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Page 1 1:06-cv-01318-MMM-JAG
#4
Page 1 of 3
E-FILED
Friday, 16 February, 2007 12:15:20 PM
Clerk, U.S. District Court, ILCD
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF ILLINOIS
PEORIA DIVISION
DR. SHIPHRAH WILLIAMS-EVANS,
Plaintiff
v.
THE METHODIST MEDICAL CENTER
OF ILLINOIS,
Defendant.
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)
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No. 06-1318
ANSWER AND COUNTERCLAIM
JURY TRIAL DEMANDED
AGREED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE PLEAD
The Methodist Medical Center of Illinois (and d/b/a Methodist College of Nursing)
(“Methodist”), through its attorneys, Stephen D. Erf and Benjamin J. Hanauer of McDermott
Will & Emery LLP, with the agreement of Dr. Shiphrah Williams-Evans (“Plaintiff”), moves the
Court to extend the time to answer or otherwise plead to March 9, 2007 and in support of its
motion states as follows:
1.
On or about December 18, 2007, Plaintiff filed a pro se complaint and mailed
Methodist the forms to waive service of the summons, which Methodist timely completed and
returned.
2.
Prior to the filing of the complaint, an attorney for Plaintiff had solicited a
settlement proposal, which Methodist sent to the attorney on December 18, 2006. Methodist had
not heard a response from Plaintiff and planned to file a substantive response to the complaint on
February 16, 2007.
3.
No attorney has filed an appearance on behalf of Plaintiff in this matter.Page 2 1:06-cv-01318-MMM-JAG
4.
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Page 2 of 3
On February 16, 2007, Plaintiff contacted counsel for Methodist and initiated
discussion regarding the settlement proposal.
5.
Because it is not clear whether Plaintiff is represented by counsel in this matter
and because the attorney who had communicated on behalf of Plaintiff on the subject in
December 2006 is unavailable until late the week of February 19, 2007, counsel for Methodist
declined to engage in discussion of the settlement directly with Plaintiff and suggested that the
parties jointly seek an extension of time to respond to the Complaint to permit clarification of
whether Plaintiff is represented by counsel and to exhaust settlement discussions.
6.
Plaintiff agreed to the foregoing suggestion and agrees to the extension to
March 9, 2007 for Methodist to answer or otherwise plead.
7.
As a courtesy, a copy of this motion is being sent to the attorney who previously
communicated with Methodist on behalf of Plaintiff.
8.
This motion is not interposed for the purposes of unnecessary delay.
WHEREFORE, The Methodist Medical Center of Illinois respectfully requests the Court
to extend the time to answer or otherwise plead to March 9, 2007.
Dated: February 16, 2007
Respectfully submitted,
THE METHODIST MEDICAL CENTER OF
ILLINOIS
By:______/s/ Stephen D. Erf________________
One of Its Attorneys
Stephen D. Erf
Benjamin J. Hanauer
McDermott Will & Emery LLP
227 West Monroe Street
Chicago, Illinois 60606
Tel. 312.372.2000
Fax. 312.984.7700
-2-Page 3 1:06-cv-01318-MMM-JAG
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Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned hereby certifies under penalty of perjury under the laws of the State of
Illinois that, on February 16, 2007 he caused to be served on the person(s) listed below in the
manner shown Agreed Motion To Extend Time To Answer Or Otherwise Plead:
Dr. Shiphrah Williams-Evans
1021 S. Quincy
Green Bay, WI 54301
Mr. Donald R. Jackson
456 Fulton St.
Peoria, IL 61602
United States Mail, First Class
By Messenger
:
By Overnight Delivery
By Facsimile
By Electronic Mail upon counsel of record, who are filing users according to the Court’s
General Order On Electronic Filing
/s/ Stephen D. Erf
CHI99 4787589-1.054910.0085
-3-
PDF Page 1
PlainSite Cover Page
PDF Page 2
1:06-cv-01318-MMM-JAG
#4
Page 1 of 3
E-FILED
Friday, 16 February, 2007 12:15:20 PM
Clerk, U.S. District Court, ILCD
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF ILLINOIS
PEORIA DIVISION
DR. SHIPHRAH WILLIAMS-EVANS,
Plaintiff
v.
