Notice of Extension of Time

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Case 1:21-cv-00143-JRS-DML Document 8 Filed 02/09/21 Page 1 of 2 PageID #: 57

UNITED STATES DISTRICT COURT


FOR THE SOUTHERN DISTRICT OF INDIANA

MIDCONTINENT INDEPENDENT
SYSTEM OPERATOR, INC.,

Plaintiff,
CIVIL ACTION NO. 1:21-CV-143

v.

JAMES F. SULLIVAN a/k/a JIM CASSIDY,

Defendant.

NOTICE OF EXTENSION OF TIME TO


ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT

Pursuant to Local Rule 6-1, Midcontinent Independent System Operator, Inc.

(“Midcontinent”) files on behalf of Defendant James F. Sullivan (“Sullivan”) this notice for an

extension of time seeking a twenty-eight (28) day extension of time through and including March

10, 2021, in which to answer, move or otherwise respond to the allegations in Plaintiff’s

Complaint.

The current deadline for Sullivan to answer or otherwise respond is February 10, 2021.

This is Sullivan’s first request for an extension.

The requested extension does not interfere with the Case Management Plan, scheduled

hearings or trials, or other deadlines set by the Court.

Plaintiff Midcontinent’s counsel consents to Sullivan’s request for extension of time.


Case 1:21-cv-00143-JRS-DML Document 8 Filed 02/09/21 Page 2 of 2 PageID #: 58

Dated: February 9, 2021 Respectfully submitted,

/s/ Kevin W. Kirsch


Kevin W. Kirsch
[email protected]
David A. Mancino
[email protected]
Kevin P. Flynn (pro hac vice forthcoming)
[email protected]
BAKER & HOSTETLER LLP
312 Walnut Street, Suite 3200
Cincinnati, Ohio 45202-4074
Telephone: (513) 929-3400
Facsimile: (513) 929-0303

Jared A. Brandyberry (pro hac vice


forthcoming)
[email protected]
BAKER & HOSTETLER LLP
1801 California Street, Suite 4400
Denver, Colorado 80202-2662
Telephone: (303) 764-4072
Facsimile: (303) 861-7805
Attorneys for Midcontinent Independent
System Operator, Inc.

CERTIFICATE OF SERVICE
I hereby certify that this document filed through the CM/ECF system will be sent

electronically to the registered participants as identified on the NEF (NEF) and paper copies will

be sent to those indicated as non-registered participants on February 9, 2021.

/s/ Kevin W. Kirsch


Kevin W. Kirsch

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