Simon v. Northwestern University et al

MOTION

N.D. Ill.June 9, 2016

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ALSTORY SIMON, ) ) Plaintiff, ) ) v. ) No. 15 C 1433 ) PAUL J. CIOLINO, ) Honorable Robert M. Dow, Jr. ) Defendant, Third-Party Plaintiff, ) ) v. ) ) ANITA ALVAREZ, et al., ) ) Third-Party Defendants. ) UNOPPOSED MOTION FOR EXTENSION OF TIME Third-Party Defendant, Anita Alvarez (“Alvarez”), in her official capacity as State’s Attorney of Cook County, by her attorney, Anita Alvarez, State’s Attorney of Cook County, through Donald J. Pechous and Lisa M. Meador, Assistant State’s Attorneys, hereby moves this Honorable Court, pursuant to Federal Rule of Civil Procedure 6(b), for an extension of time in which to answer or otherwise plead to Third-Party Plaintiff’s Third-Party Complaint and, in support of this motion, state as follows: 1. On May 2, 2016, Third-Party Plaintiff, Paul J. Ciolino, filed an Amended Counterclaim and Third-Party Complaint naming Alvarez as a Third-Party Defendant. 2. Counsel for Third-Party Defendant, Alvarez, recently was assigned and filed her appearance on June 8, 2016. Counsel requires additional time to answer or otherwise plead to the Amended Counterclaim and Third-Party Complaint so as to sufficiently determine the appropriate course of action. Case: 1:15-cv-01433 Document #: 112 Filed: 06/09/16 Page 1 of 2 PageID #:928 2 3. A responsive pleading by the other named Third-Party Defendants who have already appeared is due on June 9, 2016. 4. Third-Party Defendant Alvarez asks this Court to grant her until July 11, 2016 to answer or otherwise plead. 5. The request for an extension is made in good faith and will not prejudice the parties in this matter. 6. The parties have met and conferred and counsel for Third-Party Plaintiff has no objection to the extension of time. WHEREFORE, Third-Party Defendant Alvarez respectfully requests that this Honorable Court extend the time to answer or otherwise plead until July 11, 2016. Respectfully submitted, ANITA ALVAREZ State’s Attorney of Cook County By: _/s/ Lisa M. Meador Lisa M. Meador Donald J. Pechous Assistant State’s Attorney Cook County State’s Attorney’s Office 500 Richard J. Daley Center Chicago, Illinois 60602 (312) 603-3369 Case: 1:15-cv-01433 Document #: 112 Filed: 06/09/16 Page 2 of 2 PageID #:929