Grochocinski v. Mayer Brown Rowe & Maw LLP et al

Filing 143

MOTION by Plaintiff David Grochocinski for leave to file excess pages in Response to Defendants' Motion for Summary Judgment and Local Rule 56.1(b)(3)(C) (Joyce, Edward)

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ILLINOIS, EASTERN DISTRICT
DAVID GROCHOCINSKI, not individually,
but solely in his capacity as the Chapter 7
Trustee for the bankruptcy estate of
CMGT, INC.
Plaintiff,
v.
MAYER BROWN ROWE & MAW LLP,
RONALD B. GIVEN, and CHARLES W.
TRAUTNER,
Defendants.

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No. 06 C 5486
Judge Virginia M. Kendall

PLAINTIFF’S UNOPPOSED MOTION FOR LEAVE TO FILE OVERSIZE RESPONSE
TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND LOCAL RULE
56.1(b)(3)(C) STATEMENT
Plaintiff, David Grochocinski, in his capacity as the Chapter 7 trustee for the bankruptcy
estate of CMGT, Inc. (“Plaintiff”), moves for leave to file an oversize Response to defendants
Mayer Brown Rowe & Maw LLP’s and Ronald B. Given’s (“Defendants”) motion for summary
judgment and Local Rule 56.1(b)(3)(C) Statement. In support of this motion, Plaintiff states as
follows:
1.

On May 8, 2009, Defendants filed their Unopposed Motion for Leave to File

Oversize Summary Judgment Brief and Local Rule 56.1 Statement. Defendants requested leave
to file a brief not in excess of 30 pages and a Local Rule 56.1 Statement not in excess of 150
paragraphs. This Court granted Defendants’ motion.
2.

Defendants filed a 27 page summary judgment brief and a Local Rule 56.1

Statement containing 147 paragraphs. In addition to their oversized brief and Local Rule 56.1
Statement, Defendants have the opportunity to file a reply in support of their motion for
summary judgment.

3.

Plaintiff’s Response is his only opportunity to respond to Defendants’ summary

judgment motion. In order to fully address all of Defendants’ arguments and assertions of
purportedly undisputed facts, Plaintiff requires an oversize brief and Local Rule 56.1 statement.
4.

Defendants do not object to the relief sought herein.

Wherefore, Plaintiff respectfully requests that this Court: (a) grant this Unopposed
Motion; (b) grant Plaintiff leave to file a Response to Defendants’ motion for summary judgment
that is no longer than 30 pages in length; and, (c) grant Plaintiff leave to file a Local Rule
56.1(b)(3)(C) Statement containing no more than 75 numbered paragraphs.
Dated: June 19, 2009

Respectfully submitted,
DAVID GROCHOCINSKI, not individually, but
solely as the trustee in bankruptcy, for THE
ESTATE OF CMGT, INC.,

By:________/s/ Edward T. Joyce______________
Plaintiff’s attorneys

Edward T. Joyce
Arthur W. Aufmann
Robert D. Carroll
EDWARD T. JOYCE & ASSOC., P.C.
11 South LaSalle Street, Ste., 1600
Chicago, Illinois 60603
Telephone – [phone]
Atty No. 32513

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