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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

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KAITLIN E. WALSH, on behalf of herself, and

all other plaintiffs known and unknown,

Plaintiff,

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“SIX FLAGS ENTERTAINMENT CORPORATION” 

D/B/A SIX FLAGS GREAT AMERICA,

Defendant.

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Civil Action No. 12-cv-05038

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JOINT MOTION FOR EXTENSION OF TIME

FOR PARTIES TO FILE AN AGREED MOTION FOR

PRELIMINARY APPROVAL OF CLASS SETTLEMENT

Plaintiff Kaitlin E. Walsh and Defendant Great America, LLC (D/B/A “Six Flags Great 

America”), sued as Six Flags Entertainment Corporation, D/B/A Six Flags Great America, 

(collectively the “Parties”) respectfully and jointly move this Court for entry of an Order 

granting it an extension of time up to, and including, August 23, 2013 by which the parties must 

file an agreed motion for preliminary approval of a class settlement. In support of this Motion, 

the Parties state:

1. This Motion is brought prior to the expiration of the time this Court ordered the 

Parties to file an agreed motion for preliminary approval of a class settlement. 

2. The current deadline for the Parties to file an agreed motion for preliminary 

approval of a class settlement is currently June 19, 2013.

3. The Parties jointly request this extension.

4. The Parties have requested one extension of time to file an agreed motion for 

preliminary approval of a class settlement, which was granted.

5. At the time of the Parties’ first request for an extension, the Parties had exchanged 

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extensive discovery for the purposes of settlement, including the number of putative class 

numbers and applicable hours worked, walking time and distances throughout the park, park 

procedures, numerous declarations, and initial damages models. The parties were actively 

working together in hopes of achieving settlement but required more time to process the 

information exchanged. 

6. Since that time, the Parties have continued to work together diligently and have 

made considerable progress in their negotiations. After considerable exchange of data and 

information and collective interaction, the Parties have tentatively agreed to a damages model 

and are working together to gather the remaining data necessary to calculate the damages 

according to the agreed model. 

7. The Parties continue to work together and believe they will be able to reach a 

settlement agreement if given additional time to gather the remaining data and finalize the 

remaining negotiations and calculations. The Parties believe they can obviate the need for 

considerable and expensive discovery and costly depositions if they are permitted to continue 

their settlement talks and joint calculations.

For all the reasons stated above, the Parties respectfully request that this Court enter an 

Order granting it an extension of time up to and including August 16, 2013, to file an agreed 

motion for preliminary approval of a class settlement.

Dated: June 17, 2013 Respectfully submitted,

By: /s/ John W. Billhorn By: /s/ Kevin M. Cloutier 

 John William Billhorn Kevin Cloutier 

 Billhorn Law Firm Catherine B. Diggins

 120 South State Street Sheppard, Mullin, Richter & Hampton LLP

 Suite 400 Three First National Plaza

 Chicago, IL 60603 70 West Madison Street, 48th Floor

 (312) 853-1450 Chicago, IL 60602

 jbillhorn@billhornlaw.com Tel: 312.499.6300

Fax: 312.499.6301

Attorneys for Plaintiff

James R. Hays

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Sheppard, Mullin, Richter & Hampton LLP

30 Rockefeller Plaza

New York, New York 10112

Telephone: (212) 653-8700

Facsimile: (212) 653-8701

jhays@sheppardmullin.com

Attorneys for Defendant

Case: 1:12-cv-05038 Document #: 24 Filed: 06/17/13 Page 3 of 3 PageID #:79