Solano et al v. Rolling Stone L.L.C.

MOTION

N.D. Ill.July 10, 2008

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS MELISSA SOLANO and CEIL STEARMAN Plaintiffs, - against - ROLLING STONE L.L.C., Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) 08 CV 3909 Judge Joan Humphrey Lefkow Magistrate Judge Valdez UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANT TO ANSWER OR OTHERWISE PLEAD Defendant, Rolling Stone L.L.C. (“Defendant”), moves this Court for an extension of time within which to answer or otherwise plead to plaintiffs, Melissa Solano and Ceil Stearman’s (“Plaintiffs”) complaint in the above-captioned action, to and including August 11, 2008. In support of its motion, Defendant states as follows: 1. On or about May 23, 2008, Plaintiffs filed a complaint against Defendant in the Circuit Court of Cook County entitled Melissa Solano and Ceil Stearman v. Rolling Stone L.L.C. Case No. 08 L 5729 (“Complaint”). 2. On or about June 10, 2008, Defendant was served with copies of the Summons and Complaint. 3. On or about July 3, 2008, Defendant contacted Plaintiffs’ counsel with a request to extend the time for Defendant to answer or otherwise plead to Plaintiffs’ complaint. 4. On July 3, 2008, Plaintiffs’ counsel signed a stipulation to extend the time for Defendant to answer or otherwise plead up to and including August 11, 2008. A copy of the stipulation is attached to this Motion as Exhibit A. Case 1:08-cv-03909 Document 7 Filed 07/10/2008 Page 1 of 2 5. On July 9, 2008, Defendant filed a Notice of Removal with this Court to remove this matter from state court on diversity jurisdiction grounds. 6. On July 10, 2008, counsel for Plaintiffs affirmed via e-mail that Plaintiffs do not oppose a thirty day-extension of time for Defendant to answer or otherwise plead. WHEREFORE, Defendant, Rolling Stone, L.L.C., respectfully requests an additional thirty (30) days, to and including August 11, 2008, in which to answer or otherwise respond to Plaintiffs’ Complaint. Dated: July 10, 2008 Respectfully submitted, ROLLING STONE, L.L.C. By:__/Steven L. Baron/ Steven L. Baron, ARDC No. 6200868 Natalie A. Harris, ARDC No. 6272361 Mandell Menkes LLC 333 West Wacker Drive, Suite 300 Chicago, Illinois 60606 Telephone: (312) 251-1000 Facsimile: (312) 251-1010 Attorneys for Defendant Of Counsel: Elizabeth A. McNamara Bryan M. Tallevi Davis Wright Tremaine LLP 1633 Broadway New York, NY 10019 Case 1:08-cv-03909 Document 7 Filed 07/10/2008 Page 2 of 2 Case 1:08-cv-03909 Document 7-2 Filed 07/10/2008 Page 1 of 1