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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

MARIA F. ASTUDILLO, ) 

formerly known as MARIA F. MANCILLA, ) 

 ) 

 Plaintiff, ) 12-CV-5072 

 ) 

 vs. ) Judge John F. Grady 

 ) Magistrate Daniel G. Martin 

JEROLD KAPLAN LAW OFFICE, PC; ) 

and MIDLAND FUNDING LLC; ) 

 ) 

 Defendants. ) 

 

AGREED MOTION FOR AN EXTENSION 

 OF THE DISCOVERY CUT-OFF DEADLINE

 Plaintiff Maria F. Astudillo, f/k/a Maria F. Mancilla, by and through her counsel, 

and defendants Jerold Kaplan Law Office, PC and Midland Funding, LLC, by and through their 

counsel, hereby request that this Court extend the discovery cut-off deadline by ninety-one days. 

 In support of their motion, the parties state as follows: 

1. Plaintiff sued defendants for violation of the Fair Debt Collection 

Practices Act and the Illinois Consumer Fraud Act, wrongful garnishment and common law 

fraud after defendants garnished her wages for the debt of another consumer with the same first 

name and a similar social security number. 

2. On December 18, 2012, this Court set a March 15, 2013 discovery cut-off 

deadline. 

3. The parties continue to discuss settlement, and on December 21, 2012, 

Judge Grady referred this case to Magistrate Judge Martin for a settlement conference. 
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4. A settlement conference for this case has been scheduled before 

Magistrate Judge Martin on April 16, 2013. 

5. The parties requested a settlement conference before the current discovery 

cut-off deadline but Magistrate Judge Martin was not available to conduct a settlement 

conference before the current discovery cut-off deadline. The earliest settlement conference date 

available was April 16, 2013. 

6. In light of the date of this settlement conference, the parties request that 

the Court extend the current discovery cut-off date of March 15, 2013 until approximately sixty 

days after the settlement conference has been completed, up through and including June 14, 

2013. 

7. The parties therefore request that this Court extend the discovery cut-off 

date by ninety-one days. 

8. The parties will continue to work to settle the case prior to the settlement 

conference on April 16, 2013. 

9. The parties do not bring this motion to unnecessarily delay proceedings. 

 WHEREFORE, the parties request that this Court extend the March 15, 2013 

discovery cut-off date by ninety-one days to June 14, 2013. 

 s/Tara L. Goodwin 

 Tara L. Goodwin 

Daniel A. Edelman 

Tara L. Goodwin 

Rupali R. Shah 

EDELMAN, COMBS LATTURNER & GOODWIN, LLC 

120 S. LaSalle Street, 18th floor 

Chicago, Illinois 60603 

(312) 739-4200 

(312) 419-0379 (FAX) 
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 s/Katherine H. Tresley 

 Katherine H. Tresley 

David M. Schultz 

Katherine H. Tresley 

Hinshaw & Culbertson, LLP 

222 North LaSalle Street, Suite 300 

Chicago, IL 60601 
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CERTIFICATE OF SERVICE 

 

 I, Tara L. Goodwin, hereby certify that on January 11, 2013, I caused to be electronically 

filed the foregoing with the Clerk of the Court using the CM/ECF system, which will send notice 

to the following: 

David M. Schultz 

Katherine H. Tresley 

Hinshaw & Culbertson, LLP 

222 North LaSalle Street, Suite 300 

Chicago, IL 60601 

dschultz@hinshawlaw.com 

ktresley@hinshawlaw.com 

 

 s/Tara L. Goodwin 

 Tara L. Goodwin 

Tara L. Goodwin 

Rupali R. Shah 

EDELMAN, COMBS, LATTURNER & GOODWIN, LLC 

120 South LaSalle Street, Suite 1800 

Chicago, Illinois 60603 

(312) 739-4200 

(312) 419-0379 (FAX)