Greenwood v. Sprint Corporation

MOTION

N.D. Ill.January 15, 2016

34620050M4 IN THE UNITED STATES DISTRICT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION SHARRON GREENWOOD, ) ) Plaintiff, ) No. 1:14-cv-08302 ) v. ) Honorable Virginia M. Kendall ) NEXTEL WEST SERVICES, LLC, ) ) Defendant. ) PLAINTIFF SHARRON GREENWOOD’S MOTION FOR EXTENSION OF TIME WITHIN WHICH TO COMPLETE DISCOVERY Plaintiff Sharron Greenwood, by her appointed counsel, Stephen W. Heil, respectfully moves this Honorable Court to extend the time within which to complete discovery in this matter for 90 days, or until March 31, 2016. In support of this motion, Plaintiff states as follows: 1. On April 16, 2015, Stephen W. Heil was appointed by this Court as counsel for Plaintiff. (Dkt. #13) Thereafter, on June 15, 2015, Plaintiff filed her First Amended Complaint in this action. (Dkt. #16) 2. On July 6, 2015, this Court ordered that discovery is scheduled to close on January 15, 2016. (Dkt. #20) This Court also ordered that the parties are to appear for a status hearing on January 19, 2016. (Dkt. #20) 3. On August 24, 2015, Defendant filed its answer to Plaintiff’s First Amended Complaint. (Dkt. #23) 4. On August 25, 2015, Nextel West Services, LLC, was substituted as defendant in this action. (Dkt. #25) 5. From September 28, 2015, through November 2, 2015, Plaintiff’s appointed Case: 1:14-cv-08302 Document #: 33 Filed: 01/15/16 Page 1 of 4 PageID #:131 2 counsel, Mr. Heil, was engaged on trial. 5. Due to the nature of this action, on November 19, 2015, the parties’ jointly moved for a confidentiality order, which was granted. (Dkt. #30) Extensive written discovery and extensive document production proceeded with the parties, by agreement, exchanging written discovery on December 4, 2015. Plaintiff was also required to supplement her discovery responses, which was done on December 18, 2015. Defendant produced 1,198 pages of documents, which required extensive analysis prior to, and in preparation for Plaintiff’s deposition. 6. On January 13, 2016, Plaintiff was presented for her deposition. Following Plaintiff’s deposition, Plaintiff made her second settlement demand. 7. Plaintiff believes that she can complete her discovery, including depositions, within 90 days, barring unforeseen circumstances. 8. Plaintiff also desires the opportunity to engage in a settlement conference with the Court. 9. This is Plaintiff’s first request for an extension of time within which to complete written discovery. 10. Defendant opposes Plaintiff’s request for this extension. 11. An additional 90 days within which to conduct discovery is not prejudicial to the parties nor to the Court. Furthermore, the allowance of this additional time will ultimately facilitate the expeditious resolution of this case, either by settlement or by trial. WHEREFORE, for the reasons stated above, Plaintiff respectfully requests that this Court enter an order extending discovery for an additional 90 days, or until March 31, 2016, and for any other and further relief as this Court deems just and proper. Case: 1:14-cv-08302 Document #: 33 Filed: 01/15/16 Page 2 of 4 PageID #:132 3 Respectfully submitted, By: /s/ Stephen W. Heil__________ Stephen W. Heil ARDC 6204266 Cray Huber Horstman Heil & VanAusdal LLC 303 West Madison, Suite 2200 Chicago, IL 60606 (312) 332-8450 swh@crayhuber.com Attorney for Plaintiff Sharron Greenwood Case: 1:14-cv-08302 Document #: 33 Filed: 01/15/16 Page 3 of 4 PageID #:133 4 CERTIFICATE OF SERVICE The undersigned certifies pursuant to Fed.R.Civ.P. 5 and L.R. 5.5, that a true and correct copy of the foregoing EXTENSION OF TIME WITHIN WHICH TO COMPLETE DISCOVERY was filed on January 15, 2016, with the clerk of the court using the CM/ECF system, which will send notice to counsel of record. By: /s/Stephen W. Heil Stephen W. Heil Case: 1:14-cv-08302 Document #: 33 Filed: 01/15/16 Page 4 of 4 PageID #:134