Students and Parents For Privacy et al v. United States Department of Education et al

Northern District of Illinois, ilnd-1:2016-cv-04945

NOTICE of Motion by Laura Rose Hammargren for presentment of motion for miscellaneous relief, [192] before Honorable Jorge L. Alonso on 1/30/2018 at 09:30 AM.

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Case: 1:16-cv-04945 Document #: 193 Filed: 01/24/18 Page 1 of 3 PageID #:2792 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS STUDENTS AND PARENTS FOR) PRIVACY, a voluntary unincorporated) association; C.A., a minor, by and through) her parent and guardian, N.A.; A.M., a) minor, by and through her parents and) No. 1:16 CV 4945 guardians, S.M. and R.M.; N.G., a minor, by) and through her parent and guardian, R.G.;) The Hon. Jorge L. Alonso, A.V., a minor, by and through her parents) District Court Judge and guardians, T.V. and A.T.V.; and B.W.,) a minor, by and through his parents and) guardians, D.W. and V.W.,)) Plaintiffs,)) v.)) UNITED STATES DEPARTMENT OF) EDUCATION; JOHN B. KING, JR., in his) official capacity as United States Secretary) of Education; UNITED STATES) DEPARTMENT OF JUSTICE; LORETTA) E. LYNCH, in her official capacity as) United States Attorney General; and) SCHOOL DIRECTORS OF TOWNSHIP) HIGH SCHOOL DISTRICT 211, COUNTY) OF COOK AND STATE OF ILLINOIS,)) Defendants, and)) STUDENTS A, B, and C, by and through) their parents and legal guardians Parents A,) B, and C, and the ILLINOIS SAFE) SCHOOLS ALLIANCE,)) Intervenor-Defendants.) NOTICE OF JOINT MOTION TO ESTABLISH A DEADLINE TO FILE AN AMENDED COMPLAINT, FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFFS' COMPLAINT, AND TO MODIFY THE STATUS HEARING SCHEDULE Case: 1:16-cv-04945 Document #: 193 Filed: 01/24/18 Page 2 of 3 PageID #:2793 PLEASE TAKE NOTICE that on Tuesday, January 30, 2018, at 9:30 a.m., or as soon thereafter as counsel may be heard, the undersigned counsel will appear before the Honorable Judge Jorge L. Alonso in Courtroom 1278 of the United States District Court for the Northern District of Illinois, 219 South Dearborn Street, Chicago, Illinois 60604, to present the Parties' Joint Motion to Establish a Deadline to File an Amended Complaint, for an Extension of Time to Respond to Plaintiffs' Complaint, and to Modify the Status Hearing Schedule. Respectfully submitted, Dated: January 24, 2018 /s/ Laura R. Hammargren Britt M. Miller John Knight Timothy S. Bishop ROGER BALDWIN FOUNDATION OF Laura R. Hammargren ACLU, INC. Linda X. Shi 180 North Michigan Avenue MAYER BROWN LLP Suite 2300 71 South Wacker Drive Chicago, IL 60601 Chicago, IL 60606 Telephone: (312) 201-9740 ext. 335 Telephone: (312) 782-0600 Facsimile: (312) 288-5225 Facsimile: (312) 701-7711 jknight@aclu-il.org bmiller@mayerbrown.com tbishop@mayerbrown.com - and - lhammargren@mayerbrown.com lshi@mayerbrown.com Ria Tabacco Mar* AMERICAN CIVIL LIBERTIES UNION - and – FOUNDATION 125 Broad St., 18th Floor Catherine A. Bernard New York, NY 10004 Madeleine L. Hogue* Telephone: (212) 549-2627 MAYER BROWN LLP Facsimile: (212) 549-2650 1999 K Street, N.W. rmar@aclu.org Washington, DC 20006-1101 Telephone: (202) 263-3000 * Admitted pro hac vice Facsimile: (202) 263-3300 cbernard@mayerbrown.com mhogue@mayerbrown.com * Admitted pro hac vice Counsel for Students A, B, and C, and the Illinois Safe Schools Alliance 1 Case: 1:16-cv-04945 Document #: 193 Filed: 01/24/18 Page 3 of 3 PageID #:2794 CERTIFICATE OF SERVICE I, Laura R. Hammargren, an attorney, hereby certify that on January 24, 2018, I caused a true and correct copy of the foregoing NOTICE OF MOTION as well as the JOINT MOTION TO ESTABLISH A DEADLINE TO FILE AN AMENDED COMPLAINT, FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFFS' COMPLAINT, AND TO MODIFY THE STATUS HEARING SCHEDULE, to be filed and served electronically via the court's CM/ECF system. Notice of this filing will be sent by e-mail to all parties by operation of the court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the court's CM/ECF System. /s/ Laura R. Hammargren Laura R. Hammargren MAYER BROWN LLP 71 South Wacker Drive Chicago, IL 60606 Telephone: (312) 782-0600 Facsimile: (312) 701-7711 lhammargren@mayerbrown.com