IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

NICHOLAS MARTIN, ) 

 ) 

 Plaintiff, ) 

 ) 

v. ) 

 ) No. 12-cv-5147 

CELLCO PARTNERSHIP d/b/a VERIZON ) 

WIRELESS, VANTAGE SOURCING, LLC, ) Judge Ronald A. Guzman 

MIRACLE FINANCIAL, INC., and CREDIT ) 

BUREAU OF NAPA COUNTY, INC. d/b/a ) 

CHASE RECEIVABLES, ) 

 ) 

 Defendants. ) 

AGREED MOTION FOR ENTRY OF STIPULATION PURSUANT TO FEDERAL RULE 

OF CIVIL PROCEDURE 29

 Plaintiff Nicholas Martin (“Plaintiff”), pro se, and Defendants Cellco Partnership 

d/b/a Verizon Wireless (“Verizon”) through its attorneys Arnstein & Lehr, LLP, and 

Vantage Sourcing, LLC through its attorneys Gozdecki, Del Giudice, Americus & 

Farkas, LLP (collectively the “Parties”), move this Court for the entry of an order 

approving the attached stipulation pursuant to Federal Rule of Civil Procedure 29. In 

support thereof, the Parties state as follows: 

1. Plaintiff filed this action against Verizon, Vantage Sourcing, LLC, Miracle 

Financial, Inc. and Credit Bureau of Napa County, Inc. d/b/a Chase Receivables1

 on 

June 27, 2012, asserting violations of the Fair Debt Collection Practices Act and the 

Telephone Consumer Protection Act. (ECF No. 1.) 

 

1

 Plaintiff voluntarily dismissed Miracle Financial from this case on July 20, 2012. (ECF No. 13.) Credit 

Bureau of Napa County, Inc. has failed to answer or otherwise appear and was held in default on August 

7, 2012. (ECF No. 19.) 

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2. Verizon filed a motion to dismiss which this Court recently denied on October 

18, 2012. (ECF No. 30.) Vantage Sourcing, LLC has filed an Answer to the Complaint. 

(ECF No. 23.) 

3. On September 12, 2012, this Court entered the following discovery schedule: 

amended pleadings and joinder of parties to be completed by October 31, 2012, fact 

discovery to close on January 28, 2013, Plaintiff’s expert disclosures to be made by 

February 28, 2013, and Defendants’ expert disclosures to be made by April 25, 2013. 

(ECF No. 26.) 

4. On September 24, 2012, Plaintiff propounded written interrogatories, 

requests to produce documents and requests to admit facts on Verizon. Additionally, on 

September 26, 2012, Plaintiff propounded written interrogatories, requests to produce 

documents and requests to admit facts on Vantage Sourcing, LLC. 

5. On October 17, 2012, Defendant Vantage Sourcing, LLC propounded written 

interrogatories and requests to produce documents on Plaintiff and requests to produce 

documents on Defendant Verizon. 

6. Subsequent to the issuance of Plaintiff’s formal discovery, the Parties agreed 

to participate in a settlement conference in front of Magistrate Judge Sheila Finnegan in 

an attempt to resolve Plaintiff’s claims.2

 Accordingly, the Parties have agreed and 

stipulated that the deadline to answer all outstanding written discovery will be extended 

to a date thirty days after the settlement conference. 

7. Federal Rule of Civil Procedure 29 states: 

Unless the court orders otherwise, the parties may stipulate that: 

*** 

 

2

 A date has not yet been set for the settlement conference. The Parties are currently cooperating to 

choose a mutually agreeable date. 

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(b) other procedures governing or limiting discovery be 

modified—but a stipulation extending the time for any form of 

discovery must have court approval if it would interfere with the 

time set for completing discovery, for hearing a motion or for trial. 

8. Pursuant to Rule 29, the Parties stipulate that any and all responses to 

discovery served prior to the stipulation are extended to a date thirty days after the 

settlement conference is concluded. However, because such a stipulation may affect 

the overall discovery schedule entered by this Court on September 12, 2012, the 

Parties jointly, or one of them, may, at a later date, bring a motion to extend the 

discovery deadlines subject to this Court’s approval. Therefore, the Parties seek the 

Court’s approval for this stipulation. 

WHEREFORE, the Parties respectfully request that this Court enter an order 

approving the attached stipulation. 

 Respectfully submitted, 

/s/ Nicholas Martin

Nicholas Martin 

Pro Se 

PO Box 4030 

Chicago, IL 60654-4030 

(312) 725-9103 

Plaintiff 

/s/ Elizabeth Thompson

Elizabeth Thompson 

Hal Morris 

ARNSTEIN & LEHR LLP 

120 South Riverside Plaza 

Suite 1200 

Chicago, Illinois 60606-3910 

Phone: 312.876.7833 

Fax: 312.876.0288 

Counsel for Defendant 

Cellco Partnership 

/s/ Rick Del Giudice

Rick Del Giudice 

Dean Kalant 

GOZDECKI, DEL GIUDICE, 

AMERICUS & FARKAS LLP 

1 East Wacker 

Suite 1700 

Chicago, IL 60601 

Phone: 312-782-5010 

Fax: 312-782-4324 

Counsel for Defendant 

Vantage Sourcing, LLC 

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It is hereby stipulated and agreed by and between the Plaintiff, Nicholas Martin, 

pro se, and Defendants Cellco Partnership d/b/a Verizon Wireless through its attorneys 

Arnstein & Lehr, LLP and Vantage Sourcing, LLC through its attorneys Gozdecki, Del 

Giudice, Americus & Farkas, LLP, that pursuant to Federal Rule of Civil Procedure 29, 

any and all responses to discovery served prior to this stipulation are extended to a date 

thirty days after the settlement conference is concluded, to answer, object, or otherwise 

respond. 

/s/ Nicholas Martin

Nicholas Martin 

Pro Se 

PO Box 4030 

Chicago, IL 60654-4030 

(312) 725-9103 

Plaintiff 

/s/ Elizabeth Thompson

Elizabeth Thompson 

Hal Morris 

ARNSTEIN & LEHR LLP 

120 South Riverside Plaza 

Suite 1200 

Chicago, Illinois 60606-3910 

Phone: 312.876.7833 

Fax: 312.876.0288 

Counsel for Defendant 

Cellco Partnership 

/s/ Rick Del Giudice

Rick Del Giudice 

Dean Kalant 

GOZDECKI, DEL GIUDICE, 

AMERICUS & FARKAS LLP 

1 East Wacker 

Suite 1700 

Chicago, IL 60601 

Phone: 312-782-5010 

Fax: 312-782-4324 

Counsel for Defendant 

Vantage Sourcing, LLC 

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Certificate of Service

 The undersigned, an attorney, certifies that she caused the foregoing Agreed 

Motion for Entry of Stipulation Pursuant to Federal Rule of Civil Procedure 29 to be 

served by electronic mail, pursuant to the election to receive notice of filings through email, on Nicholas Martin, at n.m.martin@hotmail.com, and that she electronically filed 

the same with the Clerk of Court by using the CM/ECF system, which sent notification of 

such filing to all parties of record, on or before 5:00 p.m. on October 22, 2012. 

 /s/ Elizabeth A. Thompson

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