T.C. Development & Design Inc v. K&L Supply Co IncMOTIONN.D. Ill.September 4, 2008K Mn for 30-day ext time.doc 1717149/rRJS IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS WESTERN DIVISION T.C. DEVELOPMENT & DESIGN, INC. ) dba CONDOR PRODUCTS, ) ) Plaintiff, ) Case No.: 03:08-CV-50062 ) v. ) Judge PHILIP REINHARD ) K&L SUPPLY CO., INC. ) Mag. Judge P. MICHAEL MAHONEY ) Defendant. ) NOTICE AND AGREED MOTION FOR 30-DAY EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD TO THE COMPLAINT To: Plaintiff and Its Counsel of Record Please take notice that Defendant K&L Supply Co., Inc., hereby moves, with agreement of counsel Kathleen A. Rheintgen for Plaintiff T.C. Development & Design, Inc., for an exten- sion of 30 days, from September 8, 2008 to and including October 8, 2008, to file its Answer or other Pleading in response to the Complaint in this matter. This extension will allow the parties to continue and hopefully to conclude settlement talks in this matter. This motion is not interposed for any purpose of mere delay. Respectfully submitted, Dated: September 4, 2008 Defendant K&L Supply Co., Inc. By: __/s/J.R. Crossan ____ Its Local Counsel Robert J. Schneider John R. Crossan CHAPMAN AND CUTLER LLP 111 West Monroe Street, #1700 Chicago, Illinois 60603 (312) 845-3000 Case 3:08-cv-50062 Document 14 Filed 09/04/2008 Page 1 of 2 -2- Facsimile: (312) 701-2361 iplaw@chapman.com crossan@chapman.com Timothy J. Maier MAIER & MAIER, PLLC 1000 Duke Street Alexandria, VA 22314 (703) 740-8322 x-101 Facsimile: (703) 991-7071 tjm@maierandmaier.com CERTIFICATE OF SERVICE A true copy of the foregoing NOTICE AND AGREED MOTION FOR 30-DAY EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD TO THE COMPLAINT is being served through the Court’s ECM system on each of the counsel of record for Plaintiff, on this 4th day of September 2008, and a copy is being delivered to chambers of Magistrate Judge Mahoney via overnight courier. ____/s/ J R Crossan ______ Counsel for Defendant K&L Supply Case 3:08-cv-50062 Document 14 Filed 09/04/2008 Page 2 of 2
