Jackson v. Illinois Department Of Corrections et al

MOTION

N.D. Ill.August 1, 2008

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ROMEO JACKSON, ) ) Plaintiff, ) No.08-C-2597 ) v. ) Judge Charles P. Kocoras ) ILLINOIS DEPARTMENT ) OF CORRECTIONS, et al., ) ) Defendants. ) MOTION OF DR. PARTHA GHOSH, DR. EVARISTO AGUINALDO AND LATANYA WILLIAMS FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Defendants, DR. PARTHA GHOSH, DR. EVARISTO AGUILNALDO and LATANYA WILLIAMS, by their attorneys, CHARYSH & SCHROEDER, LTD., pursuant to FRCP 6(b), for their Motion For An Extension Of Time To Respond To Plaintiff’s Complaint, state as follows: 1. These defendants have previously signed waivers of service which require them to respond to plaintiff’s complaint by August 4, 2008. 2. That counsel for these defendants was only recently retained, and requires additional time to review plaintiff’s complaint, and properly review and investigate the facts of the case, in order to properly respond on behalf of said defendants. 3. These defendants request an enlargement of time of fourteen (14) days from the hearing date of this motion, in which to properly respond to plaintiff’s complaint. Case 1:08-cv-02597 Document 19 Filed 08/01/2008 Page 1 of 3 4. This motion is not made for the purpose of undue delay, and plaintiff will not be prejudiced by the granting of this motion, as not all defendants have yet been served. WHEREFORE, defendants, DR. PARTHA GHOSH, DR. EVARISTO AGUINALDO and LATANYA WILLIAMS, respectfully request that this Honorable Court enter an order granting an extension of time of fourteen (14) days from the hearing date of this motion, to respond to the plaintiff’s complaint. CHARYSH & SCHROEDER, LTD. /s/William Michael LeCrone CHARYSH & SCHROEDER, LTD. 33 North Dearborn Street Suite 1300 Chicago, Illinois 60602 (312) 372-8338 Michael J. Charysh, ARDC #6187455 William Michael LeCrone, ARDC # 6182862 Case 1:08-cv-02597 Document 19 Filed 08/01/2008 Page 2 of 3 PROOF OF SERVICE BY ELECTRONIC FILING AND U.S. MAIL The undersigned attorney certifies that on August 1, 2008, this motion was electronically filed with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to all counsel of record at the email addresses indicated above; this notice, and the documents referred to therein have also been served on all parties not electronically served by causing a copy of the same to be placed in the U.S. Mail at 33 North Dearborn Street, Chicago, Illinois on or before 5:00 p.m. on August 1, 2008, with proper postage prepaid. s/ William Michael LeCrone Case 1:08-cv-02597 Document 19 Filed 08/01/2008 Page 3 of 3