Twardy, et al v. Priceline.com, Inc, et al

MOTION for Extension of Time until 8/21/06 to Reply to Defendants' Opposition to Plaintiffs' 329 Motion to Compel

D. Conn.August 10, 2006

1 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT IN RE: PRICELINE.COM, INC. SECURITIES LITIGATION _________________________________ This document relates to: ALL ACTIONS : : : : : : : : : MASTER FILE NO. 3:00CV01884(AVC) August 10, 2006 UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to D. Conn. L. Civ. R. 7(b), Plaintiffs, by and through their counsel, hereby move this Court for a seven (7) day extension of time to reply to the Priceline Defendants’ Memorandum in Opposition to Plaintiffs' Motion to Compel Emails and Electronic Documents Contained on the "Snapshot" and "Terminated Employee Tapes". In support of this motion, Plaintiffs state as follows: 1. Plaintiffs filed a motion to compel discovery from the Priceline Defendants on July 6, 2006, and a motion to compel discovery from Defendant Walker on July 7, 2006. 2. The Priceline Defendants’ filed their opposition to Plaintiffs’ motion to compel on July 27, 2006, and Defendant Walker filed his opposition to Plaintiffs’ motion to compel on July 28, 2006. 3. Plaintiffs’ reply briefs to both the Priceline Defendants’ opposition as well as Defendant Walker’s opposition currently are due August 14, 2006. 4. Good cause is shown for an extension of seven (7) days for Plaintiffs to reply to the Priceline Defendants’ opposition, until August 21, 2006, as numerous, contentious discovery issues have been raised and additional time is necessary to adequately address these issues. Case 3:00-cv-01884-AVC Document 347 Filed 08/10/2006 Page 1 of 4 2 Importantly, this brief extension will have no bearing on any other deadlines set by the Court in this action. 5. The Priceline Defendants do not oppose this motion. 6. This is Plaintiffs’ first request for extension of time to reply to the Priceline Defendants’ opposition. WHEREFORE, Plaintiffs respectfully request that the Court grant an extension of time to reply to the Priceline Defendants’ opposition until August 21, 2006. Dated: August 10, 2006 Respectfully submitted, SCOTT + SCOTT, LLC _/s/Erin Green Comite_____________ David R. Scott (ct16080) Mark V. Jackowski Erin Green Comite (ct24886) 108 Norwich Avenue P.O. Box 192 Colchester, CT 06415 Telephone: (860) 537-5537 Facsimile: (860) 537-4432 SCOTT + SCOTT, LLC Geoffrey M. Johnson 33 River Street Chagrin Falls, OH Chagrin Falls, OH 44022 Telephone: (440) 247-8200 Facsimile: (440) 247-8275 JOHNSON & PERKINSON Dennis J. Johnson Jacob B. Perkinson Eben Duval 1690 Williston Road P.O. Box 2305 South Burlington, VT 05403 Telephone: (802) 862-0030 Facsimile: (802) 862-0060 Case 3:00-cv-01884-AVC Document 347 Filed 08/10/2006 Page 2 of 4 3 STULL, STULL & BRODY Jules Brody Aaron Brody 6 East 45th St. New York, NY 10017 Telephone: (212) 687-7230 Facsimile: (212) 490-2022 Co-Lead Counsel Case 3:00-cv-01884-AVC Document 347 Filed 08/10/2006 Page 3 of 4 4 CERTIFICATE OF SERVICE I hereby certify that on August 10, 2006, a copy of the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the court’s electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the court’s CM/ECF System. ___/s/Erin Green Comite_________ Erin Green Comite Case 3:00-cv-01884-AVC Document 347 Filed 08/10/2006 Page 4 of 4