1:17-cv-01201-JES-JEH # 21 Page 1 of 3 E-FILED

Tuesday, 13 June, 2017 04:18:05 PM

Clerk, U.S. District Court, ILCD

IN THE UNITED STATES DISTRICT COURT FOR THE

CENTRAL DISTRICT OF ILLINOIS, PEORIA DIVISION

Curtis Lovelace, et al.,

Plaintiffs,

v. Case No. 17 cv 1201

The Honorable James E. Shadid

Det. Adam Gibson, et al.,

Defendants.

QUINCY DEFENDANTS MOTION FOR EXTENSION OF TIME

TO ANSWER OR OTHERWISE PLEAD TO PLAINTIFFS COMPLAINT

Defendants City of Quincy, Anjanette Biswell, Robert Copley, Dina Dreyer, Adam

Gibson, and John Summers (hereinafter Quincy Defendants), through their attorneys Thomas

G. DiCianni, Ellen K. Emery and Elizabeth K. Barton of Ancel, Glink, Diamond, Bush, DiCianni

& Krafthefer, P.C., seek an extension of time to answer or otherwise plead to Plaintiffs

Complaint. In support, Defendants state as follows:

1. Plaintiff filed the instant lawsuit on May 8, 2017, claiming he was wrongfully

arrested for the murder of his ex-wife. (Dkt. 1.) The Complaint contains 151 numbered

paragraphs and 11 separate counts for various federal and state causes of action. (Id.)

2. Plaintiff did not issue waivers of service to the Defendants.

3. The summonses were returned executed on May 24, 2017. (Dkts. 5-12.)

Therefore, Defendants answer to the Complaint is due June 13, 2017. (Id.)

3. The Quincy Defendants counsel filed their appearances on June 8, 2017, shortly

after they were assigned to represent Defendants in this matter. (Dkts. 13-15.) Therefore, defense

counsel is still investigating these extensive claims and their defenses in this case and will

require additional time to file the responsive pleading.

 1:17-cv-01201-JES-JEH # 21 Page 2 of 3

6. Quincy Defendants ask for an additional 28 days to answer or otherwise plead to

this complaint, up to and including July 11, 2017.

7. This motion is brought in good faith and will not significantly delay the

proceedings.

8. The undersigned counsel reached out to Plaintiffs counsel to determine whether

they had an objection to the instant Motion, but did not hear back from them as of this filing.

WHEREFORE, Quincy Defendants pray this Honorable Court grant them an extension of

time, up to and including July 11, 2017, to answer or otherwise plead to Plaintiffs Complaint.

Dated: June 13, 2017 ANCEL, GLINK, DIAMOND, BUSH,

DICIANNI & KRAFTHEFER, P.C.

By:
Elizabeth K. Barton, Atty No 6295848
One of the Attorneys for Defendants City
of Quincy, Biswell, Copley, Dreyer,
Gibson, and Summers

Thomas G. DiCianni / tdicianni@ancelglink.com

Ellen K. Emery / eemery@ancelglink.com
Elizabeth K. Barton / ebarton@ancelglink.com
ANCEL, GLINK, DIAMOND, BUSH, DiCIANNI, & KRAFTHEFER, P.C.
140 South Dearborn Street, 6th Floor
Chicago, Illinois 60603
Tel: 312.782.7606
Fax: 312.782.0943

2
 1:17-cv-01201-JES-JEH # 21 Page 3 of 3

CERTIFICATE OF SERVICE

I, Kathleen M. Turner, a non-attorney, state that I caused to be served a copy of the

aforementioned document (Quincy Defendants Motion for Extension of Time to Answer or
Otherwise Plead to Plaintiffs Complaint) upon (See Below) at his/ respective address via CM-
EMF E-Filing pursuant to General Orders on Electronic Case Filing Section XI(C) and UPS
Overnight Mail at 140 South Dearborn Street, Chicago, Illinois 60601 at or before June 13,
2017.

Jonathan I. Loevy / jon@loevy.com

Tara E. Thompson / tara@loevy.com
Loevy & Loevy
311 North Aberdeen Street, 3rd floor
Chicago, IL 60607
Attorney for Plaintiff

James Hansen / jhansen@srnm.com

Schmiedeskamp, Robertson, Neu & Mitchell LLP
525 Jersey Street
Quincy, IL 62301
Attorney for County of Adams, Gary Farha, and James Keller

Under penalties as provided by law pursuant to Federal Court Rule 28 USC Sec. 1746, I certify
that the statements set forth herein are true and correct.

/s/Kathleen M. Turner______________

Thomas G. DiCianni
Ellen K. Emery
Elizabeth K. Barton
ANCEL, GLINK, DIAMOND, BUSH, DICIANNI
& KRAFTHEFER, P.C.
140 South Dearborn Street, 6th Floor
Chicago, Illinois 60603
(312) 604-9150/(312) 782-0943 Fax
tdicianni@ancelglink.com
eemery@ancelglink.com
ebarton@ancelglink.com

4826-0122-6570, v. 1