Mohr v. WeatherTechMOTIONN.D. Ill.June 28, 20191 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Sharesse Mohr, Plaintiff, v. WEATHER TECH, a/k/a MACNEIL AUTOMOTIVE PRODUCTS LIMITED, Defendant. § § § § § § § § § § Case No. 17-cv-04451 Hon. Gary Feinerman Hon. Mag. M. David Weisman UNOPPOSED MOTION TO EXTEND CLOSE OF FACT DISCOVERY Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), Plaintiff Sharesse Mohr (“Plaintiff”), by and through her undersigned attorneys, moves to extend the close of fact discovery from June 28, 2019, to and including September 6, 2019. In support of this Motion, Plaintiff states as follows: 1. On May 15, 2019, the Court entered an Order extending the close of fact discovery to June 28, 2019. [See Dkt. #95] 2. The 30(b)(6) deposition of Weather Tech still needs to be scheduled. The parties are making their best efforts to confirm as soon as possible a firm date in mid-August or early September for the 30(b)(6) deposition. 3. Plaintiff is also in the process of issuing a follow-up third party subpoena that may or may not necessitate a deposition. Defendant does not anticipate the need for any further fact discovery except as may reasonably be necessary as a result of Plaintiff’s remaining discovery. Case: 1:17-cv-04451 Document #: 97 Filed: 06/28/19 Page 1 of 4 PageID #:307 2 4. This Motion is brought for good cause shown, and is not brought for any improper purpose. As the Court is aware, counsel for Plaintiff in this matter, Ms. Bahe-Jachna, was appointed by the Court and is handling this case on a pro bono basis. 5. Ms. Bahe-Jachna has consulted with Tim Schaum and Robert Grabemann, counsel for Defendant Weather Tech, concerning this Motion. Messrs. Schaum and Grabemann advised Ms. Bahe-Jachna that Defendant does not oppose this Motion. 6. Although this is not the first request for an extension of the fact discovery deadline, good cause does exist, neither side will be prejudiced by this extension, the remaining deposition is for a witness who must be produced by the Defendant, and the parties are working diligently to bring fact discovery to a close as soon as possible. In addition, Plaintiff’s expert has been diligently working on her report and is expected to be able to finalize that report for production to Defendant within a short period of time after she has reviewed the transcript of the 30(b)(6) deposition. The parties agree that this will be the final request for an extension of the fact discovery deadline barring any currently unforeseen issues arising. WHEREFORE, for the reasons set forth above and for such other and further reasons as may appear to the Court at a hearing on this Motion, Plaintiff Sharesse Mohr respectfully requests that this Court extend the current fact discovery deadline from June 28, 2019, to and including September 6, 2019, and grant such other and further relief as justice may require. PLAINTIFF SHARESSE MOHR By: /s/ Ruth A. Bahe-Jachna One of Her Attorneys Ruth A. Bahe-Jachna Scott Dorsett GREENBERG TRAURIG, LLP 77 West Wacker Drive, Suite 3100 Chicago, IL 60601 Case: 1:17-cv-04451 Document #: 97 Filed: 06/28/19 Page 2 of 4 PageID #:308 3 (312) 456-8400 baher@gtlaw.com dorsetts@gtlaw.com Dated: June 28, 2019 Case: 1:17-cv-04451 Document #: 97 Filed: 06/28/19 Page 3 of 4 PageID #:309 CERTIFICATE OF SERVICE I, Ruth A. Bahe-Jachna, an attorney, certify that on June 28, 2019, a true and correct copy of the foregoing UNOPPOSED MOTION TO EXTEND CLOSE OF FACT DISCOVERY was served on all counsel of record electronically through the Northern District of Illinois CM/ECF electronic filing system. /s/ Ruth A. Bahe-Jachna Ruth A. Bahe-Jachna Case: 1:17-cv-04451 Document #: 97 Filed: 06/28/19 Page 4 of 4 PageID #:310
