IN THE UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

DAVID EVANS III, et al., )

)

Plaintiffs, )

) Case No. 20 cv 2453

v. )

) The Honorable Rebecca R. Pallmeyer

THOMAS J. DART, et al., )

)

Defendants. )

UNOPPOSED PLAINTIFF’S SECOND MOTION FOR AN EXTENSION OF TIME TO 

FILE REPLY TO DEFENDANTS’ RESPONSE (DKT. 90) TO PLAINTIFF’S MOTION 

TO CONDITIONALLY CERTIFY CLASS

NOW COME Plaintiffs, by and through their undersigned counsel, Cass T. Casper, Esq., 

DISPARTI LAW GROUP, P.A., and move this Honorable Court for an extension of time to file 

their Reply to Defendants’ Response to Plaintiff’s Motion to Conditionally Certify Class (Dkt. 

90) to and including January 21, 2022 for the following reasons.

1. This Motion is unopposed.

2. This is Plaintiff’s Second Motion for an extension of time to file their Reply.

3. First, Plaintiff Joseph Tinoco passed away on the evening/overnight of January 12, 2022 

and Plaintiff’s counsel is assisting the family in dealing with the situation, as well as assessing 

how this affects his position in the instant case.

4. Second, Plaintiff’s counsel has a large number of litigation responsibilities necessitating

this extension and requests an extension to and including January 21, 2022 to file this Reply for 

the following reasons:

a. Plaintiffs’ counsel must file three amended complaints in Jaimie Mireles v. Dart,

Case: 1:20-cv-02453 Document #: 93 Filed: 01/13/22 Page 1 of 3 PageID #:1364
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Joel Mireles v. Dart, and Squeo v. Dart before Judge Neil Cohen by January 14, 2022, which 

was ordered by him to be done by that date on January 12, 2022, just two days and this obviously 

is a priority project for that reason.

b. Plaintiff had oral argument before Judge Sophia Hall in Goral, et al. v. Dart, et 

al., 17 CH 15546 on January 13, 2022.

c. Plaintiff has a Reply to a Motion to Consolidate due in Denham v. Dart, 2020 L 

10893 and Dart v. Denham, 2018 L 10207 on January 14, 2022, with a hearing date of January 

23, 2022, necessitating this getting done immediately so the Court may have everything ample in 

advance of the hearing date.

d. Plaintiff has discovery due to Metra Defendants in Arriaga v. Metra, et al., on 

January 14, 2022 that also need to be produced by that date.

5. This Motion is not for dilatory purposes, but to ensure a fulsome and accurate Reply.

CONCLUSION

For the foregoing reasons, Plaintiffs respectfully request that this Honorable Court grant 

this Motion, and extend their time to file their Reply to Defendants’ Response in Opposition to 

Plaintiff’s Motion to Conditionally Certify a Class (Dkt. 90) no later than January 21, 2022.

Electronically filed: January 13, 2022

Respectfully submitted,

By: /s/ Cass T. Casper

__________________________________

One of Plaintiffs’ Attorney

Cass T. Casper, Esq.

DISPARTI LAW GROUP, P.A. 

121 West Wacker Drive, Suite 2300

Chicago, Illinois 60601

P: (312) 506-5511 ext. 331

E: ccasper@dispartilaw.com

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CERTIFICATE OF SERVICE

The undersigned attorney hereby certifies that on January 13, 2022, he caused to be 

served the foregoing document on all counsel of record via this Court’s CM/ECF filing system, 

and that all such counsels are registered e-filers.

/s/ Cass T. Casper

____________________________________

Case: 1:20-cv-02453 Document #: 93 Filed: 01/13/22 Page 3 of 3 PageID #:1366