Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-01036-DJS Document 193 Filed 12/12/2007 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CALL CENTER TECHNOLOGIES, : CIVIL ACTION NO. 3:03CVl036
(DIS)
Plaintiff,
v.
GRAND ADVENTURES TOUR &
TRAVEL PUBLISHING CORPORATION,
INTERLINE TRAVEL & TOUR, INC.
Defendants. : DECEMBER 12, 2007
PLAINTIFF’S SECOND MOTION FOR EXTENSION OF TIME TO FILE
OBJECTION TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
The Plaintiff, Call Center Technologies, Inc. ("CCT"), in accordance with the
provisions of Local Rule 7(b), moves for an extension of time to tile its Objection to the
Defendant’s Motion for Summary Judgment. CCT moves for an order granting the
Plaintiff a one week extension of time until December 2l, 2007 to Hle their Objection to
Defendant’s Motion for Summary Judgment. This is the second request for an extension
of time to file an Objection to Defendant’s Motion for Summary Judgment. In support of
this motion, the undersigned states:
NO ORAL ARGUMENT REQUESTED
TESTIMONY NOT REQUIRED

Case 3:03-cv-01036-DJS Document 193 Filed 12/12/2007 Page 2 of 4
1. In this action CCT asserts a claim for breach of contract against Interline
Travel & Tour, Inc. (‘°interline") as a successor to defendant Grand Adventures Tour &
Travel Pubiishing Corporation for the latter’s purchase of certain parts and equipment
being used by Interline.
2. On November 2, 2007, the Court entered an Order that required the
Plaintiff to respond to the Defendanfs Motion for Surnrnary Judgment on or before
November 23, 2007.
3. On November 21, 2007 Plaintiff tiled a Motion for Extension of Time to
file Objection to Defendant’s Summary Judgment.
4. On November 28, 2008, the Court entered an Order granting an extension
of time to file Objection to Summary Judgment untii December 14, 2007 also stating that
no further extensions will be granted.
5. This request is being made for a number of reasons including, one,
Counsel was and is continuing preparation on a Petition for Certification for Appellate
docket #27324 (Roy Young v. Call Center Technologies) simultaneously with the
Objection to Summary Judgment; and two, Counsel has been experiencing difficulties
with his Lexis Nexis search database for a number of days, causing an inability to
research.
6. Further, the undersigned counsel urges the court to, despite the Court’s
Order of no further extensions, to consider the lack of prejudice to both opposing counsel
in responding and to the Court in deciding the Defendant’s motion due to the fact that
` both the Christmas and New Year’s holiday immediately follow this tiling and neither
party would or should expect a ruling to come until after the Court has enjoyed its
holidays to the fullest extent.

Case 3:03-cv-01036-DJS Document 193 Filed 12/12/2007 Page 3 of 4
7. Counsel for the Defendant has been contacted, is aware of this request and
does not consent due to the fact that the November 28, 2007 Order states that no further
extensions will be granted.
WHEREFORE, the Plaintiff respectfully requests a final one week extension of
time to tile its Objection to Defendant’s Motion for Summary Judgment until December
21, 2007.
THE PLAINTIFF
By /s/ Kevin P. Chamberlin
Kevin P. Chamberlin
40 Lake Avenue Extension — Suite 4
Danbury, CT 06811
Federal Bar #— ct26843
Phone: 203-792-00ll
Fax: 203-792-3370
[email protected]

Case 3:03-cv-01036-DJS Document 193 Filed 12/12/2007 Page 4 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CALL CENTER TECHNOLOGIES, : CIVIL ACTION NO. 3:03 CV} 036
(DIS)
Plaintifi
v.
GRAND ADVENTURES TOUR &
T@VEL PUBLISHING CORPORATION,
INTERLINE TRAVEL & TOUR, INC.
Defendants. : DECEMBER I2, 2007
CERTIFICATE OF SERVICE
I hereby certify that on December I2, 2007, a copy of foregoing Second Motion
for Extension of Time to tile Objection to Defendant’s Motion for Summary Judgment,
was filed electronically and served by mail on anyone unable to accept electronic filing.
Notice of this tiling will be sent by email to all parties by operation of the court’s
electronic tiling as indicated on the Notice of Electronic Filing. Parties may access this
tiling through the court’s CM/ECP System.
/s/ Kevin P. Chamberlin
Kevin P. Chamberlin
Federal Bar No. ct26843
40 Lake Avenue Extension — Suite 4
Danbury, CT 06811
Phone: 203-792-001 l
Fax: 203—792—3370
[email protected]