Whitley v. Taylor, Bean & Whitaker Mortgage Corp. et al

MOTION

N.D. Ill.August 4, 2008

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION IDA MAE WHITLEY, ) ) Plaintiff, ) ) v. ) ) TAYLOR, BEAN & WHITAKER MORTGAGE ) CORP., ADVANCE LENDING GROUP, CORP., ) Case No. 08-CV-3114 GIL & GIL GROUP CORP., REAL ) ESTATE-LINCOLN, FAVIAN CARDENAS, ) Judge Castillo BLUE HORIZON REAL ESTATE CORP., ) and DOES 1-10, ) Magistrate Judge Valdez ) Defendants. ) DEFENDANT ADVANCE LENDING GROUP, CORP.’s MOTION FOR ENLARGEMENT OF TIME TO ANSWER OR OTHERWISE PLEAD COMES NOW defendant Advance Lending Group, Corp., by counsel, Katten & Temple, LLP, and hereby moves this Honorable Court for an enlargement of time of 14 days to answer or otherwise plead to plaintiff’s complaint, and in support thereof, states as follows: 1. Plaintiff filed her complaint in this matter on or about May 30, 2008. 2. This Court has previously ordered all defendants to answer or otherwise plead by August 8, 2008. An initial status hearing is set for August 20, 2008 at 9:45 a.m. 3. Counsel was recently retained by Advance Lending and filed their appearances on July 31, 2008. 4. Plaintiff’s counsel has indicated that plaintiff intends to file an amended complaint in this matter in the near future. 5. Counsel will be on vacation the week of August 11, 2008. Case 1:08-cv-03114 Document 15 Filed 08/04/2008 Page 1 of 2 6. Defendant Advance Lending hereby requests that this Court grant it an additional 14 days (up to and including August 22, 2008) to answer or otherwise plead to plaintiff’s complaint. 7. No party will be prejudiced as a result of the relief sought in this motion, nor is this motion presented for delay or any other improper purpose. WHEREFORE, Advance Lending Group, Corp. respectfully requests entry of an Order extending its time to answer or otherwise plead up to and including August 22, 2008, and granting such further relief as the Court finds just and appropriate. DATED: August 4, 2008 Respectfully submitted, ADVANCED LENDING GROUP, CORP. By: /s/ Joshua R. Diller_________ One of its Attorneys Nancy A. Temple (6205448) Joshua R. Diller (6289368) Katten & Temple, LLP 542 S. Dearborn St., Suite 610 Chicago, IL 60605 312-663-0800 312-663-0900 (fax) Case 1:08-cv-03114 Document 15 Filed 08/04/2008 Page 2 of 2