APPELLANT’S FIRST MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY BRIEF.
NOW COMES LISA WILLIAMSON, APPELLANT, by and through her attorney HERMAN J. MARINO, who hereby submits her FIRST Request for Enlargement of Time to File her Reply Brief:
1. On January 24, 2012, Appellant filed her Brief, with paper copies submitted February 1, 2012.
2. On February 23, 2012, Appellee Curran timely filed its Response Brief.
3. Appellant’s Reply Brief is due March 8, 2012.
4. Appellant is scheduled to be out of town during the week of February 27, 2012, and will not return until Monday, March 5, 2012. Upon his return he has an arbitration scheduled for Wednesday, March 7, 2012 in Kane County Illinois and a deposition scheduled Thursday, March 8, 2012.
5. Filed herewith is the Affidavit of Appellant’s counsel summarizing the reason why he is requesting an additional ten (10) days to file the Reply Brief, through Monday, March 19, 2012.
6. Appellant has filed this Motion seven days in advance as required under Circuit Rule 26.
7. A copy of this motion was served upon counsel for Appellee by facsimile transmission before filing.
8. Appellant has two prior request for enlargement of time for filing its initial Brief and NO request for enlargement of time to file its Reply Brief.
9. Appellant’s counsel believes that no party will be prejudiced by granting Appellant additional time to file her Reply Brief, since oral argument has not been scheduled.
WHEREFORE, APPELLANT LISA WILLIAMSON, by and through her attorney HERMAN J. MARINO, respectfully request that this Honorable Court grant her an additional ten (10) days through and including Monday, March 19, 2012, to file her brief; and provide such further and other relief as is just in the premises.
LISA WILLIAMSON, Plaintiff
s/ Herman J. Marino
by: One of her attorneys