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1:17-cv-01201-JES-JEH

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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.

Det. Adam Gibson, et al.,

Defendants.

Case No. 17 cv 1201

The Honorable James E. Shadid

QUINCY DEFENDANTSMOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE PLEAD TO PLAINTIFF’S 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 Plaintiff’s

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.

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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 Plaintiff’s 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 Plaintiff’s Complaint.

Dated: June 13, 2017

ANCEL, GLINK, DIAMOND, BUSH, DICIANNI & KRAFTHEFER, P.C.

By:

GLINK, DIAMOND, BUSH, DICIANNI & KRAFTHEFER, P.C. By: Elizabeth K. Barton, Atty No 6295848 One of

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, 6 th Floor Chicago, Illinois 60603 Tel: 312.782.7606 Fax: 312.782.0943

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CERTIFICATE OF SERVICE

I, Kathleen M. Turner, a non-attorney, state that I caused to be served a copy of the aforementioned document (Quincy DefendantsMotion for Extension of Time to Answer or Otherwise Plead to Plaintiff’s 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.

Thomas G. DiCianni Ellen K. Emery Elizabeth K. Barton

ANCEL, GLINK, DIAMOND, BUSH, DICIANNI & KRAFTHEFER, P.C.

140 South Dearborn Street, 6 th 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

/s/Kathleen M. Turner

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