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Motion for Leave to File Reply Brief in Support of Its Motion to Dismiss — No. 1:22-cv-01204 (Dkt. 37, C.D. Ill.)

Summary

Defendant Reditus Laboratories, LLC's Motion for Leave to File Reply Brief in Support of Its Motion to Dismiss, document 37 filed May 4, 2024 in the Central District of Illinois (Case 1:22-cv-01204-SLD-JEH), United States of America ex rel. Ferzad Abdi v. Aaron James Rossi, et al., before Chief Judge Sara Darrow. Under Local Rules 7.1(B) and 7.1(F), Reditus seeks leave to file a reply in support of its motion to dismiss the First Amended Complaint, which it filed February 20, 2024. The relator filed his opposition on April 10, 2024 after a 30-day extension, and Reditus says a short reply is needed to answer his arguments. The reply is attached as Exhibit A, with a proposed order and a certificate of service signed by ArentFox Schiff LLP counsel.

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“Motion for Leave to File Reply Brief in Support of Its Motion to Dismiss — No. 1:22-cv-01204 (Dkt. 37, C.D. Ill.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-for-leave-to-file-reply-brief-in-support-of-its-motion-to-dismi-98bc08da3d/, SHA-256 f66bcb8497d15a8a44ceeed0dee66125c74c5da48ec42a11e185eb54579b5539.

Full text

              1:22-cv-01204-SLD-JEH # 37           Filed: 05/04/24    Page 1 of 3




                      IN THE UNITED STATES DISTRICT COURT
                      FOR THE CENTRAL DISTRICT OF ILLINOIS

UNITED STATES OF AMERICA                     )
ex rel. FERZAD ABDI,                         )
                                             )
       Plaintiff/Relator                     )      Case No. 1:22-cv-01204
                                             )
               v.                            )      Chief Judge Sara Darrow
                                             )
AARON JAMES ROSSI, et al.,                   )
                                             )
       Defendants.                           )

                     DEFENDANT REDITUS LABORATORIES, LLC’s
                      MOTION FOR LEAVE TO FILE REPLY BRIEF
                       IN SUPPORT OF ITS MOTION TO DISMISS

       Pursuant to Local Rules 7.1(B) and 7.1(F), Defendant Reditus Laboratories, LLC

(“Reditus”) respectfully seeks leave to file a reply memorandum in support of its Motion to

Dismiss Relator’s First Amended Complaint. As grounds for this Motion, Reditus states as

follows:

       1.      On February 20, 2024, Reditus filed its Motion to Dismiss the First Amended

Complaint and accompanying Memorandum of Law. ECF # 31, 32.

       2.      After seeking, and receiving, a 30-day extension of the deadline for his Response,

Relator filed his Opposition and Memorandum in response to Reditus’ motion to dismiss on April

10, 2024. ECF # 34-36.

       3.      A short reply memorandum is necessary to respond to arguments raised in Relator’s

Response, to fully elucidate the complex legal and factual issues presented by Reditus’ Motion to

Dismiss, and to aid the Court in its consideration of Reditus’ pending motion.

       WHEREFORE, Reditus respectfully requests that the Court grant it leave to file the Reply

in Support of Its Motion to Dismiss, which is attached hereto as Exhibit A in accordance with

Local Rule 7.1(F). A proposed order is also attached for the Court’s consideration.
             1:22-cv-01204-SLD-JEH # 37          Filed: 05/04/24     Page 2 of 3




Dated: May 4, 2024                         Respectfully submitted,

                                           /s/ William P. Ziegelmueller
                                           William P. Ziegelmueller
                                           Meredith F.W. DeCarlo
                                           James D. Cromley
                                           ARENTFOX SCHIFF LLP
                                           233 South Wacker Dr., Suite 7100
                                           Chicago, IL 60606
                                           (312) 258-5500

                                            Attorneys for Defendant Reditus Laboratories, LLC



                               CERTIFICATE OF SERVICE

        The undersigned certifies that on May 4, 2024, the foregoing Motion for Leave to File
Reply in Support of Its Motion to Dismiss and the accompanying Proposed Order were filed
electronically and served upon all counsel of record by operation of the Court’s CM/ECF system.

                                                   /s/ William P. Ziegelmueller




                                                  2
                     1:22-cv-01204-SLD-JEH # 37    Filed: 05/04/24    Page 3 of 3




                           IN THE UNITED STATES DISTRICT COURT
                           FOR THE CENTRAL DISTRICT OF ILLINOIS

UNITED STATES OF AMERICA                     )
ex rel. FERZAD ABDI                          )
                                             )
         Plaintiff/Relator                   )      Case No. 1:22-cv-01203
                                             )
                     v.                      )      Chief Judge Sara Darrow
                                             )
AARON JAMES ROSSI, et al.,                   )
                                             )
         Defendants.                         )


                                     [PROPOSED] ORDER

         Upon consideration of the Motion for Leave to File Reply in Support of Its Motion to

Dismiss (the “Motion”) filed by Defendant Reditus Laboratories, LLC (“Reditus”), IT IS

HEREBY ORDERED that Defendant Reditus’ Motion is GRANTED and that the Clerk is directed

to file Reditus’ Reply in Support of Its Motion to Dismiss attached to the Motion as Exhibit A.

         SO ORDERED this ______ day of _____________, 2024.




                                                    __________________________________
                                                    SARA L. DARROW
                                                    Chief United States District Judge
SHDOCS:220922413.1




                                                    3


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