Motion To Extend Discovery Page 2
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2between ten and fifteen depositions to be taken in this case including plaintiff ABC’s deposition
in Joliet, Illinois. As of today, two plaintiff’s depositions have been confirmed.
6.
Plaintiff’s counsel, XX, has communicated that she objects to an extension for
discovery because the case has taken too long to progress.
7.
This is Defendants’ first request for an extension of discovery.
WHEREFORE, for reasons set forth above, Defendants respectfully request this
Honorable Court extend discovery sixty (60) days.
Respectfully Submitted,
s/_________________
Signature Block
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