Miller et al v. Midland Credit Management, Inc. et al

MOTION

N.D. Ill.July 16, 2008

504246.1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MARCIA K. MILLER, et al. Plaintiffs, v. MIDLAND CREDIT MANAGEMENT, INC., et al., Defendants. Case No.: 08 CV 780 Judge Coar Magistrate Judge Ashman AGREED MOTION OF DEFENDANTS FOR EXTENSION OF TIME TO RESPOND TO REQUESTS FOR ADMISSIONS Defendant Midland Credit Management, Inc. (“Midland Credit” ), Midland Funding LLC (“Midland Funding” ), and Encore Capital Group, Inc. f/k/a MCM Capital Group, Inc. (Encore Capital” ) (collectively “Defendants”), by their undersigned attorneys, move for an extension of time to and including July 30, 2008, to respond to Plaintiffs’ Request to Admit under Fed.R.Civ.P. 36, and in support states as follows: 1. Defendants’ responses to Plaintiff served their First Discovery Requests currently are due July 16, 2008. (Doc. #34.) 2. Despite good faith efforts to do so, counsel for Defendants requires an additional 14 days to complete responses to those Requests for Admissions. 3. On July 16, 2008, counsel for Defendants spoke with one of the attorneys for Plaintiffs, Cassandra P. Miller, and Ms. Miller has no objection to this motion or to the relief requested herein. 4. No party will be prejudiced by the requested extension. Case 1:08-cv-00780 Document 35 Filed 07/16/2008 Page 1 of 2 2 504246.1 WHEREFORE, Defendants respectfully request that this Honorable Court grant this Agreed Motion, give Defendants to and including July 30, 2008 to respond to Plaintiffs’ Requests for Admission, and award to Defendants such other and further relief as this Court deems just and appropriate. Respectfully submitted, Midland Credit Management, Inc., Midland Funding LLC, and Encore Capital Group, Inc. f/k/a MCM Capital Group, Inc., Defendants By: /s/ Jason M. Kuzniar____________________ One of their attorneys Jason M. Kuzniar, Esq. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER, LLP 120 North LaSalle Street, Suite 2600 Chicago, IL 60602 (312) 704-0550 CERTIFICATE OF SERVICE The undersigned, an attorney, hereby certifies that on the 16th day of July 2008, the above and foregoing was electronically filed with the Clerk of the Court using the CM/ECF system and that a true and correct copy was served on the following by CM/ECF Electronic Notification: Cathleen M. Combs, Esq. (ccombs@edcombs.com) Cassandra P. Miller, Esq. (cmiller@edcombs.com) Daniel A. Edelman, Esq. (courtecl@edcombs.com) James O. Latturner, Esq. (jlatturner@edcombs.com) _/s/ Jason M. Kuzniar ________ Jason M. Kuzniar Case 1:08-cv-00780 Document 35 Filed 07/16/2008 Page 2 of 2