IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF

ILLINOIS

ART ASK AGENCY, )

)

Plaintiff, )

)

v. ) Case No. 1:20-cv-04608

)

STARRYMOON-LONG, et al. )

)

Defendants. ) Hon. Manish S. Shah

UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER

OR OTHERWISE PLEAD

COMES NOW Defendant starrymoon-long (hereinafter “starrymoon”), by and through counsel, 

and pursuant to Federal Rule of Civil Procedure 6(b) respectfully move this Court for an 

extension of time to answer or otherwise plead, showing the Court as follows:

1. Plaintiff filed its Complaint on July 10, 2020. [ECF No. 1]

2. The Court’s docket indicates that responsive pleadings were due October 1, 2020. 

3. The parties have been engaged in settlement discussions that are ongoing. The parties 

had hoped to complete their negotiations prior to the default deadline. However, they

require more time to conduct negotiations. 

4. The undersigned counsel sent an email to Michael Hierl, counsel for Plaintiff, on 

November 10, 2020 proposing an agreement for a short extension of time for 

starrymoon to answer or otherwise plead to permit the parties time to determine 

whether a settlement can be reached. Attorney Hierl responded and agreed. 

5. The undersigned represents other defendants in this case. On November 9, 2020, the 

parties agreed to an extension of time for those defendants through November 30, 

Case: 1:20-cv-04608 Document #: 55 Filed: 11/11/20 Page 1 of 3 PageID #:3125
2020. Those defendants filed an uncontested motion for extension of time which was 

granted by this Court on the same day. [ECF No. 50, 51] Defendant starrymoon 

respectfully requests a matching extension of time through November 30, 2020.

6. There is no intention by starrymoon in filing this motion for extension to negatively 

affect the entry of default against any other non-moving Defendants in this case. The 

relief sought in this motion is limited to starrymoon alone. 

7. Defendant starrymoon respectfully requests that the Court enter an Order granting 

this motion and extending the deadline for it to answer or otherwise plead through 

November 30, 2020, to permit the parties to determine whether settlement is possible, 

or whether starrymoon will file a responsive pleading by that date.

8. This extension of time is not being sought for the purpose of delay or frustration of 

the progress of this matter.

9. This extension will not unduly burden Plaintiff.

WHEREFORE, Defendant starrymoon-long respectfully requests that this Court grant

its Unopposed Motion for Extension of Time to Answer or Otherwise Plead and Ordering

Defendant starrymoon-long to answer or otherwise plead by November 30, 2020. 

Respectfully submitted,

/s/ Erin K. Russell

The Russell Firm, LLC 

833 W. Chicago Avenue, Suite 508

Chicago, IL 60642

T: 312-994-2424

F: 312-706-9766

erin@russellfirmip.com

Case: 1:20-cv-04608 Document #: 55 Filed: 11/11/20 Page 2 of 3 PageID #:3126
CERTIFICATE OF 

SERVICE

This is to certify that on November 11, 2020, this document was filed with the Court 

via the CM/ECF electronic filing system, thereby serving it upon all counsel of record.

/s/ Erin K. Russell

Case: 1:20-cv-04608 Document #: 55 Filed: 11/11/20 Page 3 of 3 PageID #:3127