Angel Perez v. City of Chicago

Angel Perez v. City of Chicago

2019 WL 7290848

COMPLAINT filed by Angel Perez; Jury Demand. Filing fee $ 400, receipt number 0752-8468319.(DeCaro, Dennis) (Entered: 06/20/2013)

CIVIL Cover Sheet (DeCaro, Dennis) (Entered: 06/20/2013)

Attorney Appearance by Angel Perez (DeCaro, Dennis) (Entered: 06/20/2013)

CASE ASSIGNED to the Honorable Robert M. Dow, Jr. Designated as Magistrate Judge the Honorable Mary M. Rowland. (jn, )

ATTORNEY Appearance for Defendant City of Chicago by Jason Michael Marx (Marx, Jason) (Entered: 08/01/2013)

ENTERED IN ERROR (Shoffner, Robin) Modified on 8/13/2013 (gcy, ). (Entered: 08/12/2013)

MOTION by Defendants City of Chicago, Jorge L Lopez for extension of time to file answer (Marx, Jason) (Entered: 08/12/2013)

NOTICE of Motion by Jason Michael Marx for presentment of motion for extension of time to file answer 6 before Honorable Robert M. Dow Jr. on 8/15/2013 at 09:15 AM. (Marx, Jason) (Entered: 08/12/2013)

MINUTE entry before Honorable Robert M. Dow, Jr: Before the Court is Defendants' unopposed joint motion to extend time to answer or otherwise plead 6 . The motion is granted. Defendants' answer or other response to the complaint is due 9/9/2013. Notice of motion date of 8/15/2013 is stricken and no appearances are necessary on that date. Mailed notice (tbk, ) (Entered: 08/13/2013)

NOTICE of Correction regarding attorney appearance 5 . (gcy, ) (Entered: 08/13/2013)

ATTORNEY Appearance for Defendant Jorge L Lopez by Kathryn M. Doi (Doi, Kathryn) (Entered: 08/19/2013)

ATTORNEY Appearance for Defendant Jorge L Lopez by Matthew P Dixon (Dixon, Matthew) (Entered: 08/22/2013)

MINUTE entry before Honorable Robert M. Dow, Jr: Initial Status hearing set for 9/24/2013 at 09:00 AM. and parties are to report the following: (1) Possibility of settlement in the case; (2) If no possibility of settlement exists, the nature and length of discovery necessary to get the case ready for trial. Plaintiff is to advise all other parties of the courts action herein. Lead counsel is directed to appear at this status hearing. Parties to prepare and submit a joint status report at least two days prior to set status. (See Judge's web page for status report). Mailed notice (tbk, ) (Entered: 09/06/2013)

ANSWER to Complaint with Jury Demand by City of Chicago(Marx, Jason) (Entered: 09/06/2013)

ANSWER to Complaint with Jury Demand by Jorge L Lopez(Doi, Kathryn) (Entered: 09/18/2013)

NOTICE by Jorge L Lopez re answer to complaint 14 and Certificate of Service (Doi, Kathryn) (Entered: 09/18/2013)

STATUS Report by Angel Perez (DeCaro, Dennis) (Entered: 09/19/2013)

MINUTE entry before Honorable Robert M. Dow, Jr: Status hearing held on 9/24/2013. Rule 26(a)(1) initial disclosures to be exchanged by 10/15/2013. Parties to submit Protective Order and Agreed HIPPA Order by 10/15/2013. All fact discovery to be completed by 3/25/2014. Status hearing set for 3/13/2014 at 09:00 AM. Mailed notice (tbk, ) (Entered: 09/24/2013)

ENTER AGREED CONFIDENTIALITY ORDER Signed by the Honorable Robert M. Dow, Jr on 10/3/2013. Mailed notice(tbk, ) (Entered: 10/03/2013)

ENTER AGREED QUALIFIED HIPAA PROTECTIVE Order Signed by the Honorable Robert M. Dow, Jr on 10/3/2013. Mailed notice(tbk, ) (Entered: 10/03/2013)

