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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 SUBMIT JOINT STATUS REPORT

(unopposed)

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 joint status report. In support thereof, the Plaintiffs state as follows:

1.) That this case was referred to Magistrate Judge McShain on July 28, 2023.

2.) That this Honorable Court ordered that the parties submit their joint status report to 

by August 18, 2023.

3.) That counsels for the parties discussed the status report on August 15, 2023, in 

which attorneys discussed their positions as to the ongoing litigation in this matter. 

Plaintiff will be asking for leave to file an amended complaint, in which the 

defendant will object. The parties agree that they will need to tender a briefing 

schedule as to Plaintiff’s pending motion for leave to file an amended complaint.

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4.) That lead attorney for the Plaintiffs, Robert Holstein, suffered injury from a fall on 

August, 15, 2023, and co-counsel for the plaintiffs, Allison Muth, fell ill on Augst 16, 

2023. Due to the time in which Plaintiffs’ attorney were tending to their health, they 

have become behind in their ability to timely draft the joint status report, due to 

other pending litigation in their practice. 

5.) Furthermore, Plaintiffs’ attorneys are in need of more time to determine the issues 

that may be included in their proposed amended complaint, and to determine the 

adequate time needed to brief their the motion.

6.) The City does not oppose Plaintiffs’ Motion for Extension based on the reasons 

provided by counsel, and the Court’s expressed direction that a Joint Status Report 

must be filed. Otherwise, the City was prepared to file its own report.

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 an additional 7 days to submit the parties joint status report.

Date: the 18th day of August, 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

Case: 1:20-cv-00420 Document #: 231 Filed: 08/18/23 Page 2 of 3 PageID #:4070
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(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

Friday, August 18, 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 #: 231 Filed: 08/18/23 Page 3 of 3 PageID #:4071