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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. ) Honorable LaShonda Hunt

)

CITY OF CHICAGO, et al )

)

Defendants. )

PLAINITFFS’ MOTION FOR EXTENSION OF TIME TO COMPLETE CLASS DISCOVERY

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 

complete class discovery. In support thereof, the Plaintiffs state as follows:

1.) That this Honorable Court ordered that class discovery be complete by June 26, 

2023.

2.) That during the time in which Honorable Court granted for the parties to conduct 

and complete class discovery, two major events have impacted Plaintiffs’ ability to timely 

conduct and/or review class discovery in this case. The first reason being that plaintiffs’ 

counsels, Kenneth Flaxman and Joel Flaxman, unexpectedly motioned this Honorable Court and 

were ultimately given leave to withdraw their appearances by this Honorable Court on June 15, 

2023. Prior to this event, Plaintiffs’ attorneys Holstein and Muth believed with good faith that 

the co-counsels for the Plaintiffs, Joel Flaxman and Kenneth Flaxman, were handling all matters 

relating to the class discovery. Counsels Muth and Holstein, as of this time, do not have any 

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information as to the status of the class discovery due to lack of communication with noth cocounsel and opposing counsels.

3.) That counsels for the plaintiff, Allison K. Muth and Robert Holstein, as of this time, 

do not have the status on the class discovery that may have been conducted by prior cocounsels. Plaintiffs’ counsels need additional time to review any discovery that may have been 

conducted, consult with opposing counsels, and/or need addional time to conduct additional 

class discovery. 

4.) Furthermore, this case was reassigned to the Honorable LaShonda Hunt on June 

15, 2023. As a result of this reassignment, Plaintiffs will be requesting that this Honorable 

Court conduct a review of the file and prior orders that were entered in this matter. 

5.) That counsel for the plaintiffs has contacted counsels for the defendant, City of 

Chicago, to inquire as to whether there was an objection to this filing for a motion for an 

extension of time to complete class discovery. As of the time of this filing, there has been no 

response from the City of Chicago.

6.) That attorney Muth is out of the country until July 18, 2023, therefore, plaintiifs will 

there need for additional time to conduct, propound, and complete class discovery.

7.) There will not be any prejudice to the additional extension of time to conduct and 

complete class discovery to either party.

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

Plaintiffs a minimum of an additional 90 days to conduct and complete class discovery, and any 

other relief that this honorable Court finds just.

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Date: the 26th day of June, 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

CERTIFICATE OF SERVICE

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

Monday, June 26, 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____

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