Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-01036-DJS Document 86 Filed 07/13/2005 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
Civil Action N0. s;0scv1036 (DJS)
Plaintiff
GRAND ADVENTURES TOUR &
TRAVEL PUBLISHING CORPORATION, :
INTERLINE TRAVEL & TOUR, INC., :
Defendants. July 8, 2005
PLAINTIFF’S OBJ ECTION TO DEFENDANT INTERLINE TRAVEL & TOUR, INC.’S
MOTION TO QUASH
Plaintiff Call Center Technologies, Inc., by its undersigned attorneys, hereby submits
pursuant to D. Conn. L. Civ. R. 7(a) its Objection to the Motion to Quash filed by Defendant
Interline Travel & Tour, Inc. (“Interline”). As set forth more fully in the Plaintiff s
accompanying Memorandum of Law, the Defendant’s Motion to Quash subpoenas issued to
third-parties should be denied for the following reasons:
(1) The Motion to Quash is not properly filed in the District of Connecticut. The
subpoenas were issued by the United States District Courts for the Northern and Western
Districts of Texas, the only courts with jurisdiction over the subpoenas.
(2) The Motion to Quash is untimely as having been filed beyond the applicable 14
day time limitation set forth in Fed. R. Civ. P. 45(c)(2)(B) and 45(c)(3)(A).
(3) The Defendant lacks standing to contest subpoenas issued to third-parties and has
not established a personal right or privilege in the documents requested.
ORAL ARGUMENT
NOT REQUESTED

Case 3:03-cv-01036-DJS Document 86 Filed 07/13/2005 Page 2 of 4
(4) The Defendant has failed to satisfy its heavy burden of proof burden documents
requested by the subpoenas are relevant to the Plaintiff s claims in this matter and are within the
permissible scope of discovery.
WHEREFORE, Plaintiff respectfully requests that the Motion to Quash filed by the
Defendant Interline Travel & Tour, Inc. be denied.
Respectfully submitted, _
PLAIN ALL CENTER T OLOGIES, INC.
By:
So on Pear lum Heymann & Stich, LLP
M. Shafferman (JS-1055)
Wall Street, 35th Floor
ew York, New York 10005
Telephone: (212) 267-7600
Facsimile: (212) 267-2030
E-mail: [email protected],
Its Attorneys.
Dated: New York, New York
July 8, 2005
2

Case 3:03-cv-01036-DJS Document 86 Filed 07/13/2005 Page 3 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
CALL CENTER TECHNOLOGIES, INC., : Civil Action No. 3:03CV1036 (DJ S)
Prarmrrr, 2
v.
GRAND ADVENTURES TOUR &
TRAVEL PUBLISHING CORPORATION, 2
IN TERLINE TRAVEL & TOUR, INC., :
Defendants. July 8, 2005
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within and foregoing
was served via United States first-class mail, postage prepaid, and by facsimile, on this 8th day
of July, 2005 upon all pro se parties and cormsel of record, as follows:
Laura F. Baldini, Esq.
Counsel for Defendant Interline Travel & Tour, Inc.
2 Batterson Park Road, 2nd Floor
Farmington, CT 06032
Telephone: 860-874-8463
Facsimile: 860-561-9823
Ms. Courtney Baxter
Jackson Walker, LLP
100 Congress Ave., Suite 1100
Austin, TX 78701
Mr. Lester Sprouse
Sprouse & Anderson
515 Congress Avenue, Suite 1212
Austin, TX 78701
3

Case 3:03-cv-01036-DJS Document 86 Filed 07/13/2005 Page 4 of 4
Beatrix Bemauer, Esq.
Grant Thorton
175 West Jackson Blvd.
20th Floor
Chicago, IL 60604
Randy Sarosdy, Esq.
Akin, Gump, Strauss, Hauer & Feld
300 W. 6m Street, Suite 2100
Austin, TX 78701
Yesenia
Sworn to before me this
gm day of July, 2005
. _ _ {/F`\_»
otary Public
Jill H. Teitel
Notary Public, State oi New York
Fleqistration #02TE5069470
Oua med in New York County
My Commission Expires Nov. 25, 1M/
1,000
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