Ondras v. Professional Compounding Centers of America et al

MOTION

N.D. Ill.June 25, 2015

1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS KATHLEEN I. ONDRAS, Individually and as Personal Representative of the Estate of Christopher A. Ondras, Plaintiff, v. PROFESSIONAL COMPOUNDING CENTERS OF AMERICA, PADDOCK LABORATORIES/PERRIGO, and MEDISCA, INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 15-cv-4595 Judge Matthew F. Kennelly AGREED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE PLEAD Defendant Medisca, Inc. (“Medisca”), by its undersigned counsel, and with agreement from counsel for Plaintiff, Kathleen I. Ondras, Individually and as Personal Representative of the Estate of Christopher A. Ondras (“Plaintiff”), hereby moves this Court, pursuant to Federal Rule of Civil Procedure 6(b) for an extension of time to answer or otherwise plead in response to Plaintiff’s Complaint. In support thereof, Medisca states as follows: 1. On May 26, 2015, Plaintiff filed her Complaint. (Dkt. No. 1.) 2. Plaintiff served her Complaint on Medisca on June 18, 2015. 3. Medisca’s response to Plaintiff’s Complaint is currently due July 9, 2015. 4. Medisca seeks additional time, until August 21, 2015, to answer or otherwise plead. 5. On June 22, 2015, Plaintiff’s counsel stated that she agrees to the extension of time requested by this motion. Case: 1:15-cv-04595 Document #: 9 Filed: 06/25/15 Page 1 of 3 PageID #:17 2 6. This motion is not made for purposes of harassment or undue delay, nor is it due to any oversight or lack of diligence on the part of Medisca. WHEREFORE, Medisca respectfully requests that this Court grant this Agreed Motion to Extend Time to Answer or Otherwise Plead and enter an order extending the time within which Medisca must answer or otherwise plead up to and including August 21, 2015. Dated: June 25, 2015 Respectfully Submitted, /s/ W. Gordon Dobie_____ W. Gordon Dobie Thomas G. Weber WINSTON & STRAWN LLP 35 West Wacker Drive Chicago, Illinois 60601 Tel: (312) 558-5600 Fax: (312) 558-5700 wdobie@winston.com tgweber@winston.com Counsel for Medisca, Inc. Case: 1:15-cv-04595 Document #: 9 Filed: 06/25/15 Page 2 of 3 PageID #:18 3 CERTIFICATE OF SERVICE I, Thomas G. Weber, attorney for Defendant Medisca, Inc., certify that on June 25, 2015, I caused a true and correct copy of the foregoing AGREED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE PLEAD to be electronically filed with the Clerk of the Court using the CM/ECF system, which will send a notice of electronic filing to all parties and counsel of record, including: Rebecca A.G. Robertson MacDonald Law Group, LLC One Bowdoin Square, Eighth Floor Boston, MA 02114 Tel: (617) 747-7551 Fax: (617) 747-7551 rrobertson@mlglegal.com By: /s/ Thomas G. Weber____ Case: 1:15-cv-04595 Document #: 9 Filed: 06/25/15 Page 3 of 3 PageID #:19