Mann v. National Asset Management Enterprises, Inc. et al Document 14: Motion for Leave to File

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1:04-cv-01304-JBM-JAG # 14 Page 1 of 2 E-FILED Monday, 07 February, 2005 03:11:02 PM Clerk, U.S. District Court, ILCD IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION KAY F. MANN, Plaintiff, v.

NATIONAL ASSET MANAGEMENT
ENTERPRISES, INC.; LAW OFFICES OF
GERALD E. MOORE & ASSOCIATES, P.C.,

Defendants.

04 C 1304

Judge McDade Magistrate Judge Gorman PLAINTIFF’S MOTION FOR LEAVE TO SUBMIT ADDITIONAL AUTHORITY IN FURTHER OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS NOW COMES plaintiff, who respectfully requests that this Court enter an order permitting her to submit the opinion on defendants’ motion to dismiss in Longo v. Gerald E. Moore & Assoc., Case No. 04 C 5759 (N.D.Ill), in further opposition to defendants’ motion to dismiss in this case.

In support of this motion, plaintiff states:

1.

This is a Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. case, in which there is a fully-briefed motion to dismiss pending. Judge Lefkow in the Northern District of Illinois denied a substantially identical motion on February 3, 2005 in Longo v. Gerald E. Moore & Assoc., Case No. 04 C 5759 (N.D.Ill). That opinion is attached as Exhibit A. The opinion was not cited in plaintiff’s original response brief because it was not available until February 3, 2005.

WHEREFORE, plaintiff respectfully requests that this Court permit her to submit the opinion on defendants’ motion to dismiss in Longo v. Gerald E. Moore & Assoc., Case No. 04 C 5759 (N.D.Ill), in further opposition to defendants’ motion to dismiss in this case.

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1:04-cv-01304-JBM-JAG

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Respectfully submitted,

s/ Alexander H. Burke Alexander H. Burke Daniel A. Edelman Cathleen M. Combs James O. Latturner Alexander H. Burke EDELMAN, COMBS, LATTURNER & GOODWIN, LLC 120 S. LaSalle Street, 18th Floor Chicago, IL 60603

(312) 739-4200

(312) 917-0379 (FAX)

CERTIFICATE OF SERVICE

I, Alexander H. Burke, hereby certify that, on February 7, 2005, I caused to be served a true and correct copy of the attached document via electronic filing to the following persons:

David L. Hartsell Paul C .Ziebert McGuireWoods, LLP 77 W. Wacker Drive, Suite 4100 312-750-5758 312-920-6190 fax

s/ Alexander H. Burke Alexander H. Burke J:\Case\national-mann12.365\pleading\Add'l Authority Longo\add'l authority.wpd