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

Case 3i03-cv-01036-DJS Document 136 _ Filed 07/13/2006 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CALL CENTER TECHNOLOGIES, : CIVIL ACTION NO. 3:C·3CVlt'l·36 {DJS}
Plaintiff,

GRAND ADVENTURES TOUR Se
TRAVEL PIlHI.lSI—llNG CORPORATION,
INTERLINE TRAVEL Ec TOUR, INC.
Defendants. : JULV I3, EDGE
MOTIQ QN FOR EXTENSION OF TIME NUNC PRO TUNC
The Plaintiff in the above-entitled matter moves for a live {5] day extension of time
[beyond ruling} to complete service of outstanding subpoenas. [n support of this motion the
Plaiutiffeffers the following:
t. This case is not yet scheduled for trial.
2. Plaintiff was ordered pursuant to Court order dated June 6, Zlllilb te serve the
outstanding “reyised" subpoenas.
3. Said time expired July l I, 2lJl]6.
4. During this period of time, PlaintitI”s counsel has had to contend with a serious health
matter in the State of Florida. Specifically, Plaintiffs counsel`s mother suffered a
major stroke several weeks ago and was hospitalized. She has since been treating with
various doctors in two locations in Florida. Most recently she has also been seen by
physicians in Connecticut. Her condition remains serious to date as she has suffered
permanent damage to the right sidc of hcr brain.

Case 3:03-cv-01036-DJS Document 136 Filed 07/13/2006 Page 2 of 4
5. Ceunsel has traveled te be by her side and assist with the many health care specialists.
6. Ceunsel fer Plaintiff has been respensihle fer net eniy the care ef his lviether, but that
ef his Father whe is alse elderly and carrnet live alene.
T. During the pendency ef this situatien, the service efthe subpeenas in questien was
prepared, but net erdered due te ceunsel’s fecus en his ebligatiens te his parents.
S. Only recently has ceunsel fer Plaint:iH resumed his werltlead as attemey and net yet at
a hill time schedule.
9. It was then he discevered his failure te act in a timely fashien in this case.
ID. Ceunsel acltnewledges that this request is net in cempliance with the aferementiened
Ceurt eader and tirrther acknewleriges diis is net the iirst late filing by same.
ll. Ceunsel dees hewever, truthfully state that the circumstances ef this delay were net
intentienal and ceuld never have been expected.
12. Ceunsel claims that the prejudice te his client weuld be eutweighed by that ef the
Defendants. lI1 that this is essentially the enly discevery he has scught (and been
allewed) and witheut it, weuld be left with nene.
13. Ceunsel admits that it vveuld be just fer 11im te suffer serne ferm ef sanctien, hewever,
he claims witheut questien that the petential damage dene te the pessible acquisitien
et" material evidence and therefere the case itself, weuld likely be irreparable.
WHEREFDRE, ceunsel fer Plaintiff respectfully requests t.hat the Ceurt grant him an
additienal 5 days [aiter ruling) te preperly serve the feur suhpeenas en the Texas parties se
that the case may preceed te trial.

Case 3:03-cv-01036-DJS Document 136 Filed 07/13/2006 Page 3 of 4
This is the Plaint.ii‘l"s seventh and tins] request for an extensien of time related to
diseoverv. A telephone call was made to Attorney Elaldini’s office by Attomey Chamberlin
on July 13, 2l]i}6, at the time on tiling Attorney Baldini has not responded and therefore the
Plaintiff eannot oornrnent on whether or not the Defendants consent to the Motion for
Extension of Time Nune Pro Tune.
BY: fsf Kevin P. Chamberlin
Kevin P. Chamberlin
39 Mill Plain Read, Suite lll
Danbury, CT {16311
Federal Bar #— et26E43
Tel. (H13) ?92—[ll}1 1
ORDER
The foregoing motion having been considered bv the Court, is hereby URDERHI}:
GRAl*~lTEDJT}ENlED
BY THE COURT
JUDGEICLERK

Case 3:03—cv—01036-DJS Document 136 Filed 07/13/2006 Page 4 0f 4
CERTIEQQ QATIUN
l hereby certify that a eepy ef the abeve ebjeeticm was mailed and faxed en July I3,
2t}{l6 te:
Law ClHieea nf Laura Baldini
2 Battersea Park Read, Emi Fleur
Farmington, CT U6032
BY: fat Kevjn P, Chamberlin
Kevin P. Chamberlin
39 Ivlill Plain Read, Suite li}
Danbury, CT {1*63ll
Federal Bar #· 4:126843
Tel. @[13) 792-I][Ill