Mack v. Viking Client Services, Inc.

MOTION

N.D. Ill.July 5, 2012

EAST\47812785.3 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION DAVID MACK, ) ) Plaintiff, ) ) v. ) Case No. 1:12-cv-04574 ) VIKING CLIENT SERVICES, INC. f/k/a ) Judge Manning VIKING COLLECTION SERVICES, INC., ) ) Defendant. ) UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD IN RESPONSE TO PLAINTIFF’S COMPLAINT Defendant, Viking Client Services, Inc. f/k/a Viking Collection Services, Inc. (“Viking”) hereby moves this Court, under Fed. R. Civ. P. 6(b), for an extension of time to answer or otherwise plead in response to Plaintiff’s Complaint - Class Action (“Complaint”), and in support thereof states as follows: 1. Pursuant to service of summons, Viking is required to answer or otherwise plead to the Complaint in this case by July 6, 2012. 2. The allegations of the Complaint relate to alleged violations of the Telephone Consumer Protection Act, 47 U.S.C. § 227, and the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. 3. Viking is in the process of gathering records concerning the allegations contained in the Complaint so that it may fully address, and defend itself against, the claims asserted in the Complaint. 4. Viking respectfully requests that this Court extend their time to answer or otherwise plead to August 3, 2012. Case: 1:12-cv-04574 Document #: 7 Filed: 07/05/12 Page 1 of 3 PageID #:23 EAST\47812785.3 2 5. Counsel for the Plaintiff does not oppose the proposed extension. 6. Viking’s motion is not brought for purposes of needlessly delaying the proceedings and will not prejudice any party. WHEREFORE, Viking respectfully request that this Court grant its motion for an extension of time to answer or otherwise plead in response to the Complaint up to and including August 3, 2012. Date: July 5, 2012 Respectfully submitted, VIKING CLIENT SERVICES, INC. f/k/aVIKING COLLECTION SERVICES, INC. By: /s/ Albert E. Hartmann One of Its Attorneys Albert E. Hartmann (ARDC #06256064) DLA PIPER US LLP 203 North LaSalle Street, Suite 1900 Chicago, Illinois 60601 T: 312-368-2142 F: 312-630-7317 Email: albert.hartmann@dlapiper.com Case: 1:12-cv-04574 Document #: 7 Filed: 07/05/12 Page 2 of 3 PageID #:24 EAST\47812785.3 3 CERTIFICATE OF SERVICE I, Albert E. Hartmann, an attorney, depose and state that on July 5, 2012, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will serve electronic notice to all counsel of record. s/ Albert E. Hartmann Albert E. Hartmann Case: 1:12-cv-04574 Document #: 7 Filed: 07/05/12 Page 3 of 3 PageID #:25