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

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V DISTRICT OF CONNECTICUT `
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, CALL CENTER TECHNOLOGIES, : CIVIL ACTION NO. 3:03CVl 036 _
(DJ S) . F -
Plaintiff,
v.
GRAND ADVENTURES TOUR &
TRAVEL PUBLISHING CORPORATION,
INTERLINE TRAVEL & TOUR, INC.
_ Defendants. : MARCH 15, 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 April 19, 2006. CCT moves for an order that the discovery deadline in this
case be extended for thirty days. This is the fourth request for extension of the discovery
deadline. In support of this motion, the undersigned states:
NO ORAL ARGUMENT REQUESTED
TESTIMONY NOT REQUIRED
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. Q_ Case 3:03-cv-010§6-DJS Document 120 Filed 03/-1- 6/2006 Page 2 of 3 i
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l. In this action CCT asserts a claim for breach of contract against Interline
Travel & Tour, Inc. ("lnterline”) 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 January 20, 2006, the Court entered an Order that in part required all
discovery, including experts reports and depositions, shall be completed by April 19,
2006.
3. To date, the Court has yet to make a ruling as to how the parties will A
proceed in the narrowing of subpoenas that remain outstanding. A Motion to Amend the
Complaint and a Proposed Amended Complaint, along with a Request for Extension of
Time, were filed in an effort to expedite this task. The Motion for Extension of Time was _
then met with objection, and awaits court ruling.
WHEREFORE, the Plaintiff respectfully requests that the discovery deadline be
extended thirty days in light of the fact that the infomation sought in the subpoenas has
not yet been requested. Further, opposing counsel has been contacted with respect to this
request and takes no position as to the outcome.
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.. ,_ Case 3:03-cv-010365DJS Document 120 Filed O3/1g/2006 Page 3 of 3 {
THE PLAINTIFF
Kevin P. Chamberlin
100 Mill Plain Road, 4th Floor
Danbury, CT 06811
Federal Bar #- ct26843
Te1. (203) 792-0011
CERTIFICATION
I hereby certify that a copy of the above objection was mailed and faxed on
March 15, 2006to:
Law Offices of Laura Baldini
2 Batterson Park Road, 2"d Floor
Farmington, CT 06032
1
Kevin P. Chamberlin
1