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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.
Let me know.
Peter
----- 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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