Motion To Extend Discovery printable pdf download

Motion To Extend Discovery

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

______________et al.,

)

Case No.: C

Plaintiff,

)

Judge

)

, et al.,

)

Defendants.

)

Jury Demanded

DEFENDANTS’ MOTION TO EXTEND DISCOVERY

Defendants XX (“Defendants”), by their undersigned attorneys, respectfully move this

Honorable Court, pursuant to Fed.R.Civ.P. 25(e) and 45 C.F.R. §§ 160 and 164, to extend the

discovery deadline sixty (60) days. In support thereof, Defendants state:

Plaintiff filed his complaint on February 12, 2009. The parties currently have a

discovery close date of April 13, 2010.

Defendants moved to substitute counsel on March 5, 2010. This court granted the

motion on March 18, 2010.

On March 22, 2010, Defense counsel diligently noticed six depositions for early

April. Plaintiffs first noticed defendants’ depositions on March 4, 2010 for late March and early

April.

On March 22, 2010, Plaintiff’s counsel, _____, notified defendants’ counsel that

plaintiff _________is currently incarcerated in the X Youth Center.

On March 22, 2010, defendants received the last set of outstanding interrogatory

answers from plaintiff ZYX. The parties have exchanged written discovery. However, there are

Motion To Extend Discovery