September 24, 2003, the parties entered into a Standing Order detailing the discovery deadlines in this case. Under the existing Scheduling Order, Interline was required to disclose expert witnesses by April 1, 2004. The undersigned seeks an additional fifteen days to confer with her out-of-state client (who has been out of the country) and necessary individuals so that Interline's expert witness(es) is properly disclosed. This is Interline's first request seeking an extension of time and requesting a modification of the Court's Standing Order. The requested extension will not delay the proceedings in this case as the deadline for deposing any of Interline's expert witnesses is June 1, 2004. The undersigned has advised plaintiff s counsel of the instant motion but was not able to ascertain CCTI's position with respect to it. WHEREFORE, Interline respectfully requests that its Motion for Extension of Time be granted and that the Court's Standing Order be modified accordingly.

I-Aw OFFICES OF LAuRA FLYNN BALDINI, LLC

2 Batterson Park Road, 2nd Floor 0 Farmington, CT 06032 juris No. 421267 9 (860) 874-8483 * Fax: (860) 561-9823

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F. Respectfully submitted, DEFENDANT, TRAVE

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LAw OFFICES OF LAuRA FLYNN BALDINI, LLC

2 Batterson Park Road, 2nd Floor 9 Farmington, CT 06032 juris No. 421267 9 (860) 874-84$3 e Fax: (860) 561-9823

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ORDER The foregoing MOTION, having been duly presented to this Court, it is hereby ORDERED, that the same be and hereby is GRANT'ED/DENIED. THE COURT,

JUDGE/Clerk

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2 Batterson Park Road, 2nd Floor * Farmington, CT 06032 juris No. 421267 * (860) 874-8493 * Fax: (860) 561-9823

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CERTIFICATE OF SERVICE This is to certify that the foregoing was mailed via U.S. mail, postage prepaid on this 3 1 st day of March, 2004 to the following counsel of record: Jack Garamella, Esq. Gregg Brauneisen, Esq. Collins, Hannafin, Garamella, Jaber & Tuozzolo, PC Counselfor Plaintiff 148 Deer Flill Avenue P.O. Box 440 1~ Danbury, CT 068 1 0
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LAw OFFICES OF 1AuRA FLYNN BALDINI, LLC

2 Batterson Park Road, 2nd Floor 0 Farmington, CT 06032 juris No. 421267 0 (860) 874-8463 9 Fax: (860) 561-9823

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