Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:03-cv-01036-DJS

Document 183

Filed 10/24/2007

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CALL CENTER TECHNOLOGIES, (DJS) Plaintiff, v. GRAND ADVENTURES TOUR & TRAVEL PUBLISHING CORPORATION, INTERLINE TRAVEL & TOUR, INC. Defendants. : October 23, 2007 : CIVIL ACTION NO. 3:03CV1036

PLAINTIFF'S MOTION PURSUANT TO FED. R. CIV. P. 36(b) TO AMEND ADMISSIONS

Pursuant to Fed. R. Civ. Proc. 36(b), Plaintiff Call Center Technologies, Inc. ("Plaintiff") hereby moves to amend certain admissions previously served upon Defendant Interline Travel & Tour, Inc. ("Interline" or "Defendant"). In support of this motion, the undersigned states:

1.

On September 10, 1997 this Court ordered that Plaintiff respond to

Interline's outstanding discovery requests on or before October 12, 2007, which time was subsequently extended by the Court until October 22, 2007.

NO ORAL ARGUMENT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-01036-DJS 2.

Document 183

Filed 10/24/2007

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In Defendant Interline Travel & Tour Inc.'s Motion to Dismiss, Motion

for Enforcement of Court Order and Motion for Sanctions for Failure to Comply with Discovery dated November 13, 2006, Plaintiff attached its outstanding discovery requests in its letters of September 7, 2006, September 17, 2006, and October 17, 2006, attached to such motions.

3.

In Defendant's September 21, 2006 letter Defendant requested that

Plaintiff revise numerous paragraphs of Plaintiff's Requests for Admission of Statements and Documents dated August 3, 2006.

4.

Pursuant to Defendant's request, Plaintiff has revised its admissions.

5.

In addition, Plaintiff has revised certain of its admissions not requested by

Defendant in order to clarify and make them consistent with other admissions which the Defendant did request that Plaintiff revise.

WHEREFORE, Plaintiff respectfully requests that its attached amended admissions be allowed pursuant to Fed. R. Civ. P. 36(b).

THE PLAINTIFF By /s/ Kevin P. Chamberlin Kevin P. Chamberlin 40 Lake Avenue Extension ­ Suite 4 Danbury, CT 06811 Federal Bar #- ct26843 Phone: 203-792-0011 Fax: 203-792-3370 [email protected]

Case 3:03-cv-01036-DJS

Document 183

Filed 10/24/2007

Page 3 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CALL CENTER TECHNOLOGIES, (DJS) Plaintiff, v. GRAND ADVENTURES TOUR & TRAVEL PUBLISHING CORPORATION, INTERLINE TRAVEL & TOUR, INC. Defendants. : OCTOBER 23, 2007 : CIVIL ACTION NO. 3:03CV1036

CERTIFICATE OF SERVICE I hereby certify that on October 23, 2007, a copy of foregoing Motion to Amend, was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by email to all parties by operation of the court's electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the court's CM/ECF System.

/s/ Kevin P. Chamberlin Kevin P. Chamberlin Federal Bar No. ct26843 40 Lake Avenue Extension ­ Suite 4 Danbury, CT 06811 Phone: 203-792-0011 Fax: 203-792-3370 [email protected]