MOTION by counsel for Plaintiff Angel Perez to withdraw as attorney (DeCaro, Dennis) (Entered: 12/10/2013)

NOTICE of Motion by Dennis John DeCaro for presentment of motion to withdraw as attorney 20 before Honorable Robert M. Dow Jr. on 12/17/2013 at 09:15 AM. (DeCaro, Dennis) (Entered: 12/11/2013)

MINUTE entry before the Honorable Robert M. Dow, Jr: MOTION by Dennis DeCaro, counsel for Plaintiff Angel Perez, to withdraw as attorney 20 is granted. Plaintiff is given to 1/31/2014 to obtain new counsel or file his pro se appearance. This case is set for further status on 2/6/2014 at 9:00 a.m. at which time either new counsel or Plaintiff himself must appear. Failure to appear may lead to sanctions up to and including dismissal of the case for want of prosecution. As discussed on the record in open court, withdrawing counsel is directed to serve a copy of this order on Plaintiff Perez and place on the docket confirmation that service was effectuated. Mailed notice (tbk, ) (Entered: 12/17/2013)

Notice to Plaintiff of Minute Order granting Plaintiff's Counsel to Withdraw by Angel Perez (DeCaro, Dennis) (Entered: 12/17/2013)

MINUTE entry before the Honorable Robert M. Dow, Jr: On the Court's own motion, Status hearing date of 2/6/2014 is stricken and Status hearing reset for 2/5/2014 at 09:00 AM. Mailed notice (tbk, ) (Entered: 12/23/2013)

ATTORNEY Appearance for Plaintiff Angel Perez by Jon F Erickson (Erickson, Jon) (Entered: 01/22/2014)

ATTORNEY Appearance for Plaintiff Angel Perez by Michael D. Oppenheimer (Oppenheimer, Michael) (Entered: 01/22/2014)

ATTORNEY Appearance for Plaintiff Angel Perez by Ronak P. Maisuria (Maisuria, Ronak) (Entered: 01/22/2014)

MINUTE entry before the Honorable Robert M. Dow, Jr: Status hearing held on 2/5/2014. Existing discovery schedule is stricken. Parties to file a joint status report with proposed discovery schedule by 3/10/2014. Further Status hearing set for 3/13/2014 at 09:00 AM. Mailed notice (tbk, ) (Entered: 02/05/2014)

MOTION by counsel for Plaintiff Angel Perez to withdraw as attorney (Maisuria, Ronak) (Entered: 02/07/2014)

NOTICE of Motion by Ronak P. Maisuria for presentment of motion to withdraw as attorney 29 before Honorable Robert M. Dow Jr. on 2/13/2014 at 09:15 AM. (Maisuria, Ronak) (Entered: 02/07/2014)

MINUTE entry before the Honorable Robert M. Dow, Jr: MOTION by Plaintiff's attorneys, Ronak Maisuria, Jon Erickson, and Michael Oppenheimer of Erickson & Oppenheimer to withdraw their appearance 29 is granted. Plaintiff is given unitl 3/13/2014 to obtain new counsel or file his pro se appearance. This case is set for further status on 3/13/2014 at 9:00 a.m. at which time either new counsel or Plaintiff himself must appear. Failure to appear may lead to sanctions up to and including dismissal of the case for want of prosecution. As discussed on the record in open court, withdrawing counsel is directed to serve a copy of this order on Plaintiff Perez and place on the docket confirmation that service was effectuated. Mailed notice (tbk, ) (Entered: 02/14/2014)

CERTIFICATE of Service by Plaintiff Angel Perez regarding order on motion to withdraw as attorney, motion hearing, set/reset hearings, terminate motions,,,,,,,,,,,, 31 (Attachments: # 1 Notice of Filing)(Maisuria, Ronak) (Entered: 02/25/2014)

