DOCUMENT STRICKEN: RESPONSE to Motion re [5] MOTION to Dismiss Response to Motion to Dismiss filed by Defendant Methodist Medical Center of Illinois. (Erf, Stephen) Modified on 3/9/2007 (CL, ilcd).
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Page 1 1:06-cv-01318-MMM-JAG
#6
Page 1 of 3
E-FILED
Thursday, 08 March, 2007 02:55:46 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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No. 06-1318
RESPONSE OF
THE METHODIST MEDICAL CENTER OF ILLINOIS
TO PLAINTIFF’S MOTION TO DISMISS
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, states the following as its response to the motion of Dr. Shiphrah WilliamsEvans (“Plaintiff”) to dismiss her Complaint.
1.
Methodist does not oppose Plaintiff’s motion to dismiss her Complaint and action.
2.
If the Court declines to dismiss Plaintiff’s Complaint and action, Methodist
requests leave to file its response to Plaintiff’s Complaint within seven (7) days
following the docketing of the Court’s order. In the meantime, Methodist will
defer filing its responsive pleading pursuant to Plaintiff’s request.Page 2 1:06-cv-01318-MMM-JAG
#6
Dated: March 8, 2007
Page 2 of 3
Respectfully submitted,
THE METHODIST MEDICAL CENTER OF
ILLINOIS
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
By:________________________________
One of Its Attorneys
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#6
Page 3 of 3
CERTIFICATE OF SERVICE
Steven D. Erf, an attorney, states that he caused Response of The Methodist Medical
Center of Illinois to Plaintiff’s Motion to Dismiss to be served by First Class Mail on March 8,
2007 to:
Dr. Shiphrah Williams-Evans
1021 South Quincy
Green Bay, Wisconsin 54301
_s/s Steven D. Erf___________________
CHI99 4796382-1.054910.0085
-3-
PDF Page 1
PlainSite Cover Page
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1:06-cv-01318-MMM-JAG
#6
Page 1 of 3
E-FILED
Thursday, 08 March, 2007 02:55:46 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
RESPONSE OF
THE METHODIST MEDICAL CENTER OF ILLINOIS
TO PLAINTIFF’S MOTION TO DISMISS
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, states the following as its response to the motion of Dr. Shiphrah WilliamsEvans (“Plaintiff”) to dismiss her Complaint.
1.
Methodist does not oppose Plaintiff’s motion to dismiss her Complaint and action.
2.
If the Court declines to dismiss Plaintiff’s Complaint and action, Methodist
requests leave to file its response to Plaintiff’s Complaint within seven (7) days
following the docketing of the Court’s order. In the meantime, Methodist will
defer filing its responsive pleading pursuant to Plaintiff’s request.
PDF Page 3
1:06-cv-01318-MMM-JAG
#6
Dated: March 8, 2007
Page 2 of 3
Respectfully submitted,
THE METHODIST MEDICAL CENTER OF
ILLINOIS
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
By:________________________________
One of Its Attorneys
-2-
PDF Page 4
1:06-cv-01318-MMM-JAG
#6
Page 3 of 3
CERTIFICATE OF SERVICE
Steven D. Erf, an attorney, states that he caused Response of The Methodist Medical
Center of Illinois to Plaintiff’s Motion to Dismiss to be served by First Class Mail on March 8,
2007 to:
Dr. Shiphrah Williams-Evans
1021 South Quincy
Green Bay, Wisconsin 54301
_s/s Steven D. Erf___________________
CHI99 4796382-1.054910.0085
-3-
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