IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

Selene Danielle Arriaga, 

Plaintiff,

v. Case No: 20-cv-4498

Thomas J. Dart, Sheriff of Cook County, 

Illinois; The Northeast Regional Commuter 

Railroad Corporation d/b/a Metra; Cook 

County, Illinois; Marie Rangel, Joseph Perez; 

Paul Riggio; David Cammack; Theodore 

Stajura; and Timothy O’Donnell,

Defendants.

The Honorable Judge Virginia Kendall

Magistrate Judge Maria Valdez

PLAINTIFF’S MOTION FOR LEAVE TO FILE RESPONSE TO SHERIFF 

DEFENDANTS’ MOTION TO DISMISS INSTANTER (Dkt. 30)

NOW COMES, SELENE DANIELLE ARRIAGA (“Plaintiff”), by and through 

undersigned counsel, and moves this Honorable Court for a second extension of time up to and 

including November 24, 2020 to respond to the Sheriff Defendants’ Motion to Dismiss (Dkt. 30) 

for the following reasons, and/or to file the Response Instanter on November 24, 2020. 

1. Plaintiff’s counsel contacted all defense counsel by email on November 24, 2020, and 

will confirm with the Court when he hears back.

2. This is Plaintiff’s Second Motion for Extension of Time or Motion for Leave to File 

Instanter.

3. Plaintiff requires an additional day to respond to the Motion due to a number of other

obligations pending, including:

a. Motion to Dismiss Response due in Macklin v. IDOT, et al., 2020 CH 04096 that

is due on November 20, 2020.

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b. Deposition in Strickland v. Dart, 19-cv-02621, on November 16, 2020 at 12:00

p.m.

c. Deposition in Leibas, et al. v. Dart, et al., 19-cv-07592, on November 16, 2020 at

10:30 a.m. and in the afternoon (undersigned is having cocounsel cover this

during the Strickland deposition).

d. Deposition in Leibas, et al. v. Dart, et al., 19-cv-07592, on November 19, 2020 at

10:30 a.m.

e. Deposition in Leibas, et al. v. Dart, et al., 19-cv-07592, on November 23, 2020 at

10:30 a.m.

f. The above-noted depositions took a substantial amount of preparation time and 

also took up most of the prior week and all day on November 23, 2020 until after 

6 p.m.

5. In addition, the Response contains a number of issues that are research-intensive into

equal protection and statutes of limitations, and took a lot of research time to properly 

respond.

6. This Motion is not for dilatory purposes but to ensure a proper and fulsome response to

the Motion to Dismiss is filed.

Plaintiff respectfully requests leave to file the accompanying Response Instanter on 

November 24, 2020.

CONCLUSION 

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For the foregoing reasons, Plaintiff respectfully requests that this Court grant this Motion 

and allow her to file her Response to the Sheriff Defendants’ Motion to Dismiss (Dkt. 30) 

Instanter on November 24, 2020. 

Respectfully submitted,

/s/ Cass T. Casper

_____________________________

Cass T. Casper, Esq.

DISPARTI LAW GROUP, P.A.

121 West Wacker Drive, Suite 2300

Chicago, Illinois 60601

Phone: (312) 506-5511 ext. 331

Email: ccasper@dispartilaw.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that he served the foregoing document on all counsel of 

record via this Court’s CM/ECF filing system on November 24, 2020, and that such counsels are 

registered e-filers. 

/s/ Cass T. Casper

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