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

Case 3:03-cv-01036-DJS

Document 181

Filed 10/12/2007

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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 12, 2007 : CIVIL ACTION NO. 3:03CV1036

PLAINTIFF'S MOTION FOR EXTENSION OF TIME OF DISCOVERY DEADLINE The Plaintiff, Call Center Technologies, Inc. ("CCT"), in accordance with the provisions of Local Rule 7(b), moves for an extension of time of the Court's deadline for completion of discovery in this matter. The Court's current deadline for completion of the balance of discovery is October 12, 2007. CCT moves for an order granting the Plaintiff an additional 30 days to file the balance of their responses to Defendants supplemental interrogatories and requests for production. This is the first request for an extension of time to respond to the supplemental requests. In support of this motion, the undersigned states:

NO ORAL ARGUMENT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-01036-DJS

Document 181

Filed 10/12/2007

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 Publishing Corporation for the latter's purchase of certain parts and equipment being used by Interline.

2.

On September 10, 2007, the Court entered an Order that in part required

the Plaintiff to respond to the Defendant's outstanding discovery requests on or before October 12, 2007. 3. A combination of the fact that the Plaintiff's counsel has moved his place

of business from one location to another (in August, 2007) and the fact that the Plaintiff, himself, has been traveling to and from California for business has caused a delay in completing the aforementioned responses and compilations. 4. Due to the schedule set by this Court in the same order it is more likely

than not, that Defendant's counsel is hard at work on a draft for Summary Judgment and would not be prejudiced by this delay.

Case 3:03-cv-01036-DJS

Document 181

Filed 10/12/2007

Page 3 of 4

WHEREFORE, the Plaintiff respectfully requests a thirty day extension of time to complete its responses and compilations necessary to comply with the court's 9/10/07 order. Finally, opposing counsel has been made aware of this request and does not consent.

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 181

Filed 10/12/2007

Page 4 of 4

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 12, 2007 : CIVIL ACTION NO. 3:03CV1036

CERTIFICATE OF SERVICE I hereby certify that on October 12, 2007, a copy of foregoing Motion for Extension of Time of Discovery Deadline, 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]