Franek v. Walmart Stores, Inc. et al

Filing 19

MOTION by Defendant Walmart Stores, Inc. for extension of time to file answer or otherwise plead Agreed (Valdetero, Jena)

Case 1:08-cv-00058 Document 19

Filed 03/04/08 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CLEMENS FRANEK, Plaintiff, vs. WAL-MART STORES, INC. & TARGET CORPORATION, Defendants. ) ) ) ) ) ) ) ) ) )

Case No. 08-cv-00058

Judge Robert M. Dow, Jr.

AGREED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD Defendant Wal-Mart Stores, Inc. ("Wal-Mart"), by and through its attorneys, hereby respectfully moves the Court for an Order granting Wal-Mart an extension of time, up to and including March 18, 2008, in which to answer or otherwise plead to Plaintiff's Complaint. In support of this Motion, Wal-Mart states as follows: 1. 2. Wal-Mart's answer or other responsive pleading is due on March 4, 2008. Wal-Mart needs additional time to conduct an appropriate investigation of

the factual and legal bases of the allegations in Plaintiff's Complaint in order to prepare a proper response thereto. 3. This Motion is not made for the purpose of delay, and Plaintiff will not be

prejudiced by the short extension requested. 4. Plaintiff's counsel was contacted on March 4, 2008, and Plaintiff's

counsel consents to this Motion.

72152.1

Case 1:08-cv-00058 Document 19

Filed 03/04/08 Page 2 of 3

WHEREFORE, Wal-Mart Stores, Inc. respectfully requests that the Court enter an Order granting an extension, up to and including March 18, 2008, within which to file an answer or other responsive pleading. Dated: March 4, 2008 Respectfully submitted, WAL-MART STORES, INC. By: /s/ Jena Valdetero One of Its Attorneys David A. Roodman BRYAN CAVE LLP One Metropolitan Square 211 North Broadway, Suite 3600 St. Louis, Missouri 63102 Mark A. Paskar Jena Valdetero BRYAN CAVE LLP 161 North Clark Street, Suite 4300 Chicago, Illinois 60601 Telephone: [phone] Facsimile: [phone]

72152.1

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Case 1:08-cv-00058 Document 19

Filed 03/04/08 Page 3 of 3

CERTIFICATE OF SERVICE The undersigned, an attorney, certifies that a true and correct copy of the foregoing document was served via the court's electronic filing system this 4th day of March, 2008, to all counsels of record: Mark D. Roth [e-mail] Larry L. Saret [e-mail] Arthur Gollwitzer, III [e-mail] Gilberto Eduardo Espinoza [e-mail] _____/s/ Jena Valdetero_______________ Jena Valdetero

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