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 Sally J. Scott for presentment of motion for extension of time to file answer, [228] before Honorable Jorge L. Alonso on 4/11/2019 at 09:30 AM.

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Case: 1:16-cv-04945 Document #: 229 Filed: 04/08/19 Page 1 of 5 PageID #:3456 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION 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 MOTION 2669863.1 Case: 1:16-cv-04945 Document #: 229 Filed: 04/08/19 Page 2 of 5 PageID #:3457 TO: See attached Certificate of Service PLEASE TAKE NOTICE that on Thursday, April 11, 2019, at 9:30 a.m., or as soon thereafter as counsel may be heard, we shall appear before the Honorable Jorge L. Alonso, or any judge sitting in his stead, in Courtroom 1903 of the U.S. District Court for the Northern District of Illinois, 219 South Dearborn Street, Chicago, Illinois, and then and there present Joint Motion for an Extension of Time to Answer Plaintiffs' First Amended Complaint, which is hereby served upon you. Dated: April 8, 2019 Respectfully submitted, BOARD OF EDUCATION OF TOWNSHIP HIGH SCHOOL DISTRICT 211 By: /s/Sally J. Scott One of Its Attorneys Sally J. Scott Michael A. Warner, Jr. Jennifer A. Smith Erin Fowler FRANCZEK RADELET P.C. 300 South Wacker Drive, Suite 3400 Chicago, IL 60606-6785 (312) 986-0300 2 2669863.1 Case: 1:16-cv-04945 Document #: 229 Filed: 04/08/19 Page 3 of 5 PageID #:3458 CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that she caused a true and correct copy of the foregoing NOTICE OF MOTION to be filed with the Clerk of the Court using the CM/ECF system which will send electronic notification to the following counsel of record this 8th day of April, 2019: Thomas L. Brejcha Peter Breen Thomas Olp THOMAS MORE SOCIETY 19 S. LaSalle St., Suite 603 Chicago, IL 60603 Attorneys for Plaintiffs Gary S. McCaleb Jeana Hallock ALLIANCE DEFENDING FREEDOM 15100 N. 90th St. Scottsdale, AZ 85260 Attorneys for Plaintiffs J. Matthew Sharp ALLIANCE DEFENDING FREEDOM 1000 Hurricane Shoals Rd., NE Suite D-1100 Lawrenceville, GA 30043 Attorneys for Plaintiffs Douglas G. Wardlow 14033 Commerce Ave. NE #300-310 Prior Lake, MN 55372 Attorneys for Plaintiffs 2669863.1 Case: 1:16-cv-04945 Document #: 229 Filed: 04/08/19 Page 4 of 5 PageID #:3459 Megan A. Crowley Shiela Lieber James O. Bickford U.S. DEPARTMENT OF JUSTICE, CIVIL DIVISION, FEDERAL PROGRAMS BRANCH 20 Massachusetts Ave., N.W. Washington, DC 20001 Attorneys for U.S. Department of Education, Elisabeth DeVos; United States Department of Justice, Jefferson B. Sessions III Benjamin L. Berwick U.S. Department of Justice Civil Division, Federal Programs Branch 1 Courthouse Way, Suite 9200 Boston, MA 02210 Attorneys for U.S. Department of Education; John B. King, Jr., United States Department of Justice and Loretta E. Lynch Britt M. Miller Laura R. Hammargren Linda X. Shi Timothy S. Bishop MAYER BROWN LLP 71 S. Wacker Dr. Chicago, IL 60606 Attorneys for Students A, B, and C, by and through their parents and legal guardians, and the Illinois Safe Schools Alliance Catherine A. Bernard Madeleine L. Hogue MAYER BROWN LLP 1999 K St., N.W. Washington, DC 20006-1101 Attorneys for Students A, B, and C, by and through their parents and legal guardians, and the Illinois Safe Schools Alliance John A. Knight ROGER BALDWIN FOUNDATION AT ACLU, INC. 150 N. Michigan Ave., Suite 600 Chicago, IL 60601 Attorney for Intervenor Illinois Safe Schools Alliance 2 2669863.1 Case: 1:16-cv-04945 Document #: 229 Filed: 04/08/19 Page 5 of 5 PageID #:3460 Ria Tabacco Mar American Civil Liberties Union Foundation 125 Broad Street New York, NY 1004-2400 Attorneys for Students A, B, and C, by and through their parents and legal guardians, and the Illinois Safe Schools Alliance /s/Sally J. Scott 3 2669863.1