Walsh v. Credit Protection Association, LPMOTIONN.D. Ill.April 21, 20086231382v1 880635 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Patrick Walsh, Plaintiff, v. Credit Protection Association, L.P., Defendant. ) ) ) ) ) ) ) ) ) ) Case No.: 08 C 1717 Judge Hart Magistrate Judge Keys MOTION FOR ENLARGEMENT OF TIME Defendant, Credit Protection Association, L.P., by its attorney Justin M. Penn, pursuant to Federal Rule of Civil Procedure 6(b) respectfully request that this court grant a 21-day enlargement of time to file a responsive pleading to the plaintiff s Complaint, and in support thereof, states as follows: 1. Plaintiff s Complaint purports to state claims under the Fair Debt Collection Practices Act against the defendant. 2. Plaintiff s Complaint was filed on March 24, 2008, and defendant was served on April 2, 2008. Defendant s responsive pleading is due April 22, 2008. 3. Defendant has retained defense counsel who has filed an Appearance concurrently with the instant motion. Counsel for the defendant has contacted counsel for the plaintiff to discuss possible early resolution of this case. 4. Defendant hereby requests an additional 21 days to answer or otherwise plead. This time is not meant for purposes of unnecessary delay and will not prejudice Case 1:08-cv-01717 Document 11 Filed 04/21/2008 Page 1 of 3 6231382v1 880635 any party in the litigation. This time is necessary to analyze the pleading and prepare the appropriate response to the plaintiff s claims and fully explore early settlement. WHEREFORE, Defendant, Credit Protection Association, L.P. respectfully requests that this Court grant a 21-day enlargement of time, up to and including, May 13, 2008, to file a responsive pleading to the plaintiff s Complaint. Respectfully submitted, Credit Protection Association, L.P. By: s/Justin M. Penn One of the Attorneys for Defendant Justin M. Penn -Atty Bar No. 06283726 HINSHAW & CULBERTSON LLP 222 N. LaSalle Street Suite 300 Chicago, IL 60601-1081 312-704-3000 Case 1:08-cv-01717 Document 11 Filed 04/21/2008 Page 2 of 3 6231382v1 880635 CERTIFICATE OF SERVICE I, the undersigned, certify that I filed this Notice and the document referenced herein through the Court s ECM/CF system, which will cause electronic notification of this filing to be sent to all counsel of record on April 21, 2008. s/Justin M. Penn Justin M. Penn Case 1:08-cv-01717 Document 11 Filed 04/21/2008 Page 3 of 3