1 Notice of Filing

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MINUTE entry before the Honorable Robert M. Dow, Jr: Status hearing held on 3/13/2014. Plaintiff Perez appears at status and is directed to file, instanter, his pro se appearance. Case is being referred to Magistrate Judge Rowland for all discovery motions and discovery supervision. Mailed notice (tbk, ) (Entered: 03/13/2014)

EXECUTIVE COMMITTEE ORDER:Case referred to the Honorable Mary M. Rowland. Entered by Honorable Ruben Castillo on 3/13/14.(gcy, ) (Entered: 03/14/2014)

MINUTE entry before the Honorable Mary M. Rowland:Initial status hearing set for 4/1/2014 at 9:00 AM before Magistrate Judge Mary M. Rowland for discovery status and for the purpose of scheduling a settlement conference. Parties are to bring dates when both clients and counsel will be available for a settlement conference. Judge Rowland generally conducts settlement conferences Mondays through Thursdays at 1:00 p.m. Other dates and times may be available as required by the Court or the parties. The parties are directed to review and to comply with Judge Rowland's Standing Order regarding Setting Settlement Conferences, which is available on Judge Rowland's web page located on the Court's website at www.ilnd.uscourts.gov. Mailed notice (gel, ) (Entered: 03/17/2014)

MOTION by Defendant Jorge L Lopez to reset initial status date (Doi, Kathryn) (Entered: 03/19/2014)

NOTICE of Motion by Kathryn M. Doi for presentment of motion to reset 36 before Honorable Mary M. Rowland on 3/25/2014 at 09:15 AM. (Doi, Kathryn) (Entered: 03/19/2014)

MINUTE entry before the Honorable Mary M. Rowland:Defendant's Motion to reset initial status from 4/1/2014 to 4/7/2014 36 is granted. Initial Status hearing reset for 4/7/2014 at 09:00 AM. No appearance necessary on 3/25/2014. Mailed notice (gel, ) Modified on 3/20/2014 (gel, ). (Entered: 03/20/2014)

MINUTE entry before the Honorable Mary M. Rowland:Status hearing held on 4/7/2014. The individual defendant shall produce to Plaintiff any documents received from Plaintiff's previous counsel as well as individual defendant's document requests by 4/11/2014. The City shall also re-serve Plaintiff its interrogatories and document requests by 4/11/14. Mr. Prerez is ordered to respond to both defendants' discovery requests by May 15, 2014. Plaintiff shall post mark his discovery requests to the Defendants by May 23, 2014. [NOTE DATE CHANGE]. Both defendants are also ordered to re-serve any Rule 26(a)(1) disclosures on Mr. Perez by 4/11/14. Status hearing set for 5/28/2014 at 9:00 AM. Mailed notice (gel, ) (Entered: 04/07/2014)

MINUTE entry before the Honorable Mary M. Rowland:Status hearing held and continued to 6/26/2014 at 9:00 AM. The court will set a close of discovery date at that time.Mailed notice (gel, ) (Entered: 05/28/2014)

MOTION by Defendants City of Chicago, Jorge L Lopez to clarify Plaintiff's witness list (Attachments: # 1 Exhibit A - C)(Doi, Kathryn) (Entered: 06/02/2014)

1 Exhibit A - C

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MOTION by Defendants City of Chicago, Jorge L Lopez to compel answers to discovery (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Doi, Kathryn) (Entered: 06/02/2014)

1 Exhibit A

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2 Exhibit B

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NOTICE of Motion by Kathryn M. Doi for presentment of motion to clarify 41 before Honorable Mary M. Rowland on 6/10/2014 at 09:15 AM. (Doi, Kathryn) (Entered: 06/02/2014)

NOTICE of Motion by Kathryn M. Doi for presentment of motion to compel 42 before Honorable Mary M. Rowland on 6/10/2014 at 09:15 AM. (Doi, Kathryn) (Entered: 06/02/2014)

