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IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS

Bureau of Consumer Financial )

Protection, ) Case No. 1:20-cv-04176

)

Plaintiff, )

)

vs. )

)

Townstone Financial, Inc. )

)

Defendant. )

DEFENDANT’S UNOPPOSED MOTION FOR LEAVE TO EXCEED PAGE LIMITS

RELATED TO THEIR MOTION TO DISMISS PLAINTIFF’S COMPLAINT

Defendant Townstone Financial, Inc. (“Townstone”), by counsel, pursuant to Local Rule 

7.1, moves this Court for an Order granting Townstone’s Unopposed Motion For Leave To Exceed 

Page Limits Related to Their Motion to Dismiss Plaintiff’s Complaint. In support of this motion, 

Townstone states as follows:

1. Plaintiff Bureau of Consumer Financial Protection (the “Bureau”) filed a complaint 

on July 15, 2020. The Complaint is 17 pages long and contains 58 paragraphs. It asserts federal

claims against Townstone and seeks declaratory relief and monetary damages against Townstone.

2. Pursuant to Fed. R. Civ. P. 12(b)(6), Townstone will move to dismiss all of the 

Bureau’s claims for failure to state a claim upon which relief can be granted. 

3. Local Rule 7.1 provides in relevant part that “[n]either a brief in support of or in 

opposition to any motion . . . shall exceed 15 pages without prior approval of the court. . . Any 

brief or objection that does not comply with this rule shall be filed subject to being stricken by the 

court. Id.

4. This case presents complex federal questions including the interpretation of the 

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applicable statutes and regulations as well as United States Constitutional issues. 

5. While the undersigned will make every effort to condense and streamline the 

arguments in support of the motion to dismiss, we respectfully submit that a memorandum in 

excess of 15 pages is necessary to fully present all the relevant facts and legal arguments that set 

out the bases for dismissal in this important case. 

6. The undersigned has conferred with opposing counsel regarding this proposed page 

extensions. Opposing counsel is not opposed to Townstone’s request.

WHEREFORE, based on the foregoing, Townstone respectfully requests:

A. That this Court allow Townstone to file its Memorandum in support of 

Motion to Dismiss in excess of fifteen (15) pages; and

B. That this Court provisionally accept the Memorandum in support of 

Motion to Dismiss filed by Townstone, which is in excess of fifteen (15) pages.

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Respectfully submitted,

/s/ Sean P. Burke

Sean P. Burke #6277203

E. Brenda Kpotufe # 34084-49

Mattingly Burke Cohen & Biederman LLP

155 E. Market St., Suite 400

Indianapolis, IN 46204

Sean.Burke@mbcblaw.com

Brenda.Kpotufe@mbcblaw.com

Attorneys for Defendant Townstone 

Financial, Inc. 

CERTIFICATE OF SERVICE

I hereby certify that on October 20, 2020 a copy of the foregoing was filed electronically. 

Service of this filing was also made by operation of the Court’s CM/ECF system:

Barry Reiferson

Vincent Herman 

Michael G. Salemi

Mary E. Olson

Bureau of Consumer Financial Protection

230 S. Dearborn St., Suite 1590

Chicago, IL 60604

And

1700 G Street, NW

Washington, DC 20552

/s/ Sean P. Burke______________

Sean P. Burke

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