Martin v. Credit Protection Association LPMOTIONN.D. Ill.October 26, 2011 130197812 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION NICHOLAS MARTIN, on behalf of himself and others similarly situated, Plaintiff, v. CREDIT PROTECTION ASSOCIATION, LP, Defendant. Case 1:11-cv-6828 UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant, CREDIT PROTECTION ASSOCIATION, LP, by its attorneys David M. Schultz and Justin M. Penn, and pursuant to Federal Rule of Civil Procedure 6(b), respectfully requests that this court grant it a 21 day enlargement of time to file its responsive pleading to plaintiff's Complaint - Class Action, and in support thereof, states as follows: 1. Plaintiff's Complaint purports to state a class action claim under the Telephone Consumer Protection Act against the defendant. 2. Plaintiff's Complaint was filed on September 28, 2011, and defendant was served on October 5, 2011. Defendant’s responsive pleading is due on October 26, 2011. 3. Defendant respectfully requests an additional 21 days in which to file a responsive pleading. 4. This time is not meant for purposes of unnecessary delay and will not prejudice any party in the litigation. 5. Counsel for defendant spoke with counsel for the plaintiff who indicated that there is no objection to the instant request. Case: 1:11-cv-06828 Document #: 7 Filed: 10/26/11 Page 1 of 3 PageID #:23 2 130197812 WHEREFORE, defendant, CREDIT PROTECTION ASSOCIATION, LP, respectfully requests this court grant it an enlargement of time up to and including November 16, 2011, to file an answer or to otherwise plead to plaintiff's Complaint. Respectfully submitted, CREDIT PROTECTION ASSOCIATION, LP By: /s/Justin M. Penn One of its Attorneys Justin M. Penn HINSHAW & CULBERTSON 222 N. LaSalle Street, Ste 300 Chicago, IL 60601 (312) 704-3000 jpenn@hinshawlaw.com Case: 1:11-cv-06828 Document #: 7 Filed: 10/26/11 Page 2 of 3 PageID #:24 3 130197812 CERTIFICATE OF SERVICE I, an attorney, hereby certify that on October 26, 2011 I electronically filed Defendant’s Unopposed Motion for Enlargement with the Clerk of the Court using the CM/ECF system which will send notification of such filing to all counsel of record. /s/Justin M. Penn Justin M. Penn Case: 1:11-cv-06828 Document #: 7 Filed: 10/26/11 Page 3 of 3 PageID #:25
