Daniell v. Sempris, LLC et al

MOTION

N.D. Ill.September 30, 2013

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION BONNIE DANIELL, individually and on Behalf of all others similarly situated, Plaintiff, v. SEMPRIS, LLC, a Delaware limited liability Company; E. MISHAN & SONS, INC., a New York corporation d/b/a EMSON, INC.; and QUALITY RESOURCES, INC., a Florida Corporation, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 13-cv-06938 Hon. Robert W. Gettleman Magistrate Judge Maria Valdez DEFENDANT QUALITY RESOURCES, INC.’S UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), Defendant Quality Resources, Inc. (“Quality”), by and through its attorneys, respectfully moves for an extension of time to respond to Plaintiff’s Complaint, and in support thereof states as follows: 1. On August 28, 2013, Plaintiff filed the Second Amended Complaint in this matter naming Quality as a defendant. 2. On September 26, 2013, Quality removed this matter from the Circuit Court of Cook County, Illinois, County Department, Chancery Division to the United States District Court for the Northern District of Illinois, Eastern Division. 3. Pursuant Federal Rule of Civil Procedure 81, Quality’s responsive pleading to Plaintiff’s Complaint is due by October 3, 2013. 4. In exchange for accepting service on Quality’s behalf, Plaintiff’s counsel agreed to permit Quality 60 days to respond to the Complaint up to and including November 4, 2013. Case: 1:13-cv-06938 Document #: 10 Filed: 09/30/13 Page 1 of 2 PageID #:287 2 5. Counsel for Quality has numerous scheduling conflicts through October with depositions, mediations, and hearings across the nation. 6. Given Qualitiy’s counsel’s travel and required attendance at depositions, hearings, and mediations in other federal court matters, good cause exists for an extension of time for Quality to file its response to Plaintiff’s Complaint. 7. Federal Rule of Civil Procedure 6(b) allows the Court discretion to enlarge periods of time under the circumstances presented herein. 8. This Motion is not sought for any improper purpose and is intended to allow Quality time to adequately address the allegations in Plaintiff’s Complaint. WHEREFORE, Defendant Quality Resources, Inc. respectfully requests an extension of time to respond to Plaintiffs’ Complaint up to and including November 4, 2013, together with such other and further relief as this Court deems just and proper under the circumstances. Dated: September 30, 2013 Respectfully submitted, QUALITY RESOURCES, INC. By: s/ Timothy A. Hudson One of Its Attorneys Timothy A. Hudson TABET DIVITO & ROTHSTEIN LLC 209 South LaSalle Street, 7th Floor Chicago, Illinois 60604 Telephone No. (312) 762-9450 Facsimile No. (312) 762-9451 Case: 1:13-cv-06938 Document #: 10 Filed: 09/30/13 Page 2 of 2 PageID #:288