UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ANDREW J. MAXWELL, not individually, 

but as Trustee for the estate of Eduardo Garcia 

and Julia Escamilla (nka Julia Garcia), et al.,

Plaintiffs,

vs.

WELLS FARGO BANK, N.A., 

Defendant.

)

)

)

)

)

)

)

)

)

)

Case No. 1:20-cv-02402

Judge Rebecca R. Pallmeyer

Judge Heather K. McShain

WELL FARGO’S MOTION TO EXTEND DISCOVERY DEADLINES

Defendant Wells Fargo Bank, N.A. (“Wells Fargo” or “the Bank”) hereby moves to extend 

the deadline for it to respond to Plaintiff Andrew J. Maxwell’s Requests for Admission (Set One), 

Requests for Production of Documents (Set One), and Interrogatories from July 12, 2021, to 

August 2, 2021. In support of this Motion, Wells Fargo states as follows: 

1. Plaintiff served Wells Fargo with voluminous First Sets of Interrogatories, 

Requests for Production of Documents, and Requests for Admission on June 12, 2021 (together, 

“Discovery Requests”). 

2. Specifically, Plaintiff served 58 Requests for Admission, 87 Requests for 

Production of Documents, and 25 Interrogatories.

3. Under the Federal Rules of Civil Procedure, responses to written discovery requests 

are to be served within thirty (30) days of receiving the requests. The current deadline for Wells 

Fargo’s discovery responses and objections is July 12, 2021. 

4. Counsel for Wells Fargo conferred with counsel for Plaintiff seeking a 30-day 

extension to respond to the Discovery Requests, citing, among other things, the need for additional 

Case: 1:20-cv-02402 Document #: 35 Filed: 06/30/21 Page 1 of 4 PageID #:346
time to gather the information across various lines of business within the Bank and to observe the 

Bank’s required protocols for approving and verifying responses to discovery.

5. Plaintiff did not consent to the extension. Counsel for Wells Fargo then shortened 

its request to a 21-day extension, but counsel for Plaintiff informed the undersigned that he did not 

consent to an extension of that length either. See Decl. of Angela A. Smedley, Ex. 1, filed 

concurrently herewith. 

6. The extension is requested not for purposes of delay, but to provide Wells Fargo 

sufficient time to evaluate the scope of, and gather information responsive to, Plaintiff’s Discovery 

Requests, which requires additional time beyond the July 12, 2021 deadline.

7. Wells Fargo has not previously sought to extend any discovery deadlines in this 

action pursuant to this Court’s May 13 Order.

WHEREFORE, for the foregoing reasons and having shown good cause, Defendant 

Wells Fargo Bank, N.A. respectfully requests that the Court grant its Motion to Extend Discovery 

Deadlines, such that it may serve its objections and responses to Plaintiff’s Discovery Requests up 

to and including August 2, 2021. 

Dated: June 30, 2021 Respectfully submitted,

 /s/ Angela A. Smedley

Angela A. Smedley (pro hac vice) 

Winston & Strawn LLP

200 Park Avenue

New York, NY 10166

Phone: 212-294-6700

Fax: 212-294-4700

ASmedley@winston.com

Shawn R. Obi

Winston & Strawn LLP

333 South Grand Avenue

Case: 1:20-cv-02402 Document #: 35 Filed: 06/30/21 Page 2 of 4 PageID #:347
Los Angeles, CA 90071

Phone: 213-615-1700

Fax: 213-615-1750

Sobi@winston.com

Counsel for Wells Fargo Bank, N.A.

Case: 1:20-cv-02402 Document #: 35 Filed: 06/30/21 Page 3 of 4 PageID #:348
CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the 30th day of June, 2021, the foregoing was 

filed electronically with the Clerk of the Court for the United States District Court for the Northern 

District of Illinois, and was served by operation of that Court’s electronic filing system, upon the 

following:

Rusty A. Payton

Payton Legal Group

20 North Clark Street, Suite 3300

Chicago, IL 60602

Phone: 773-682-5210

info@payton.legal

Salvador J. Lopez

Robson & Lopez, LLC

180 West Washington Street, Suite 700

Chicago, IL 60602

Phone: 312-525-2166

lopez@robsonlopez.com

Nicholas H. Wooten

Nick Wooten, LLC

5125 Burnt Pine Drive

Conway, AR 72034

Phone: 833-937-6389

nick@nickwooten.com

Attorneys for Plaintiff

 /s/ Angela A. Smedley

Case: 1:20-cv-02402 Document #: 35 Filed: 06/30/21 Page 4 of 4 PageID #:349