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Thank you Kevin, but I am not available to present an emergency motion
tomorrow. I will present a motion for leave to file instanter on
Monday.
Peter
----- Original Message -----
Sent: Thursday, February 24, 2011 1:38
PM
Subject: RE: Cynowa v. CSSS - Response to
Summary Judgment
Peter,
You and I cannot agree to change the
courtesy copy due date. The March 11 courtesy copy due date was set by
the Court to accommodate its schedule. My clients do not want to be
prejudiced by the Court not having sufficient time to study the papers and
consider the issues. In addition, I and my colleagues working on the
case have arranged our schedules to be able to file our reply by March 10 and
get courtesy copies to the Court on March 11, and we have other matters to
attend to in the days following those dates. If you had come to us
earlier we could have had this discussion so that you would have recognized
the limitations to the schedule that are clear to
us.
If you are not going to accept my offer
to give you an extension till tomorrow, then you should present an emergency
motion tomorrow morning to Judge Maras (to whom the motion was
assigned). She can let us know if pushing back the courtesy copy due
date works for her schedule and we both can have the opportunity to share our
concerns with her.
Kevin
From: Peter
V. Bustamante [mailto:pvbust@ameritech.net]
Sent: Thursday, February 24, 2011 12:47
PM
To: Kevin Duff
Cc: 'Theresa V. Johnson';
jmurray@rddlaw.net; 'Haytham Faraj'; kpritchard@rddlaw.net
Subject: Re: Cynowa v. CSSS - Response to
Summary Judgment
Thank you Kevin, but I suggest that if we come in on
an agreed order revising the due dates for your reply and for courtesy copies,
that will be acceptable to the court. The due date of courtesy copies is
3/11 the hearing is on 3/24, thirteen days later. I am sure that a couple of
days is not unreasonable and that the court will have plenty of time to fully
review our submissions.
----- Original Message -----
Sent:
Thursday, February 24, 2011 12:37 PM
Subject: RE:
Cynowa v. CSSS - Response to Summary
Judgment
Peter,
Because courtesy copies of all the
papers are due to the Court on March 11, which is one day after our reply is
due, any extension to your client cannot be matched with a corresponding
extension to my clients. There is no room for slippage in the schedule
because of that date and the approaching trial date. We also want to
make sure that the Court has sufficient time to consider all the papers
before the hearing on the motion. You will remember that the Court
moved the trial date in order to give you as much time as you needed to
respond to our summary judgment motion and you picked today as your due
date. Unfortunately, Theresa has a long-standing pattern of missing
deadlines in this case. Under the circumstances, the most I can do is
to agree to an extension until tomorrow. Please make sure to serve us
by email with your response and all accompanying
papers.
Kevin
From: Peter
V. Bustamante [mailto:pvbust@ameritech.net]
Sent: Thursday, February 24, 2011 12:22
PM
To: Kevin Duff
Cc: Theresa V. Johnson
Subject: Cynowa v. CSSS - Response to
Summary Judgment
Kevin, Theresa needs a couple more days to finish
the response to your motion. May we have until Monday, by agreement
and of course, extend your deadline by the same number of days? This
will not change the hearing date. Please let me know. Thank
you.
Peter V. Bustamante
150 North Michigan
Avenue
Suite 690
Chicago, Illinois 60601
(312) 346-2072
(312)
346-2074 facsimile
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