Trujillo v. Apple Computer, Inc. et al

Filing 342

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Heath Allison and Alicia Allison, Plaintiffs, v. New Century Mortgage Corporation, Saxon Mortgage, Inc., and Does 1-5, Defendants. ) ) ) ) ) ) ) ) ) )

05 C 5273 Judge Pallmeyer Magistrate Judge Ashman

AGREED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD NOW COMES the Defendant, Saxon Mortgage, Inc. ("Saxon") by and through its undersigned counsel, pursuant to Federal Rule of Civil Procedure 6(b), and for its Agreed Motion For Extension of Time to Answer or Otherwise Plead states as follows: 1. Plaintiffs filed their Complaint on September 14, 2005. The Complaint was

served upon Saxon on September 14, 2005. 2. 3. response. 4. Plaintiff has agreed to allow Saxon an extension of thirty (30) days, up to and Saxon's answer or responsive pleading is due on October 4, 2005. Saxon requires additional time to investigate Plaintiffs' claims and prepare its

including November 3, 2005, to answer or otherwise plead. 5. Saxon does not bring the present motion for purposes of delay. Saxon has not

previously requested and extension of time from this Court and no party will be prejudiced by the granting of this motion.

WHEREFORE, Saxon Mortgage, Inc. respectfully prays that this Court enter an Order granting it an extension of time to answer or otherwise respond to Plaintiff's Complaint within 30 days, on or before November 3, 2005, and allowing any other further relief this Court deems just and appropriate. Dated: October 3, 2005 Respectfully submitted, Bank of America N.A. By: __Blair B. Hanzlik_/s/__ One of its Attorneys Linda B. Dubnow Blair B. Hanzlik (ARDC # 6279664) McGuireWoods LLP 77 W. Wacker Drive, Suite 4100 Chicago, IL 60601 Tel: [phone] Fax: [phone]

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