1. Given that respondents assert that The Learning Company ("TLC") is part of Mattel, I include TLC as part of this motion and will not ask them to be treated separately.

2. The respondents were put on notice of this complaint, via the website, by April 5, 2000.

3. Even if respondents did ask for the time with good cause, as they were required too, 804 CMR 1.10(8)(b) only an extension of "not more than 21 days in which to file the answer." Their response was served 68 days after notice was given to them--more than three weeks after the maximum possible extension.

4. It could be considered malpractice by either the old or new counsel. This would depend on the timing of the change of counsel and if previous counsel properly noticed them of the time limits.

5. If the respondents are permitted to delay by changing counsel, they may delay this case until the next century given the number of law firms in the greater Boston area.