1

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

TIMOTHY KENDRICK, )

)

Plaintiff, ) Case No. 20-CV-3871

)

vs. ) Honorable Manish S. Shah

)

CITY OF CHICAGO, and CHICAGO POLICE )

OFFICERS VINCENZO LUPO, Star #10401, )

JAMES HUNT, Star #1442 )

Defendants. )

DEFENDANT CITY OF CHICAGO’S UNOPPOSED MOTION FOR AN

EXTENSION OF TIME FOR ALL DEFENDANTS TO RESPOND TO COMPLAINT

Defendant City of Chicago, by and through its attorney, Mark A. Flessner, Corporation 

Counsel for the City of Chicago, pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), hereby 

moves this honorable Court to extend the time for all Defendants to file responsive pleading(s) to 

Plaintiff’s Complaint by twenty-nine (29) days, up to and including September 18, 2020. In support 

thereof, Defendant states as follows:

1. On July 1, 2020, Plaintiff filed a civil action alleging the Defendants violated his

Constitutional rights pursuant to 42 U.S.C. § 1983 during an alleged encounter with the Chicago 

Police Department on or about October 12, 2018. See ECF 1.

2. The deadline for Defendant City to file a responsive pleading is currently August 

24, 2020. See Fed. R. Civ. P. 12(a)(1)(A)(i). 

3. Upon information and belief, all Defendant Officers have been served. 

4. This motion is on behalf of Defendant City, but in the interests of efficiency, 

Defendant City requests this extension apply to all Defendants.

Case: 1:20-cv-03871 Document #: 16 Filed: 08/20/20 Page 1 of 3 PageID #:41
1

5. In order to properly prepare a responsive pleading, defense counsel require 

additional time to obtain and review relevant documents, meet with all Defendant Officers, and 

evaluate the most appropriate response to Plaintiff’s Complaint.

6. Federal Rule of Civil Procedure 6 provides that: “[w]hen an act may or must be 

done within a specified time, the court may, for good cause, extend the time . . . if a request is 

made, before the original time or its extension expires.” Fed. R. Civ. P. 6(b)(1)(A). Such an 

extension is warranted in this case. 

7. Defendant City respectfully requests a twenty-nine (29) day extension of time from 

August 20, 2020, to September 18, 2020, for all Defendants to file their answer or otherwise plead 

to Plaintiff’s Complaint.

8. This motion is brought in good faith and is not intended to cause undue delay. No 

prejudice will result to Plaintiff by the granting of this motion.

9. Counsel for Defendant City, Max C. Boose, contacted Plaintiff’s counsel on August 

13, 2020. Plaintiff does not oppose this motion.

Case: 1:20-cv-03871 Document #: 16 Filed: 08/20/20 Page 2 of 3 PageID #:42
1

WHEREFORE, Defendant City respectfully requests this Court to grant all Defendants an 

extension of time up to and including September 18, 2020, to answer or otherwise plead in response 

to Plaintiff’s Complaint.

Dated: August 20, 2020 Respectfully submitted,

MARK A. FLESSNER

Corporation Counsel of the City of Chicago

BY: /s/ Max C. Boose

Max C. Boose

Assistant Corporation Counsel 

Max Boose, Assistant Corporation Counsel

Elizabeth Hanford, Assistant Corporation Counsel

City of Chicago Department of Law 

Federal Civil Rights Litigation Division

30 N. LaSalle Street, Suite 900

Chicago, IL 60602

(312) 744-7684

Atty. No. 6320334

Max.Boose@cityofchicago.org

Attorneys for Defendant City of Chicago

CERTIFICATE OF SERVICE

I, Max C. Boose, an attorney, hereby certify that on August 20, 2020, I electronically filed 

the foregoing Defendant City of Chicago’s Unopposed Motion for an Extension of Time for 

All Defendants to Respond to Complaint, with the Clerk of the Court for the United States 

District Court for the Northern District of Illinois by using the CM/ECF system, serving a copy of 

the same on all parties and counsel of record. 

/s/ Max C. Boose

Max C. Boose

Assistant Corporation Counsel

Case: 1:20-cv-03871 Document #: 16 Filed: 08/20/20 Page 3 of 3 PageID #:43