Rude Music Inc v. Newt 2012, Inc. et al
MOTION by Plaintiff Rude Music Inc to supplement its Motion to Strike Affirmative Defenses (Attachments: # 1 Exhibit A)(McGarry, Annette)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
RUDE MUSIC, INC.,
NEWT 2012, INC.,NEWT
GINGRICH, and AMERICAN
) Case No. 12 cv 640
) Judge Kennelly
) Magistrate Judge Finnegan
PLAINTIFF’S MOTION FOR LEAVE TO SUPPLEMENT
ITS MOTION TO STRIKE AFFIRMATIVE DEFENSES
Rude Music, Inc. respectfully requests leave to file a supplement to its
motion to strike certain affirmative defenses asserted by Newt 2012, Inc. and
Newt Gingrich (collectively, “Gingrich”). In support of its motion, Rude Music
On March 7, 2012, Rude Music filed its motion to strike. (Doc. No.
24) On March 13, 2012, the Court continued the motion to April 4, and ordered
Gingrich to file an amended answer by March 27. (Doc. No. 33) Gingrich did so.
(Doc. No. 38)
Gingrich’s amended answer and affirmative defenses, for the most
part, fails to cure the defects in the initial pleading. Rude Music seeks leave to
supplement its motion to identify the uncured defects in the amended answer and
asks that this Court strike these defenses with prejudice and award Plaintiff its
fees for having to file this Supplement. A copy of the proposed supplement is
attached as Exhibit A.
WHEREFORE, Rude Music asks that the Court grant it leave to file
Plaintiff’s Supplement to Its Motion to Strike Affirmative Defenses.
/s/ Annette M. McGarry
Annette M. McGarry (#6205751)
Marianne C. Holzhall (#6204057)
McGarry & McGarry, LLC
120 North LaSalle Street, Suite 1100
Chicago, IL 60602
Attorneys for Rude Music, Inc.
CERTIFICATE OF SERVICE
I hereby certify that on March 29, 2012, the foregoing Plaintiff’s Motion for
Leave to Supplement Its Motion to Strike Affirmative Defenses was electronically
filed using the CM/ECF system and served upon:
Hall, Booth, Smith & Slover, PC
611 Commerce Street, Suite 2925
Nashville, TN 37203
Brian A. Rosenblatt
Darren P. Grady
Kyra E. Flores
150 North Michigan Avenue, Suite 3300
Chicago, IL 60601
Brian E. Cohen
Steven F. Pflaum
Neal, Gerber & Eisenberg
2 North LaSalle Street, Suite 1700
Chicago, IL 69602
Wiley Rein LLP
1776 K Street N.W.
Washington, DC 20006
/s/ Annette M. McGarry
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