Replies to post #173 on My Back Porch

[jhnvtjll]

I'm not sure.

[jhnvtjll]

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
CAR CHARGING GROUP, INC. a Nevada )
Corporation and 350 HOLDINGS, LLC, )
a Florida limited liability company )
)
Plaintiffs, ) Case No. 13 CV 03124
)
v. ) Hon. Elaine E. Bucklo )
JNS HOLDING CORPORATION, )
a Delaware Corporation, and )
JNS POWER & CONTROL )
SYSTEMS, INC., an Illinois Corporation )
)
Defendants. )
DEFENDANTS’ MOTION TO EXTEND TIME TO RESPOND TO THE COMPLAINT
Defendants, JNS Holding Corporation and JNS Power & Control Systems, Inc. (collectively, “JNS”), by their attorneys, hereby move this Court for entry of an order extending the deadline by seven (7) days for JNS to file a pleading responsive to Plaintiffs Car Charging Group, Inc. and 350 Holdings, L.L.C.’s (collectively, “Plaintiffs”) Complaint to and until May 30, 2013. In support of this motion, JNS states as follows:
1. On April 25, 2013, Plaintiffs filed their Complaint (Dkt.1).
2. JNS Power & Control Systems, Inc. received service of the summons and Complaint on May 2, 2013.
3. JNS Holding Corporation received service of the summons and Complaint on May 7, 2013.
4. Accordingly, JNS Power & Control Systems, Inc.’s pleading responsive to the Complaint is due May 23, 2013, and JNS Holding Corporation’s pleading responsive to the Complaint is due May 28, 2013.
Case: 1:13-cv-03124 Document #: 9 Filed: 05/14/13 Page 1 of 2 PageID #:26

5. JNS seeks an extension of the deadline to file a responsive pleading to the Complaint on behalf of both Defendants, until and to May 30, 2013.
6. JNS has not previously sought an extension to respond to the Complaint and no prejudice will result from the requested extension.
WHEREFORE, JNS respectfully requests that the Court enter an order extending the deadline for it to respond to the Complaint to May 30, 2013.
Respectfully submitted,
JNS HOLDING CORPORATION AND
JNS POWER & CONTROL SYSTEMS, INC.
By: s/ Evan J. Haim
One of Their Attorneys
Patrick E. Deady
Kelly McCloskey Cherf
Evan J. Haim
Hogan Marren, Ltd.
321 N. Clark Street, Suite 1301
Chicago, IL 60654
312-946-1800
Case: 1:13-cv-03124 Document #: 9 Filed: 05/14/13 Page 2 of 2 PageID #:27

[jhnvtjll]

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
CAR CHARGING GROUP, INC. a Nevada )
Corporation and 350 HOLDINGS, LLC, )
a Florida limited liability company )
)
Plaintiffs, ) Case No. 13 CV 03124
)
v. ) Hon. Elaine E. Bucklo )
JNS HOLDING CORPORATION, )
a Delaware Corporation, and )
JNS POWER & CONTROL )
SYSTEMS, INC., an Illinois Corporation )
)
Defendants. )
NOTICE OF MOTION
To: See Attached Service List
PLEASE TAKE NOTICE that on May 20, 2013 at 9:30 a.m., or as soon thereafter as counsel may be heard, I shall appear before the Honorable Elaine E. Bucklo in Courtroom 1441 at the Dirksen Federal Building located at 219 S. Dearborn Street in Chicago, Illinois, and then and there present Defendants’ Motion to Extend Time to Respond to Complaint, a copy of which is attached to this notice and is hereby served upon you.
JNS HOLDING CORPORATION AND
JNS POWER & CONTROL SYSTEMS, INC.
By: s/ Evan J. Haim
One of Their Attorneys
Patrick E. Deady
Kelly McCloskey Cherf
Evan J. Haim
Hogan Marren, Ltd.
321 N. Clark Street, Suite 1301
Chicago, IL 60654
312-946-1800
Case: 1:13-cv-03124 Document #: 10 Filed: 05/14/13 Page 1 of 2 PageID #:28
2
CERTIFICATE OF SERVICE
I, Evan J. Haim, hereby certify that on this 10th day of May 2013, and in accordance with the General Order on Electronic Case Filing (ECF), I served the foregoing JNS Holding Corporation and JNS Power & Control Systems, Inc.’s Motion to Extend Time to Respond to the Complaint, upon the below-named individuals by electronic transmittal through the CM-ECF electronic filing system.
Steven L. Baron Michael I. Bernstein
Natalie A. Harris The Bernstein Law Firm
Mandell Menkes LLC 1688 Meridian Avenue, Suite 418
One North Franklin Street, Suite #3600 Miami Beach, Florida 33139
Chicago, Illinois 60606 Telephone: [phone]
Telephone: [phone] Facsimile: [phone]
Facsimile: [phone] e-mail: [e-mail]
e-mail: [e-mail]
e-mail: [e-mail]
/s/ Evan J. Haim
Case: 1:13-cv-03124 Document #: 10 Filed: 05/14/13 Page 2 of 2 PageID #:29