IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Case No.: 1:11-cv-07987 

 Hon. Gary Feinerman 

KAREN L. MANCZAK, on behalf of herself, 

and all others similarly situated, 

 Plaintiff, 

 v. 

GLOBAL CLIENT SOLUTIONS, LLC, an 

Oklahoma limited liability company, GLOBAL 

HOLDINGS, LLC, an Oklahoma limited 

liability company; and DOES 1-10, inclusive, 

 Defendants. 

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AGREED MOTION FOR EXTENSION OF TIME 

TO FILE RESPONSE TO COMPLAINT AND TO RESET STATUS HEARING 

Pursuant to Federal Rule of Civil Procedure 6(b)(1) and Local Rules 5.3 and 5.4, 

Defendants Global Client Solutions, LLC and Global Holdings, LLC (collectively, 

“Defendants”), in agreement with Plaintiff Karen Manczak, respectfully request an extension of 

time for Defendants to respond to Plaintiff’s Complaint until and including April 16, 2012, and 

to reset the Status Hearing scheduled for April 11, 2012. In support of this motion, Defendants 

state as follows: 

1. This Court may, for good cause as shown herein, grant an extension of time for 

Defendants’ to respond to Plaintiff’s Complaint. See Fed. R. Civ. P. 6(b)(1). 

2. Defendants’ Response to the Complaint is currently due on April 2, 2012. (Dkt. 

No. 38). 

3. Although Defendants and Plaintiff were originally engaged in discussions to agree 

upon terms for which the parties may submit this matter to arbitration, the parties are now 

engaging in settlement negotiations and are very close to reaching a settlement in this matter. 

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The parties hope to have this process completed in the next few days. Consequently, the parties 

have agreed that an extension of time –through and including April 16, 2012 – is necessary so 

that they can attempt to work out and finalize such terms without the need of engaging in further 

litigation. 

4. Counsel for Plaintiff and Defendants have discussed and agreed to the filing of 

this Motion and the requested extension of time. 

5. This is Defendants’ fifth (agreed) request for extension of time with respect to 

filing its response to Plaintiff’s Complaint. 

6. This Motion is filed in good faith and not for purposes of delay, as all parties 

agree that such an extension is necessary. 

7. The parties further request that, should the Court grant this extension, the Court 

also reset for a later date the Status Hearing that is currently scheduled for April 11, 2012 at 9:30 

a.m. (Dkt. No. 38). 

8. No party will be prejudiced by the granting of this Motion. 

 WHEREFORE, for the reasons set forth above, and pursuant to Fed. R. Civ. P 6(b)(1), 

Defendants respectfully request an extension of time to and including April 16, 2012 to respond 

to Plaintiff’s Complaint, and that the Court reset the Status Hearing scheduled for April 11, 2012. 

Dated: March 30, 2012 Respectfully Submitted, 

 GLOBAL CLIENT SOLUTIONS, LLC, and 

GLOBAL HOLDINGS, LLC 

 

/s/ Timothy A. Hudson 

Richard W. Epstein Timothy A. Hudson 

(Florida Bar No. 229091) TABET DIVITO & ROTHSTEIN, LLC 

Rebecca F. Bratter The Rookery Building 

(Florida Bar No. 685100) 209 South LaSalle Street, 7th Floor 

GREENSPOON MARDER, P.A. Chicago, Illinois 60604 

Trade Centre South, Suite 700 Telephone: (312) 762-9476 

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7423015 v1 

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100 West Cypress Creek Road Facsimile: (312) 762-9451 

Fort Lauderdale, Florida 33309 Attorney for Defendants

Telephone: (954) 491-1120 

Attorneys for Defendants

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