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Plaintiff,
v.
ASA ROBERT PODLASEK, ET AL.
Defendants.
Case No.13-CV-4924
Honorable Judge John Z. Lee
Magistrate Judge Sheila M. Finnegan
Defendants filed their motion for summary judgment based on the statute of
On October 5, 2016, Plaintiff filed a motion to defer briefing on the motion for
summary judgment until the U.S. Supreme Court decided a potentially dispositive issue in the
currently pending Manuel v. City of Joliet. (Dkt. 153.)
3.
On October 11, 2016, the Court denied Plaintiffs motion and gave Plaintiff until
November 1, 2016 to respond to the motion for summary judgment. (Dkt. 158.)
4.
Plaintiffs counsel has been diligently preparing a response to the motion for
summary judgment but is not able to file that response by the November 1, 2016 deadline.
5.
documents, and Plaintiff is in the process of reviewing those documents plus about twice that
amount of additional pages of her own documents prior to her production.
1
6.
Due to the nature the issues implicated by the motion for summary judgment
including whether equitable estoppel and/or equitable tolling apply Plaintiff must review the
documents in her possession and those produced by Defendants before responding to the motion.
7.
Plaintiff believes that a 21-day extension will give her sufficient time to review
the relevant documents and complete her response to the motion for summary judgment.
8.
Defendants filed three motions for extension of time to file their motion for
summary judgment, each of which Plaintiff did not oppose, and each of which the Court granted.
(Dkts. 130, 132, 136, 138, 145, 147.)
9.
Plaintiffs counsel contacted Defendants various counsel about the relief sought
in this Motion. Plaintiff has not been able to reach counsel for Defendant French. Counsel for
all other defendants do not object to the relief sought in this motion.
10.
11.
This motion is brought in the interest of justice and not for the purpose of delay.
WHEREFORE, Plaintiff respectfully requests an order: (1) extending the date by which
she must respond to Defendants motion for summary judgement (Dkt. 148) by 21 days until
November 22, 2016, and (2) granting such further relief as the Court deems just and proper.
Dated: November 1, 2016
Respectfully submitted,
s/ William J. Katt
William J. Katt