Case: 1:13-cv-04924 Document #: 159 Filed: 11/01/16 Page 1 of 2 PageID #:692

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ANNABEL K. MELONGO

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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

PLAINTIFFS MOTION TO EXTEND TIME FOR PLAINTIFF TO RESPOND TO

DEFENDANTS MOTION FOR SUMMARY JUDGMENT
Plaintiff Annabel Melongo, through her attorneys, respectfully requests that the Court
extend the date by which she must respond to the Defendants motion for summary judgment by
21 days to November 22, 2016. In support of this Motion, she states as follows:
1.

Defendants filed their motion for summary judgment based on the statute of

limitations on September 7, 2016. (Dkt. 148.)

2.

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.

As of today, Defendants have produced, collectively, about 8,000 pages of

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.
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Case: 1:13-cv-04924 Document #: 159 Filed: 11/01/16 Page 2 of 2 PageID #:693

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.

This is the first request for an extension of time filed by Plaintiff.

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

Michael L. Shakman (mlshak@aol.com)

Daniel M. Feeney (dfeeney@millershakman.com)
William J. Katt (wkatt@millershakman.com)
Miller Shakman & Beem LLP
180 N. LaSalle St., Suite 3600
Chicago, Illinois 60601
Phone: (312) 263-2700
FAX: (312) 263-3270
Counsel for Plaintiff
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