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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

GLENN WILLIAMS, et al, )

)

Plaintiffs, )

) Case No: 20 CV 420

v. ) Magistrate Judge McShain

)

CITY OF CHICAGO, et al )

)

Defendants. )

PLAINITFFS’ MOTION FOR EXTENSION OF TIME TO FILE PLAINTIFFS MOTION FOR LEAVE TO 

FILE THIRD AMENDED COMPLAINT, INSTANTER

NOW COMES the named Plaintiffs, individually, and on behalf of all persons similarly 

situated, by and through their attorneys, ALLISON K. MUTH, and ROBERT A. HOLSTEIN of 

HOLSTEIN & MUTH, LLC, and respectfully moves this Court to extend the time for the parties to 

submit their motion for leave to file their Third Amended complaint, instanter. In support 

thereof, the Plaintiffs state as follows:

1.) That on September 22, 2023, this Honorable Court ordered that the Plaintiffs file 

their Motion for Leave to File their Third Amended Complaint by October 10, 2023.

2.) That Plaintiffs’ counsels have been diligently working on the motion for leave to file 

their third amended complaint, along with drafting of the third amended complaint. 

However, due to unforeseen health issues of both Attorney Muth and her 

immediate family, she has been unavailable to devote the adequate to her law 

practice that she previously expected to be able to do. Additionally, co-counsel for 

the Plaintiffs’, Robert Holstein, is preparing for major hip surgery under Dr. Stuvberg 

Case: 1:20-cv-00420 Document #: 240 Filed: 10/11/23 Page 1 of 3 PageID #:4097
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at Northwestern Hospital. The preparation has involved numerous doctor visits, and 

lab work. Therefore, Plaintiffs were unable to timely complete the drafting of the 

Motion for leave to File their Third Amended Complaint.

3.) Due to counsels’ litigation schedules in the next two weeks, counsels for the 

plaintiffs will need an additional two weeks to allocate the time to complete the 

drafting of the motion for leave to file the Third Amended complaint.

4.) The City has informed Plaintiffs that they will be opposing this motion and any 

motion for leave to file a third amended complaint. Plaintiffs feel that there will not 

be any prejudice to the defendants with the filing of their motion in the next 14 

days.

WHEREFORE, the Plaintiffs respectfully request that this Honorable Court grant the 

Plaintiffs an additional 14 days to submit the Motion for Leave to file the Plaintiffs’ Third 

Amended Complaint.

Date: the 11

th day of October, 2023 Respectfully Submitted,

__s/ Allison K. Muth_____

One of the Attorneys for Plaintiffs

Allison K. Muth

Robert A. Holstein

HOLSTEIN & MUTH, LLC

130 N. Garland Court, Suite 1906

Chicago, Illinois 60602

(312) 906-8000

Allison.muth.law@gmail.com

Hoslteinrobert3@gmail.com

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CERTIFICATE OF SERVICE

I, Allison K. Muth, attorney for named and putative class plaintiffs, hereby certify that on

Wednesday, October 11, 2023, I filed the above described document(s) on the CM/ECF system 

of the United States District Court for the Northern District of Illinois, which constates service of 

the same.

Respectfully Submitted,

 s/Allison K. Muth____

Case: 1:20-cv-00420 Document #: 240 Filed: 10/11/23 Page 3 of 3 PageID #:4099