Demar v. Chicago White Sox, Ltd., The et al

Filing 37

MOTION by Defendants Chicago White Sox, Ltd., The, Chisox Corporation, At Your Service, Inc., At Your Service, L.L.C. for extension of time Agreed Motion for Extension of Time (Vlahakis, James)

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Demar v. Chicago White Sox, Ltd., The et al Doc. 37 Case 1:05-cv-05093 858400/DW Document 37 Filed 02/23/2006 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ROBERT DEMAR, ) ) ) Plaint iff, ) ) vs. ) THE CHICAGO WHITE SOX, LTD., CHISOX ) ) CORPORATION, a corporation, AT YOUR ) SERVICE, INC., a corporation, AT YOUR ) SERVICE, L.L.C., SDI SECURITY, INC., a ) corporation, SUPERIOR AIR-GROUND AMBULANCE SERVICE, INC., a corporation, ) ) and OTHER UNKNOWN DEFENDANTS, ) ) Defendants. Case No. 05 C 5093 Judge Der-Yehiayan Magistrat e Judge Levin AGREED MOTION FOR EXTENSION OF TIME NOW COME the Defendants CHICAGO WHITE SOX, LTD., CHISOX CORPORATION, a corporation, AT YOUR SERVICE, INC., a corporation, and AT YOUR SERVICE, LLC, by and through their attorneys, HINSHAW & CULBERTSON LLP, and for their Agreed Motion for Extension of Time to File Their Answer to Plaintiff s Amended Complaint at Law, state as follows: 1. Pursuant to the Court s prior schedule, these Defendants were to file an Answer to Plaint iff s Amended Complaint by February 22, 2006. 2. Lead counsel was unable to file a timely response on behalf of these defendants due to lead counsel s professional commitments and vacation out of state until March 2, 2006. 3. These defendants seek an extension of time until March 6, 2006 in which to file an Answer to Plaintiff s Amended Complaint. 4. Plaint iff has no objection to this extension of time and no party will be prejudiced by this extension of time. 6030670v1 858400 Dockets.Justia.com Case 1:05-cv-05093 Document 37 Filed 02/23/2006 Page 2 of 3 5. 6. Discovery in this case will continue and not be affected by the extension of time. This motion is made in good faith and not for the purpose of delay, harassment or improper purpose. WHEREFORE, the Defendants, CHICAGO WHITE SOX, LTD., CHISOX CORPORATION, a corporation, AT YOUR SERVICE, INC., a corporation, and AT YOUR SERVICE, LLC, respectfully request that this court grant this agreed motion and grant them until March 6, 2006 to file an Answer to Plaintiff s Amended Complaint. Respectfully submitted, By: /s/ James C. Vlahakis One of the Attorneys for Defendants Chicago White Sox, Ltd., ChiSox Corporation (hereinafter the "Sox defendants"), At Your Service, Inc. and At Your Service LLC James C. Vlahakis Robert T. Shannon Diane E. Webster HINSHAW & CULBERTSON LLP 222 North LaSalle Street Suite 300 Chicago, Illinois 60601-1081 (312) 704-3000 ARDC No. 6230459 Jvlahakis@hinshawlaw.com 2 6030670v1 858400 Case 1:05-cv-05093 Document 37 Filed 02/23/2006 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that on February 23, 2006, I electronically filed Defendants Chicago White Sox, Ltd., ChiSox Corporation, At Your Service, Inc. and At Your Service LLC s Agreed Motion for Extension of Time, with the Clerk of the Court using the CM/ECF system which will send notification of such filing(s) to all counsel of record. I hereby certify that on February 23, 2006, I served a hard copy of the aforementioned motion to the following attorney of record: Matthew T. Martell 7557 W. 63rd Street Summit, Illinois 60501 Respect fully submitted, By: /s/ James C. Vlahakis James C. Vlahakis HINSHAW & CULBERTSON LLP 222 North LaSalle Street Suite 300 Chicago, Illinois 60601-1081 (312) 704-3000 ARDC No. 6230459 Jvlahakis@hinshawlaw.com 3 6030670v1 858400

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