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

Case 3:03-cv-01036-DJS

Document 132

Filed 05/26/2006

Page 1 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.

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CIVIL ACTION NO. 3:03CV1036

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MAY 26, 2006

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 discovery is June 5, 2006. CCT moves for an order that the discovery deadline in this case be extended for thirty days beyond the issuance of an order narrowing the scope of the subpoenas. According to the Court's Order 111, "the plaintiff shall not re-issue the subpoenas before the Court rules on the scope of proposed subpoenas". This ruling has yet to be made, and therefore, the subpoenas have not been re-issued. This is the sixth request for extension of the discovery deadline. In support of this motion, the undersigned states: NO ORAL ARGUMENT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-01036-DJS

Document 132

Filed 05/26/2006

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 April 10, 2006, Plaintiff filed their fifth request for extension of time

of the discovery deadline. The argument made in that motion was that a ruling was necessary on Defendant's Motion for Reconsideration in order to complete the narrowing of the subpoenas. Said narrowing has yet to be completed and in accordance with this Court's January 5, 2006 Order (111) "the plaintiff shall not re-issue the subpoenas before the Court rules on the scope of the proposed subpoenas".

WHEREFORE, the Plaintiff respectfully requests that the discovery deadline be extended thirty days beyond the issuance of an order narrowing the scope of the subpoenas, which the Plaintiff now seeks as an order of the Court. Finally, attempts have been made to contact counsel for the Defendant and no response has been obtained.

Case 3:03-cv-01036-DJS

Document 132

Filed 05/26/2006

Page 3 of 4

THE PLAINTIFF

By

/s/ Kevin P. Chamberlin Kevin P. Chamberlin 39 Mill Plain Road, Suite 10 Danbury, CT 06811 Federal Bar #- ct26843 Phone: 203-792-0011 Fax: 203-792-3370 [email protected]

Case 3:03-cv-01036-DJS

Document 132

Filed 05/26/2006

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.

:

CIVIL ACTION NO. 3:03CV1036

:

MAY 26, 2006

CERTIFICATE OF SERVICE I hereby certify that on May 26, 2006, 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 39 Mill Plain Road, Suite 10 Danbury, CT 06811 Phone: 203-792-0011 Fax: 203-792-3370 [email protected]