Grochocinski v. Mayer Brown Rowe & Maw LLP et al

Filing 159

RESPONSE by Plaintiff David Grochocinski to Defendants Amended Unoposed Motion for Extension of Time (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 RESPONSE TO DEFENDANTS’ UNOPPOSED MOTION FOR
EXTENSION OF TIME AND LEAVE TO FILE OVERSIZED REPLY
Plaintiff David Grochocinski, not individually but solely in his capacity as the Chapter 7
Trustee for the bankruptcy estate of CMGT, Inc. (“Plaintiff”) responds to Defendants’
unopposed motion for extension of time and leave to file oversized reply as follows:
1.

Plaintiff does not object to the relief requested in Defendants’ Motion. However,

Plaintiff does object to a misleading statement contained in that motion.
2.

Defendants state that Plaintiff’s response to Defendants’ motion for summary

judgment is “over 30 pages long.” (Def. Mot. at p. 2, ¶ 3.) That statement infers that Plaintiff
violated this Court’s Order that limited Plaintiff’s response to 30 pages.
3.

Although Plaintiff’s response is technically 31 pages long, the 31st page contains

only Plaintiff’s signature. Thus, it was misleading for Defendants to broadly state that Plaintiff
filed a response that is “over 30 pages long.”
4.

Plaintiff is filing this response simply to make the record clear about the length of

his response. He is not objecting to Defendants’ unopposed motion.

Dated: July 17, 2009

Respectfully submitted,
DAVID GROCHOCINSKI, not individually,
but solely in his capacity as the Chapter 7
Trustee for the bankruptcy 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. - Atty No. 32513
11 South LaSalle Street, Ste., 1600
Chicago, Illinois 60603

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CERTIFICATE OF SERVICE
The undersigned attorney, certifies that on July 17, 2009, he caused the attached
Plaintiff’s Response to Defendants’ Amended Unopposed Motion for Extension of Time
and Leave to File Oversized Reply to be served upon
Stephen Novack
Mitchell L. Marinello
Steven J. Ciszewski
Novack and Macey LLP
100 N. Riverside Plaza
Chicago, IL 60606
by electronically delivering a copy through the Court’s CM/ECF filing system.

/s/ Edward T. Joyce

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