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

Casevfs:03-cv-01036-DJS Document 1 17 Filed 02/15/2006 Page 1 of 3 i
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1 DISTRICT Oli? CONNECTICUT i H x
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’ CALL CENTER TECHNOLOGIES, : CIVIL ACTION NO. 3:03CVl036 LDJSP _
US 0l.._gTR_ CT COURT
Plaintiff, HAHTF ORD CT
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GRAND ADVENTURES TOUR &
TRAVEL PUBLISHING CORPORATION,
INTERLINE TRAVEL & TOUR, INC.
Defendants. : FEBRUARY 15, 2006
MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
The Plaintiff to the above titled action, CALL CENTER TECHNOLOGIES,
respectfully requests, pursuant Rule l5a of the Federal Rules of Civil Procedure, leave t0 file
the amended complaint annexed hereto. In support of this request, the Plaintiff states as
follows:
1. This is an action claiming successor liability;
2. There are outstanding subpoenas filed by the Plaintiff, the narrowing of which F
requires an adjudication of a claim of an allegation of fraud; *
3. Pursuant to Court Order based on telephone conference held on January 19, 2006, Ii
the Plaintiff was directed by the Court to tile an amended complaint.
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Case 3:03-cv-01056-DJS Document 117 Filed O2{_15/2006 Page 2 of 3 F
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WHEREF ORE, the Plaintiff prays that it be allowed to amend its complaint as requested.
BY; { mj M
Kevin P. Chamberlin
100 Mill Plain Road, 4th Floor
Danbury, CT 06811
‘ Federal Bar #- ct26843
Tel. (203) 792-0011
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Case 3:03-cv-0106365DJS Document 117 Filed O261£¥2006 Page 3 of 3
CERTIFICATION
I hereby certify that a copy of the above objection was mailed and faxed on
February 15, 2006 to:
Law Offices of Laura Baldini l
2 Batterson Park Road, 2"d Floor
Farmington, CT 06032
BY; { W
Kevin P. Chamberlin
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