THE METHODIST MEDICAL CENTER
OF ILLINOIS,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
No. 06-1318
ANSWER AND COUNTERCLAIM
JURY TRIAL DEMANDED
AGREED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE PLEAD
The Methodist Medical Center of Illinois (and d/b/a Methodist College of Nursing)
(“Methodist”), through its attorneys, Stephen D. Erf and Benjamin J. Hanauer of McDermott
Will & Emery LLP, with the agreement of Dr. Shiphrah Williams-Evans (“Plaintiff”), moves the
Court to extend the time to answer or otherwise plead to March 9, 2007 and in support of its
motion states as follows:
1.
On or about December 18, 2007, Plaintiff filed a pro se complaint and mailed
Methodist the forms to waive service of the summons, which Methodist timely completed and
returned.
2.
Prior to the filing of the complaint, an attorney for Plaintiff had solicited a
settlement proposal, which Methodist sent to the attorney on December 18, 2006. Methodist had
not heard a response from Plaintiff and planned to file a substantive response to the complaint on
February 16, 2007.
3.
No attorney has filed an appearance on behalf of Plaintiff in this matter.
PDF Page 3
1:06-cv-01318-MMM-JAG
4.
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Page 2 of 3
On February 16, 2007, Plaintiff contacted counsel for Methodist and initiated
discussion regarding the settlement proposal.
5.
Because it is not clear whether Plaintiff is represented by counsel in this matter
and because the attorney who had communicated on behalf of Plaintiff on the subject in
December 2006 is unavailable until late the week of February 19, 2007, counsel for Methodist
declined to engage in discussion of the settlement directly with Plaintiff and suggested that the
parties jointly seek an extension of time to respond to the Complaint to permit clarification of
whether Plaintiff is represented by counsel and to exhaust settlement discussions.
6.
Plaintiff agreed to the foregoing suggestion and agrees to the extension to
March 9, 2007 for Methodist to answer or otherwise plead.
7.
As a courtesy, a copy of this motion is being sent to the attorney who previously
communicated with Methodist on behalf of Plaintiff.
8.
This motion is not interposed for the purposes of unnecessary delay.
WHEREFORE, The Methodist Medical Center of Illinois respectfully requests the Court
to extend the time to answer or otherwise plead to March 9, 2007.
Dated: February 16, 2007
Respectfully submitted,
THE METHODIST MEDICAL CENTER OF
ILLINOIS
By:______/s/ Stephen D. Erf________________
One of Its Attorneys
Stephen D. Erf
Benjamin J. Hanauer
McDermott Will & Emery LLP
227 West Monroe Street
Chicago, Illinois 60606
Tel. 312.372.2000
Fax. 312.984.7700
-2-
PDF Page 4
1:06-cv-01318-MMM-JAG
#4
Page 3 of 3
CERTIFICATE OF SERVICE
The undersigned hereby certifies under penalty of perjury under the laws of the State of
Illinois that, on February 16, 2007 he caused to be served on the person(s) listed below in the
manner shown Agreed Motion To Extend Time To Answer Or Otherwise Plead:
Dr. Shiphrah Williams-Evans
1021 S. Quincy
Green Bay, WI 54301
Mr. Donald R. Jackson
456 Fulton St.
Peoria, IL 61602
United States Mail, First Class
By Messenger
:
By Overnight Delivery
By Facsimile
By Electronic Mail upon counsel of record, who are filing users according to the Court’s
General Order On Electronic Filing
/s/ Stephen D. Erf
CHI99 4787589-1.054910.0085
-3-
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