Ameristar Casino East Chicago LLC et al v. UNITE HERE Local 1

MOTION

N.D. Ill.May 31, 2016

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION AMERISTAR CASINO EAST CHICAGO, LLC, MICHAEL PEGORARO, JAMES MALECKY, LISA JUNG and MONIR DAVID, Plaintiffs, v. UNITE HERE LOCAL 1, Defendant. Case No. 1:16-cv-05379 Honorable Judge Manish S. Shah DEFENDANT UNITE HERE LOCAL 1’s UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER OR OTHERWISE PLEAD Defendant UNITE HERE Local 1 hereby requests a ten-day extension of its time to file an answer, motion to dismiss, or other responsive pleading to the Complaint in this action, and, in support, states as follows: 1. Plaintiffs Ameristar Casino East Chicago LLC, Michael Pegoraro, James Malecky, Lisa Jung, and Monir David filed their Complaint in this action on May 19, 2016. They served the Complaint on May 20, 2016. 2. Local 1’s lead counsel on this matter, Kristin Martin of Davis, Cowell & Bowe LLP, was on vacation from May 13 through May 30, 2016. Extending the time in which to answer or otherwise plead by ten days will allow Martin sufficient time to review the allegations made in the Complaint and prepare Local 1’s response. Case: 1:16-cv-05379 Document #: 7 Filed: 05/31/16 Page 1 of 2 PageID #:16 3. On May 25, 2016, counsel for Plaintiffs and for Local 1 stipulated that Local 1 would have an additional ten days in which to answer, file a motion to dismiss, or otherwise plead in response to the Complaint. Accordingly, Plaintiffs do not oppose this motion. WHEREFORE, Defendant Local 1 respectfully requests: That the Court grant a ten-day extension in the time for Defendant Local 1 to answer, move to dismiss, or otherwise respond to the Complaint, up to and including June 20, 2016. ASHER, GITTLER & D’ALBA, LTD. 200 West Jackson Blvd., Suite 1900 Chicago, IL 60606 312-263-1500 By: /s/Margaret Angelucci____________ Margaret A. Angelucci DAVIS, COWELL & BOWE, LLP 595 Market Street, Suite 800 San Francisco, CA 94105 415-597-7200 By: /s/Kristin L. Martin_______________ Kristin L. Martin, pro hac vice pending Attorneys for UNITE HERE Local 1 Case: 1:16-cv-05379 Document #: 7 Filed: 05/31/16 Page 2 of 2 PageID #:17