Redman v. Radioshack Corporation

MOTION

N.D. Ill.November 7, 2014

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION SCOTT D.H. REDMAN, individually and on behalf ) of all others similarly situated, ) Plaintiff, ) No. 11 C 6741 ) (consolidated with 11 C 7819) v. ) ) Judge Grady RADIOSHACK CORPORATION, ) a Delaware corporation, ) Magistrate Valdez Defendant. ) __________________________________________) MARIO ALIANO and VICTORIA ) RADAVICIUTE, individually and on behalf of ) all others similarly situated, ) Plaintiffs, ) ) v. ) ) RADIOSHACK CORPORATION, ) a Delaware corporation, ) Defendant. ) SCOTT REDMAN’S UNOPPOSED (BY PROPOSED INTERVENERS) MOTION FOR EXTENSION TO RESPOND TO MOTION TO INTERVENE Plaintiff Scott D.H. Redman (“Redman”), by counsel, and pursuant to Fed. R. Civ. P. 6(b), moves this Court for an extension of time to respond to Gregory Runyard’s and Eduardo Vasquez’s Motion to Intervene [DE 196] (“Motion to Intervene”). In support of this Motion, Redman states as follows: 1. On October 15, 2014, Gregory Runyard and Eduardo Vasquez (“Proposed Interveners”) filed the Motion to Intervene. 2. On October 22, 2014, this Court set a briefing schedule requiring Redman to respond to the Motion to Intervene by November 13, 2014 [DE 199]. Case: 1:11-cv-06741 Document #: 203 Filed: 11/07/14 Page 1 of 3 PageID #:2367 2 3. Redman’s undersigned counsel has been unable to respond adequately to the Motion to Intervene in part due to several absences from the office due to his daughter’s recent illness. 4. Additionally, Redman’s undersigned counsel believes that the time and resources of the parties would be better served in the near term attempting to seek a resolution to this case, rather than potentially creating divisions among the stakeholders. 5. Therefore, Redman requests that this Court grant him an additional 28 days, to December 11, 2014, to respond to the Motion to Intervene. 6. Redman’s undersigned counsel has conferred with Proposed Intervener’s counsel, Curtis Warner, and he has no opposition to this motion. WHEREFORE, for the foregoing reasons, Scott D.H. Redman requests that this Court grant him an extension, to December 11, 2014, to respond to the Motion to Intervene. SCOTT D.H. REDMAN, Plaintiff, By: /s Paul F. Markoff Paul F. Markoff Karl G. Leinberger Markoff Leinberger LLC 134 N LaSalle St Ste 1050 Chicago IL 60602 Tel: 312.726.4162 Fax: 312.674.7272 paul@markleinlaw.com Case: 1:11-cv-06741 Document #: 203 Filed: 11/07/14 Page 2 of 3 PageID #:2368 3 CERTIFICATE OF SERVICE I certify that I served a copy of this Scott Redman’s Unopposed (by Proposed Interveners) Motion for Extension to Respond to Motion to Intervene on all counsel of record electronically by using the CM/ECF system on this 7th day of November, 2014: /s Paul F. Markoff Case: 1:11-cv-06741 Document #: 203 Filed: 11/07/14 Page 3 of 3 PageID #:2369