IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

SOURCEBOOKS, INC.,

Plaintiff,

v.! ! ! ! ! ! CIVIL ACTION NO. 1:11-CV-07738

! ! ! ! ! ! The Honorable Amy J. St. Eve

ANITA CLENNEY,

Defendant and Third-Party Plaintiff,

v.

REED SMITH LLP and

DAVIS WRIGHT TREMAINE LLP,

Third-Party Defendants.

DEFENDANT/THIRD-PARTY PLAINTIFF’S RESPONSE IN 

OPPOSITION TO MOTION FOR SHORT EXTENSION OF TIME 

TO FILE MEMORANDUM OF LAW IN SUPPORT OF MOTION 

TO DISMISS COUNT III OF DEFENDANT’S COUNTERCLAIMS

AND DEFENDANT’S THIRD-PARTY COMPLAINT

Following an initial status hearing on December 12, 2011, the Court’s 

minute entry of the same date [Document # 16] established that Plaintiff 

Sourcebooks, Inc. and Third-Party Defendants Reed Smith LLP and Davis Wright 

Tremaine LLP would have until January 6, 2012 “to answer or otherwise plead to 

count 3 of the counterclaim and third-party complaint.”

Case: 1:11-cv-07738 Document #: 29 Filed: 01/09/12 Page 1 of 4 PageID #:174
On January 6, Reed Smith LLP filed a motion for an extension through 

January 11 within which to file a memorandum of law in support of the motion 

to dismiss Count III of the Defendant’s Counterclaim and her Third-Party 

Complaint [Document # 25].

The Court should deny Reed Smith’s motion as moot, however, because 

neither the Plaintiff nor the Third-Party Defendants filed any motion to dismiss 

Count III of the Counterclaim and the Third-Party Complaint on or before 

January 6, which was the deadline agreed to by the parties and established by the 

Court. As no motion was filed, there is no need for a supporting memorandum.

Neither should the Plaintiff or the Third-Party Defendants be permitted, at 

this point, to seek leave from the Court to file the motion to dismiss that was due 

by January 6. The Plaintiff and the Third-Party Defendants have adequate 

resources to ensure that they can comply with deadlines to which they have 

already agreed. 

Having failed to file their motion by the deadline set by the Court, the 

Plaintiff and Third-Party Defendants should be found to have waived their 

ability to do so, and the Court should deny the pending motion to file a 

memorandum in support as moot.

2

Case: 1:11-cv-07738 Document #: 29 Filed: 01/09/12 Page 2 of 4 PageID #:175
WHEREFORE, Defendant/Third-Party Plaintiff Anita Clenney prays that 

this Honorable Court deny Reed Smith LLP’s motion for an extension within 

which to file a memorandum of law in support of the motion to dismiss Count III 

of the Defendant’s Counterclaim and her Third-Party Complaint

!!!!!!!!! ANITA CLENNEY

! ! ! ! ! ! ! ! ! By Counsel

Adam M. Salzman! ! !

Adam M. Salzman (ARDC 6287280)

The Salzman Law Office

1111 South Boulevard

Oak Park, IL 60302

(708) 320-9888

Jeffrey V. Mehalic (Admitted pro hac vice)

Law Offices of Jeffrey V. Mehalic

2011 Quarrier Street

P. O. Box 11133

Charleston, WV 25339-1133

(304) 346-3462

Counsel for Defendant Anita Clenney

3

Case: 1:11-cv-07738 Document #: 29 Filed: 01/09/12 Page 3 of 4 PageID #:176
IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

SOURCEBOOKS, INC.,

Plaintiff,

v.! ! ! ! ! ! CIVIL ACTION NO. 1:11-CV-07738

! ! ! ! ! ! The Honorable Amy J. St. Eve

ANITA CLENNEY,

Defendant and Third-Party Plaintiff,

v.

REED SMITH LLP and

DAVIS WRIGHT TREMAINE LLP,

Third-Party Defendants.

CERTIFICATE OF SERVICE

I, Jeffrey V. Mehalic, hereby certify that on the 9th day of January, 2012, I 

electronically filed the foregoing with the Clerk of this Court using the CM/ECF 

system which will send notification of such filing to the following: 

Douglas A. Albritton, Esquire

Peter M. Stasiewicz, Esquire

Reed Smith LLP

10 South Wacker Drive, 40th Floor

Chicago, IL 60606-7507

!!!!!!! /s/ Jeffrey V. Mehalic! ! ! 

! ! ! ! ! ! ! Jeffrey V. Mehalic (Admitted pro hac vice)

4

Case: 1:11-cv-07738 Document #: 29 Filed: 01/09/12 Page 4 of 4 PageID #:177