MINUTE entry before the Honorable Mary M. Rowland:Motion hearing held. Plaintiff failed to appear. Defendants' Motion to Clarify Plaintiff's Witness List 41 is taken under advisement. The motion will be heard on 7/10/2014 at 9:00 AM. Plaintiff must appear and be prepared to address that motion. The status set for 6/26/14 is stricken.Mailed notice (gel, ) (Entered: 06/10/2014)

MINUTE entry before the Honorable Mary M. Rowland:Defendants' Motion to Compel Discovery Responses 42 is GRANTED. Exhibit A to the Motion is Plaintiff's response to Defendant Lopez's Request for Documents and First Set of Interrogatories. With respect to Requests for Production 1-3, 6-21, 24-25 and 27-28, Mr. Lopez provides several paragraphs of boilerplate objections. Mr. Perez is permitted to rely on objections. However, he must also respond to the requests by telling Defendant Lopez whether he is in possession of any documents responsive to the request. Furthermore, in response to both defendants' requests (Exhibit A and Exhibit B), Mr. Lopez indicates that he has "responsive documents and things" which include "Computer Files". The Court understands that Mr. Perez recently produced some documents to counsel for the City and is in the process of burning a CD for the City. So that it is clear, Mr. Perez is ordered to produce all of the documents that he defines as "responsive", including those contained on the CD, to defendants. Mr. Perez also indicates that he will rely on: (1) excerpts from his productions company's "whistleblower documentary"; (2) screenshots of a conversation; (3) video evidence gathered so far; (4) evidence recorded by Plaintiff during his encounter; (5) visual images of damages; (6) video of kid transported to gang area; (7) picture of ankle dent left by shackles; (8) April 21, 2013 message from defendant Lopez; and (9) picture of anal injury. Mr. Perez is required to produce copies of all of these documents and images and the recording. Mr. Perez has two weeks, until June 25, 2014, to produce these items to defendants and to supplement his responses to Defendant Lopez's Requests for Documents. Mailed notice (gel, ) (Entered: 06/11/2014)

MINUTE entry before the Honorable Mary M. Rowland:Status hearing held on 7/10/2014 and continued to 9/16/2014 at 09:30 AM.Mailed notice (gel, ) (Entered: 07/10/2014)

MOTION by Plaintiff Angel Perez to compel. (gcy, ) (Entered: 08/05/2014)

NOTICE of Motion by Angel Perez for presentment of motion to compel 48 before Honorable Mary M. Rowland on 8/12/2014 at 09:15 AM. (gcy, ) (Entered: 08/05/2014)

MINUTE entry before the Honorable Mary M. Rowland:Motion hearing held on 8/12/2014. Plaintiff's Motion to Compel 48 is denied as moot because defendants recently served discovery responses on plaintiff. Plaintiff's deposition is set for 8/27/2014 at 10:00 AM. Plaintiff is to mail the email string with investigator Corely to defendants today. Status hearing previously set for 9/16/2014 to stand. The parties should make every effort to have taken Officer Lopez's deposition or to have a firm date set for that deposition by the next status. The Court will set a close of fact discovery at the next status. Mailed notice (gel, ) (Entered: 08/12/2014)

MINUTE entry before the Honorable Mary M. Rowland:Status hearing held. Defendant's Motion to Clarify Plaintiff's witness 41 list is granted as follows: Plaintiff indicated on the record that he will not call the following individuals to establish liability against Officer Lopez: Jason Christopher, Ilana Rosenzweig, Commander Eric Washington, Superintendent Garry McCarthy, and "all other members of the '193 Gangs Investigations South'". Plaintiff has properly identified these individuals as potentially having knowledge regarding his Monell claim. Plaintiff is given until 9/24/14 to identify a home street address for Carlos De La Pena, Jon Zhong and Jason (last name unknown) OR to verify that these individuals are still employed at the locations identified in Plaintiff's Rule 26(a)(1)(A) disclosures. See Rule 26(a)(1)(A)("a party must... provide... the name and, if known, the address and telephone number of each individual likely to have discoverable information..."). Plaintiff MUST identify a last name for Jason (last name unknown) by 9/24/14. If not, this witness shall be stricken as a witness at trial. Any motion regarding the bifurcation of Monell discovery from individual liability discovery should be filed with the Magistrate Judge. Fact discovery closes on 1/2/15. Status is set for 12/18/14 at 9:00 AM. Mailed notice (gel, ) (Entered: 09/16/2014)

