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Case: 1:13-cv-01569 Document #: 37

Case: 1:13-cv-01569 Document #: 37

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Published by simality
Duffy wants more time to file a response to Russell's counter-claim
Duffy wants more time to file a response to Russell's counter-claim

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Published by: simality on Sep 30, 2013
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10/01/2013

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1
IN THE UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
DUFFY, ))) No. 13-cv-1569Plaintiff, )v. )) On Removal From The CircuitPAUL GODFREAD, ALAN COOPER ) Circuit Court of St. Clair County,and JOHN DOES 1-10, ) Illinois, 13-L-73
 
)Defendants. )) __________________________________________)
PLAINTIFF
S MOTION FOR EXTENSION OF TIME TOANSWER OR OTHERWISE PLEAD
Plaintiff, pursuant to Federal Rule of Civil Procedure 15 and other governing law,respectfully requests that this Court grant leave for him to answer or otherwise plead to theamended counterclaim of certain defendants, filed on September 16, 2013. In support hereof,Plaintiff states as follows:1.
 
This Court in its August 14, 2013 Order granted the named Defendants thirty (30)days to amend their counterclaim against Plaintiff. (ECF No. 27.) Defendants filedtheir amended counterclaim thirty-three (33) days later, on September 16, 2013.(ECF No.36.)2.
 
The amended counterclaim alleges a number of matters (a striking volume of whichare outright false or, at a minimum, materially misleading) that were not included inthe first iteration of their counterclaim. Plaintiff believes that the amendedcounterclaim includes most or all of the same defects that led to the dismissal of their initial counterclaim.
Case: 1:13-cv-01569 Document #: 37 Filed: 09/30/13 Page 1 of 4 PageID #:1163
 
23.
 
Because of the substantial number of new or modified allegations in the counterclaim,however, Plaintiff requests additional time to prepare and submit a motion addressedto the counterclaim. Plaintiff therefore requests that this Court grant it an additionalfourteen (14) days, until October 14, 2013, to answer or otherwise plead to theamended counterclaim.4.
 
Plaintiff does not bring this Motion for purposes of causing undue delay or for anyimproper purpose. Plaintiff does not believe that its request for an extension of timewill have an impact on the scheduled status date of December 12, 2013 (ECF No. 35.)WHEREFORE, for all of the foregoing reasons, Plaintiff respectfully requests thatthis Court grant this Motion; grant it until October 14, 2013 to answer or otherwise plead to the amended counterclaim; and grant any and all further relief that this Courtdeems to be reasonable and appropriate under the circumstances.Respectfully submitted,Paul A. Duffy, PLAINTIFFDATED: September 30, 2013By: s/ Paul A. DuffyPaul Duffy (Bar No. 6210496)2 N. LaSalle Street, 13
th
Floor Chicago, IL 60602Telephone: (312) 952-6136Facsimile: (312) 346-8434E-mail: pduffy@pduffygroup.com
 Attorney for Plaintiffs
Case: 1:13-cv-01569 Document #: 37 Filed: 09/30/13 Page 2 of 4 PageID #:1164
 
3
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on September 30, 2013, all counsel of record whoare deemed to have consented to electronic service are being served a true and correct copy of 
the foregoing document using the Court’s CM/ECF
system, in compliance with Local Rule5.2(a).
 
/s/ Paul DuffyPaul Duffy
 
Case: 1:13-cv-01569 Document #: 37 Filed: 09/30/13 Page 3 of 4 PageID #:1165

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