Vergara v. Uber Technologies, Inc.

MOTION

N.D. Ill.August 31, 2015

LEGAL127546951.2 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MARIA VERGARA, individually and on behalf of a class of similarly situated individuals, Plaintiff, v. UBER TECHNOLOGIES, INC., a Delaware limited liability company, Defendant No. 1:15-cv-06942 Judge Thomas Durkin Magistrate Jeffrey Cole AGREED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD TO PLAINTIFF’S COMPLAINT Now comes Defendant Uber Technologies, Inc., a Delaware Corporation (“Uber”), by its counsel, Perkins Coie LLP and pursuant to Federal Rule of Civil Procedure 6(b), hereby moves on an unopposed basis for an extension of time to answer or otherwise plead to Plaintiff’s Class Action Complaint to October 5, 2015 and in support, state as follows: 1. Plaintiff filed her Class Action Complaint on August 7, 2015 and Defendant was served on or about August 14, 2015. Defendant’s responsive pleading is due September 4, 2015 and Defendant is requesting an extension of time to and including October 5, 2015. The Court has set a status date of October 13, 2015 and a Status Report due on October 8, 2015. (Dkt. 2) No other dates have been set in this case. 2. Uber’s counsel, Debra Bernard, contacted Plaintiff’s counsel, Evan Meyers and he agrees to the requested extension. 3. This case was only recently filed, Uber has not previously requested any extensions of time and this extension of time is not requested for the purpose of delay. WHEREFORE, Uber respectfully requests that this Court grant this Agreed Motion for Extension of Time to Answer or Otherwise Plead to Plaintiff’s Complaint to October 5, 2015 and for such other and further relief the Court deems necessary in the interest of justice. Case: 1:15-cv-06942 Document #: 3 Filed: 08/31/15 Page 1 of 3 PageID #:12 LEGAL127546951.2 -2- UBER TECHNOLOGIES, INC., By: /s/ Debra R. Bernard One of its Attorneys Debra R. Bernard Perkins Coie LLP 131 S. Dearborn Street, Suite 1700 Chicago, Illinois 60603 (312) 324-8400 dbernard@perkinscoie.com Dated: August 31, 2015 Case: 1:15-cv-06942 Document #: 3 Filed: 08/31/15 Page 2 of 3 PageID #:13 LEGAL127546951.2 -3- CERTIFICATE OF SERVICE I, Debra R. Bernard, certify that on August 31, 2015, I caused the foregoing AGREED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD TO PLAINTIFF’S COMPLAINT to be filed via CM/ECF and served on the following: Myles McGuire Evan M. Meyers Eugene Y. Turin MCGUIRE LAW, P.C. 55 W. Wacker Drive, 9th Floor Chicago, Illinois 60601 T: (312) 893-7002 F: (312)275-7895 mmcguire@mcgpc.com emeyers@mcgpc.com eturin@mcgpc.com /s/ Debra R. Bernard Case: 1:15-cv-06942 Document #: 3 Filed: 08/31/15 Page 3 of 3 PageID #:14