IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JULIA ROSSI, individually, and on behalf of 

all others similarly situated, 

Plaintiff, 

v. 

CLAIRE’S STORES, INC., CBI 

DISTRIBUTING CORP., 

Defendants.

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Case No. 1:20-cv-05090

Honorable Andrea R. Wood

UNOPPOSED MOTION TO EXTEND TIME TO ANSWER

OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT

Defendants Claire’s Stores, Inc. and CBI Distributing Corp. (collectively, “Claire’s”), 

respectfully move this Court to extend the deadline for Claire’s to answer or otherwise respond to 

Plaintiff’s Class Action Complaint (Doc. 4-1) (“Complaint”) by 28 days, up to and including 

October 2, 2020. In support of its unopposed motion, Claire’s states:

1. Plaintiff Julia Rossi (“Plaintiff”) filed her Complaint on July 31, 2020, in the Circuit 

Court of Cook County, Illinois. Claire’s was served with the summons and Complaint on August 

4, 2020.

2. On August 28, 2020, Claire’s removed this matter to the United States District 

Court for the Northern District of Illinois under the Class Action Fairness Act.

3. Per Federal Rule of Civil Procedure 81(c)(2), “A defendant who did not answer 

before removal must answer or present other defenses or objections under these rules within . . . 7 

days after the notice of removal is filed.” Fed. R. Civ. P. 81(c)(2).
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4. Claire’s did not answer or otherwise plead before this matter was removed to 

federal court, and therefore, the deadline for Claire’s to answer or otherwise respond to the 

Complaint currently is September 4, 2020.

5. In the Complaint, Plaintiff alleges that the personal information of “many thousands 

of individuals throughout the United States” was compromised during a cyberattack on Claire’s ecommerce platform earlier this year. (Compl., ¶¶ 17, 72-73.) Plaintiff asserts various common law 

and statutory claims under both Illinois and Pennsylvania laws and seeks certification of a 

nationwide class and a Pennsylvania sub-class. (Id., ¶¶ 72, 79-163.)

6. Given the complexity and nature of Plaintiff’s claims, Claire’s respectfully requests 

an additional twenty-eight days, up to and including October 2, 2020, to file its responsive 

pleading.

7. Claire’s conferred with Plaintiff’s counsel in good faith prior to filing this motion, 

and Plaintiff consents to Claire’s requested extension.

8. This is Claire’s first request for an extension of time.

9. Claire’s expressly reserves the right to raise all defenses it has to the Complaint.

WHEREFORE, Defendants Claire’s Stores, Inc. and CBI Distributing Corp. respectfully 

request that this Court extend the deadline to answer or otherwise respond to Plaintiff’s Complaint 

by 28 days, up to and including October 2, 2020.
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Dated: September 1, 2020 Respectfully submitted,

/s/ Maria A. Boelen

Gilbert S. Keteltas (pro hac vice forthcoming)

Carey S. Busen (pro hac vice forthcoming)

Baker & Hostetler LLP

1050 Connecticut Ave., NW

Suite 1100

Washington, DC 20036

gketeltas@bakerlaw.com 

cbusen@bakerlaw.com

Ph: 202.861.1500

Fax: 202.861.1783

John S. Letchinger

Maria A. Boelen

Baker & Hostetler LLP

One North Wacker Drive

Suite 4500

Chicago, IL 60606

jletchinger@bakerlaw.com 

mboelen@bakerlaw.com

Ph: 312.416.6200

Fax: 312.416.6201

Attorneys for Defendants
CERTIFICATE OF SERVICE

I, John Letchinger, certify that on the 1st day of September 2020, the foregoing Unopposed 

Motion to Extend Time to Answer or Otherwise Respond to Plaintiff’s Complaint, was served via 

email on the following:

Katrina Carroll

Kyle Shamberg

Carlson Lynch LLP

111 West Washington Street, Suite 1240

Chicago, IL 60602

kcarroll@carlsonlynch.com

kshamberg@carlsonlynch.com

Tina Wolfson

Henry Kelston

Bradley King

Ahdoot & Wolfson, PC

10728 Lindbrook Drive

Los Angeles, CA 90024

twolfson@ahdootwolfson.com

hkelston@ahdootwolfson.com

bking@ahdootwolfson.com

/s/ Maria A. Boelen

Maria A. Boelen