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Help on response to Pltf's request for extension

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We are currently defendants in a case against a JDB.

The case was first filed June of 2007, so this is now over a year later.

Last month we were going to set the matter for trial.

However, when clerk heard that discovery was not completed the court filed an order giving the plaintiff 30 days to complete discovery.

(Provide me with signed credit app, bill of sale & 1 year of statements)

Plaintiff filed a request for an extension on the deadline date.

I don't have a copy of the request yet but I will be getting one today or tomorrow.

The court clerk "highly suggested" we file a response to the extension request.

Does anybody have ideas of reasons I could/should list for why the request should be denied? Any court cases I could reference?

Thanks for the assistance!

You guys have helped me already get one case dismissed, one collection account closed & so now I'm working on this one!

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