MOTION by Defendant City of Chicago to bifurcate (Attachments: # 1 Exhibit A)(Marx, Jason) (Entered: 09/16/2014)

1 Exhibit A

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NOTICE of Motion by Jason Michael Marx for presentment of motion to bifurcate 52 before Honorable Mary M. Rowland on 9/23/2014 at 09:15 AM. (Marx, Jason) (Entered: 09/16/2014)

MINUTE entry before the Honorable Mary M. Rowland:Motion hearing held. Defendant City of Chicago's Motion to Bifurcate Section 1983 Claims and Stay discovery and trial on those claims 52 is GRANTED. There is no need for counsel for the City to attend further Magistrate Judge status hearings. Status set for 12/18/14 at 9:00 AM to stand.Mailed notice (gel, ) (Entered: 09/23/2014)

ATTORNEY Appearance for Defendant Jorge L Lopez by Jason Michael Marx (Marx, Jason) (Entered: 09/24/2014)

MOTION by Plaintiff Angel Perez to Amended Complaint. (Attachments: # 1 Amended Complaint)(as, ) (Entered: 10/21/2014)

1 Amended Complaint

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NOTICE of Motion by Angel Perez for presentment of motion to Amended Complaint 56 before Honorable Mary M. Rowland on 10/21/2014 at 09:15 AM. (as, ) (Entered: 10/21/2014)

NOTICE of Correction regarding 57 . (as, ) (Entered: 10/21/2014)

MINUTE entry before the Honorable Mary M. Rowland:Motion hearing set for 10/21/2014 is stricken. Plaintiff is directed to re-notice the motion before Judge Dow. Mailed notice (gel, ) (Entered: 10/21/2014)

MOTION by Plaintiff Angel Perez to compel document production and sanction. (as, ) (Entered: 10/28/2014)

NOTICE of Motion by Angel Perez for presentment of compel document production and sanction 60 before Honorable Mary M. Rowland on 11/6/2014 at 09:15 AM. (as, ) (Entered: 10/28/2014)

MOTION by Plaintiff Angel Perez to amend complaint. (as, ) (Entered: 10/28/2014)

RE-NOTICE of Motion by Angel Perez for presentment to amend complaint 62 before Honorable Robert M. Dow Jr. on 11/4/2014 at 09:15 AM. (as, ) (Entered: 10/28/2014)

MINUTE entry before the Honorable Mary M. Rowland: Motion Hearing previously set for 11/6/2014 regarding motion to compel 60 is reset for 11/7/2014 at 09:15 AM.Mailed notice (gel, ) (Entered: 10/29/2014)

MINUTE entry before the Honorable Robert M. Dow, Jr: Plaintiffs motion to amend complaint [56 and 62] are granted. Plaintiff is directed to file an amended complaint for the limited purpose of naming additional defendants within fourteen days of the date of this order. Notice of motion date of 11/4/2014 is stricken and no appearances are necessary on that date. Mailed notice (tbk, ) (Entered: 10/30/2014)

MINUTE entry before the Honorable Mary M. Rowland:Motion hearing held on 11/7/2014. Plaintiff's Motion to compel 60 is denied as stated in open court. Defendant is ordered to produce CR files for all named Defendants. Status hearing previously set for 12/18/2014 is reset for 1/21/2015 at 09:00 AM.Mailed notice (gel, ) (Entered: 11/07/2014)

AMENDED complaint by Angel Perez against Herbert Betancourt, City of Chicago, Matthew Cline, John Dolan, Jorge L Lopez, Joseph Wagner, Edmund Zablocki. (Attachments: # 1 Notice of Filing) (as, ) (Entered: 11/13/2014)

