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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

LISA CALVENTE, 

Plaintiff, 

v. 

SALMA GHANEM and DEPAUL 

UNIVERSITY, 

Defendants. 

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Case No.: 1:20-cv-03366 

Judge John Robert Blakey 

DEFENDANTS’ RESPONSE TO PLAINTIFF’S MOTION TO CONTINUE THE 

DEADLINE TO RESPOND TO DEFENDANTS’ COMBINED 

MOTION FOR SUMMARY JUDGMENT 

1. Defendants do not object to Plaintiff’s Motion to Continue Deadline to Response 

to the Defendants’ Combined Motion for Summary Judgment [Dkt No.56] (“Motion to Continue 

Deadline”),1 provided Defendants’ deadline for filing Reply papers is likewise continued as set 

forth below.2 

2. Given the two interceding holidays between Plaintiff’s Response papers and 

Defendants’ Reply papers, and DePaul’s winter recess from December 23, 2021 through January 

2, 2022, Defendants propose January 31, 2022 as the date for their Reply papers. 

3. Further, Defendants seek clarification on the Court’s November 17, 2021 Order. 

[Dkt. No. 42.] In granting Defendants’ Motion to Exceed Page Limits and Statements of Fact, this 

Court ordered that “Plaintiff may similarly exceed the page and statement of fact limits when she 

 

1

 Plaintiff argues merits and procedural issues in her Motion to Continue Deadline, at notes 1 and 2. Given 

that the Motion to Continue Deadline is not the appropriate vehicle for those arguments, Defendants will 

respond to those arguments in appropriate filings made by motion, or response or reply thereto as the case 

may be. 

2

 Plaintiff did not confer with Defendants regarding this Motion to Continue Deadline. 

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files her response and cross motion on 12/10/21.” Defendants understand this Order grants 

Plaintiff up to 30 pages in any Memorandum of Law in Support of her Cross Motion for Summary 

Judgment, if she files,3 and up to 160 paragraphs in her 56.1(a) Statement of Undisputed Material 

Facts. What remains unclear to Defendants is the number of Local Rule 56.1(b) Statements of 

Additional Undisputed Material Facts (which is usually limited to 40), Plaintiff may file. 

Clarification from the Court on the 56.1(b) filing would be helpful. 

Respectfully submitted, 

By: /s/ Anneliese Wermuth 

Attorney for Defendants, Salma Ghanem and 

DePaul University 

Anneliese Wermuth (#6270970) 

Nandini K. Sane 

Cozen O’Connor 

123 N. Wacker Drive, Ste. 1800 

Chicago, IL 60606 

Telephone: 312/474-7876 

Email: awermuth@cozen.com 

Email: nsane@cozen.com 

 

3

 In her Motion to Continue Deadline, Plaintiff only seeks an extension on her Response to Defendants’ 

Combined Motion for Summary Judgment. Defendants understand that as a result, any Cross Motion for 

Summary Judgment Plaintiff submitted by Plaintiff must still be filed by December 10, 2021, as set forth 

in the Court’s current Scheduling Order [Dkt. No. 30]. 

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CERTIFICATE OF SERVICE 

The undersigned attorney hereby certifies that on November 22, 2021 she electronically 

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

Illinois using the ECF system, which will send notification of such filing to the following counsel 

of record: 

Fitzgerald T. Bramwell 

Law Offices of Fitzgerald Bramwell 

77 West Wacker Drive, Suite 4500 

Chicago, IL 60601 

bramwell@fitzgeraldbramwell.com 

s/ Anneliese Wermuth 

Anneliese Wermuth 

Case: 1:20-cv-03366 Document #: 59 Filed: 11/22/21 Page 3 of 3 PageID #:1992