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`VINCENT LAROBINA
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`VS.
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`ALTICE MEDIA SOLUTIONS, LLC D/B/A
`OPTIMUM
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`SUPERIOR COURT
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`J. D. OF STAMFORD/NORWALK
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`AT STAMFORD
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`SEPTEMBER 21, 2021
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`MOTION FOR EXTENSION OF TIME
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`The undersigned defendant, Altice Media Solutions, LLC d/b/a Optimum
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`(“Optimum”), hereby moves for an extension of time of sixty (60) days to respond to
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`plaintiff’s Motion for Summary Judgment dated August 25, 2021 (Entry #106.00).
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`Plaintiff commenced this action by way of Summons and Complaint dated August
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`11, 2021 with a Return Date of August 17, 2021. Just eight days after the Return Date,
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`plaintiff moved for summary judgment as to Counts One and Three of its Complaint.
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`Count One is a breach of contract claim, and Count Three is a CUTPA claim.
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`The defendant moves for an extension of time for the following reasons. First,
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`the defendant moved to strike Count Three of plaintiff’s Complaint in the Motion to
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`Strike dated September 1, 2021 (Entry #113.00). The Motion to Strike should be
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`addressed prior to the Motion for Summary Judgment.
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`Second, the defendant served discovery requests on the plaintiff on September
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`21, 2021. In order to develop its defense to plaintiff’s claims, the defendant should be
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`permitted to obtain plaintiff’s responses to discovery prior to responding the Motion for
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`Summary Judgment. It would be unfair for the plaintiff to submit that there is no
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`question of fact, but prevent the defendant from obtaining the necessary discovery to
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`determine if there is a question of fact.
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`Based on the above, the defendant respectfully requests an additional sixty (60)
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`days to respond to the plaintiff’s Motion for Summary Judgment to allow time for the
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`Court to address the defendant’s Motion to Strike and for the defendant to obtain
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`necessary discovery.
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`THE DEFENDANT,
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`BY: Matthias J. Sportini_________
` Matthias J. Sportini, Esq.
` Thomas P. Lambert, Esq.
` FLB Law, PLLC
` 315 Post Road West
` Westport, CT 06880
` Juris No.: 442190
` sportini@flb.law
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`CERTIFICATION
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`This is to certify that on this 21st day of September, 2021, a copy of the foregoing
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`was either mailed postage prepaid, emailed, faxed or hand-delivered to:
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`Vincent P. Larobina
`113 Grove Street
`Stamford, CT 06901
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`/s/ Matthias J. Sportini________
`Matthias J. Sportini
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