1 Notice of Filing

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MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM (Marx, Jason) (Entered: 11/19/2014)

NOTICE of Motion by Jason Michael Marx for presentment of Motion to Dismiss for Failure to State a Claim 68 before Honorable Robert M. Dow Jr. on 11/25/2014 at 09:15 AM. (Marx, Jason) (Entered: 11/19/2014)

MINUTE entry before the Honorable Robert M. Dow, Jr: MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM 68 is withdrawn without prejudice. As discussed on the record, Plaintiff is given until 12/3/2014 in which to file a revised amended complaint. Mailed notice (tbk, ) (Entered: 11/25/2014)

MOTION by counsel for Defendant City of Chicago to withdraw as attorney Robin Shoffner (Shoffner, Robin) (Entered: 11/30/2014)

NOTICE of Motion by Robin Denise Shoffner for presentment of motion to withdraw as attorney 71 before Honorable Robert M. Dow Jr. on 12/4/2014 at 09:15 AM. (Shoffner, Robin) (Entered: 11/30/2014)

MINUTE entry before the Honorable Robert M. Dow, Jr: Motion to withdraw the appearance of Robert Shoffner as counsel for Defendant City of Chicago 71 is granted. Notice of Motion date of 12/4/2014 is stricken and no appearances are necessary on that date. Mailed notice (tbk, ) (Entered: 12/02/2014)

REVISED Amended complaint by Angel Perez against all Defendants; Notice.(as, ) (Entered: 12/04/2014)

ANSWER to amended complaint by Herbert Betancourt, City of Chicago, Matthew Cline, John Dolan, Jorge L Lopez, Joseph Wagner, Edmund Zablocki(Doi, Kathryn) (Entered: 12/18/2014)

MOTION by Defendants John Dolan, City of Chicago, Edmund Zablocki, Jorge L Lopez, Herbert Betancourt, Matthew Cline, Joseph Wagner to dismiss Count VII of Plaintiff's Revised Amended Complaint (Doi, Kathryn) (Entered: 12/18/2014)

NOTICE of Motion by Kathryn M. Doi for presentment of motion to dismiss 76 before Honorable Robert M. Dow Jr. on 1/6/2015 at 09:15 AM. (Doi, Kathryn) (Entered: 12/18/2014)

NOTICE of Motion by Kathryn M. Doi for presentment of motion to dismiss 76 before Honorable Robert M. Dow Jr. on 1/6/2015 at 09:15 AM. (Doi, Kathryn) (Entered: 12/19/2014)

MINUTE entry before the Honorable Robert M. Dow, Jr: Motion hearing held. The plaintiff submitted to the Court and to the counsel for the defendants, his response to the defendants' motion to dismiss Count VII of plaintiff's revised amended complaint 76 . The plaintiff's response was filed this morning with the Clerk's Office. The defendants may reply by 1/20/2015. The Court will rule by mail and set the case for further status hearing at that time. Mailed notice (cdh, ) (Entered: 01/06/2015)

RESPONSE by Angel Perez to MOTION by Defendants motion to dismiss Count VII of Plaintiff's Revised Amended Complaint 76 . (as, ) (Entered: 01/08/2015)

DOCUMENT ENTERED IN ERROR. (meg, ) (Main Document 81 replaced on 1/22/2015) (meg, ). Modified on 1/22/2015 (meg, ). (Entered: 01/21/2015)

REPLY by Herbert Betancourt, City of Chicago, Matthew Cline, John Dolan, Jorge L Lopez, Joseph Wagner, Edmund Zablocki to response to motion 80 (Doi, Kathryn) (Entered: 01/21/2015)

NOTICE by Herbert Betancourt, City of Chicago, Matthew Cline, John Dolan, Jorge L Lopez, Joseph Wagner, Edmund Zablocki re reply to response to motion 82 (Doi, Kathryn) (Entered: 01/21/2015)

MINUTE entry before the Honorable Mary M. Rowland: Docket entry number 81 dated 1/21/15 is stricken. Status hearing held on 1/21/15 and continued to 3/18/15 at 9:00 AM. Parties' written discovery shall issue before that date. Parties shall submit a joint proposed order regarding the treating physician's production of records to the court's proposed order inbox by 1/26/15. Mailed notice (meg, ) (Entered: 01/22/2015)

MINUTE entry before the Honorable Mary M. Rowland: The Court, having reviewed the 1/21/2015 status hearing and the parties' agreed proposed order to enforce a subpoena issued by Defendant to nonparty Fe Velasco, M.D., finds that (1) Dr. Velasco has objected to producing certain documents; and (2) proper notice has not been given to Dr. Velasco seeking compliance with the subpoena. Fed. R. Civ. P. 45(d)(2)(B)(i) (If an objection is made by the commanded person, "on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection."). Should Defendant wish to enforce the subpoena to Dr. Velasco, it should file a motion to compel, set it for hearing, and give proper notice to Dr. Velasco. Mailed notice (meg, ) (Entered: 01/23/2015)

NOTICE by Kathryn M. Doi of Change of Address (Doi, Kathryn) (Entered: 02/10/2015)

MOTION by Plaintiff Angel Perez to compel and sanction defendant City of Chicago et al. (gcy, ) (Entered: 03/03/2015)

NOTICE of Motion to Compel and Sanction by Angel Perez. (gcy, ) (Entered: 03/03/2015)

ATTORNEY Appearance for Defendants Herbert Betancourt, City of Chicago, Matthew Cline, John Dolan, Jorge L Lopez, Joseph Wagner, Edmund Zablocki by Lindsay Erin Wilson Gowin (Wilson Gowin, Lindsay) (Entered: 03/03/2015)

MOTION by Plaintiff Angel Perez for leave to file ATTORNEYS' APPEARANCES (Kamin, Scott) (Entered: 03/13/2015)

NOTICE of Motion by Scott T. Kamin for presentment of motion for leave to file 90 before Honorable Mary M. Rowland on 3/18/2015 at 09:15 AM. (Kamin, Scott) (Entered: 03/13/2015)

MINUTE entry before the Honorable Mary M. Rowland: Status hearing held. Motion for attorney Scott T. Kamin to appear on behalf of defendant 90 is granted. Motion to Compel 87 is withdrawn. Plaintiff is granted leave to file supplemental written discovery. Status hearing set for 5/20/15 at 9:00 AM. The Court would like to set a close of fact discovery at that time. Mailed notice (mb, ) (Entered: 03/18/2015)

ATTORNEY Appearance for Plaintiff Angel Perez by Scott T. Kamin (Kamin, Scott) (Entered: 03/24/2015)

ATTORNEY Appearance for Plaintiff Angel Perez by Phillip Aaron Brigham (Brigham, Phillip) (Entered: 03/30/2015)

ATTORNEY Appearance for Plaintiff Angel Perez by Jason R. Epstein (Epstein, Jason) (Entered: 03/30/2015)

MOTION by Plaintiff Angel Perez for leave to file 2nd Amended Complaint (Attachments: # 1 Exhibit 2 nd Amended Complaint)(Kamin, Scott) (Entered: 03/31/2015)

1 Exhibit 2 nd Amended Complaint

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NOTICE of Motion by Scott T. Kamin for presentment of motion for leave to file 96 before Honorable Robert M. Dow Jr. on 4/7/2015 at 09:15 AM. (Kamin, Scott) (Entered: 03/31/2015)

ATTORNEY Appearance for Plaintiff Angel Perez by Daniel A. Edelman (Edelman, Daniel) (Entered: 04/06/2015)

ATTORNEY Appearance for Plaintiff Angel Perez by Cassandra P. Miller (Miller, Cassandra) (Entered: 04/06/2015)