COMPLAINT filed by Lucy Parsons Labs, Michael Williams, Daniel Ortiz; Jury Demand. Filing fee $ 402, receipt number AILNDC-19670038.(Manes, Jonathan) (Entered: 07/21/2022)

CIVIL Cover Sheet (Manes, Jonathan) (Entered: 07/21/2022)

ATTORNEY Appearance for Plaintiffs Lucy Parsons Labs, Daniel Ortiz, Michael Williams by Jonathan Matthew Manes (Manes, Jonathan) (Entered: 07/21/2022)

ATTORNEY Appearance for Plaintiffs Lucy Parsons Labs, Daniel Ortiz, Michael Williams by Alexa Van Brunt (Van Brunt, Alexa) (Entered: 07/21/2022)

clerk's notice

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (emc, )

case assigned

CASE ASSIGNED to the Honorable Ronald A. Guzman. Designated as Magistrate Judge the Honorable Young B. Kim. Case assignment: Random assignment. (emc, )

SUMMONS Issued as to Defendants Eduardo Almanza, Salvatore Aloisio, David O'Neal Brown, Scott Brownley, City Of Chicago, Robert Costello, Nestor De Jesus, Michael Dougherty, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Michael Kociolek, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff, Brian Roney (ak, )

summons issued

SUMMONS Returned Executed by Michael Williams, Daniel Ortiz as to All Defendants. (Manes, Jonathan) (Entered: 08/03/2022)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Lucy Parsons Labs and Corporate Disclosure Statement pursuant to Rule 7.1 (Manes, Jonathan) (Entered: 08/03/2022)

ATTORNEY Appearance for Defendant City Of Chicago by Michael P. Sheehan (Sheehan, Michael) (Entered: 08/22/2022)

ATTORNEY Appearance for Defendant City Of Chicago by Yeoeun Yoon (Yoon, Yeoeun) (Entered: 08/22/2022)

ATTORNEY Appearance for Defendant City Of Chicago by Ioana Maria Guset (Guset, Ioana) (Entered: 08/22/2022)

ATTORNEY Appearance for Defendant City Of Chicago by Allan T. Slagel (Slagel, Allan) (Entered: 08/22/2022)

ATTORNEY Appearance for Defendant City Of Chicago by Barton James O'Brien (O'Brien, Barton) (Entered: 08/22/2022)

MOTION by Defendant City Of Chicago for extension of time Defendant City of Chicago's Unopposed Motion for Extension of Time to Answer or Otherwise Plead (Sheehan, Michael) (Entered: 08/22/2022)

MINUTE entry before the Honorable Ronald A. Guzman: Defendant City of Chicago's unopposed motion for extension of time through October 21, 2022 to answer or otherwise plead in response to Plaintiff's complaint is granted. There will be no further extensions of that deadline. Mailed notice. (exr, ) (Entered: 08/22/2022)

ATTORNEY Appearance for Defendants Robert Costello, Michael Kociolek by Shneur Z. Nathan (Nathan, Shneur) (Entered: 09/09/2022)

ATTORNEY Appearance for Defendants Robert Costello, Michael Kociolek by Avi T. Kamionski (Kamionski, Avi) (Entered: 09/09/2022)

ATTORNEY Appearance for Defendants Robert Costello, Michael Kociolek by Helen Catherine O'Shaughnessy (O'Shaughnessy, Helen) (Entered: 09/09/2022)

ATTORNEY Appearance for Defendants Robert Costello, Michael Kociolek by Matthew James Mc Carter (Mc Carter, Matthew) (Entered: 09/09/2022)

ATTORNEY Appearance for Defendants Robert Costello, Michael Kociolek by Neha Sharma Locke (Locke, Neha) (Entered: 09/09/2022)

ATTORNEY Appearance for Defendants Eduardo Almanza, Salvatore Aloisio, Scott Brownley, Nestor De Jesus, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff by Shneur Z. Nathan (Nathan, Shneur) (Entered: 09/30/2022)

ATTORNEY Appearance for Defendants Eduardo Almanza, Salvatore Aloisio, Scott Brownley, Nestor De Jesus, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff by Avi T. Kamionski (Kamionski, Avi) (Entered: 09/30/2022)

ATTORNEY Appearance for Defendants Eduardo Almanza, Salvatore Aloisio, Scott Brownley, Nestor De Jesus, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff by Helen Catherine O'Shaughnessy (O'Shaughnessy, Helen) (Entered: 09/30/2022)

ATTORNEY Appearance for Defendants Eduardo Almanza, Salvatore Aloisio, Scott Brownley, Nestor De Jesus, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff by Matthew James Mc Carter (Mc Carter, Matthew) (Entered: 09/30/2022)

ATTORNEY Appearance for Defendants Eduardo Almanza, Salvatore Aloisio, Scott Brownley, Nestor De Jesus, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff by Neha Sharma Locke (Locke, Neha) (Entered: 09/30/2022)

MOTION by Defendants Eduardo Almanza, Salvatore Aloisio, Scott Brownley, Robert Costello, Nestor De Jesus, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Michael Kociolek, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff for extension of time UNOPPOSED MOTION FOR EXTENSION OF TIME FOR CERTAIN DEFENDANT OFFICERS TO FILE RESPONSIVE PLEADING (Mc Carter, Matthew) (Entered: 09/30/2022)

MINUTE entry before the Honorable Ronald A. Guzman: The unopposed motion by Defendants Eduardo Almanza, Salvatore Aloisio, Scott Brownley, Robert Costello, Nestor De Jesus, Nicholas Evangelides, Mark Flechsig, Arthur Harb, Michael Kociolek, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, and Scott Reiff for an extension of time through October 21, 2022, to file a responsive pleading 24 is granted. Mailed notice (ags, (Entered: 09/30/2022)

ATTORNEY Appearance for Defendant David O'Neal Brown by Michael P. Sheehan (Sheehan, Michael) (Entered: 10/19/2022)

ATTORNEY Appearance for Defendant David O'Neal Brown by Allan T. Slagel (Slagel, Allan) (Entered: 10/19/2022)

ATTORNEY Appearance for Defendant David O'Neal Brown by Yeoeun Yoon (Yoon, Yeoeun) (Entered: 10/19/2022)

ATTORNEY Appearance for Defendant David O'Neal Brown by Barton James O'Brien (O'Brien, Barton) (Entered: 10/19/2022)

ATTORNEY Appearance for Defendant David O'Neal Brown by Ioana Maria Guset (Guset, Ioana) (Entered: 10/19/2022)

MOTION by Plaintiffs Lucy Parsons Labs, Daniel Ortiz, Michael Williams for extension of time Joint Motion for Leave to Amend Complaint and Pleading Schedule (Manes, Jonathan) (Entered: 10/19/2022)

ATTORNEY Appearance for Defendant Michael Dougherty by Avi T. Kamionski (Kamionski, Avi) (Entered: 10/21/2022)

ATTORNEY Appearance for Defendant Michael Dougherty by Shneur Z. Nathan (Nathan, Shneur) (Entered: 10/21/2022)

ATTORNEY Appearance for Defendant Michael Dougherty by Helen Catherine O'Shaughnessy (O'Shaughnessy, Helen) (Entered: 10/21/2022)

ATTORNEY Appearance for Defendant Michael Dougherty by Matthew James Mc Carter (Mc Carter, Matthew) (Entered: 10/21/2022)

ATTORNEY Appearance for Defendant Michael Dougherty by Neha Sharma Locke (Locke, Neha) (Entered: 10/21/2022)

MINUTE entry before the Honorable Ronald A. Guzman: The parties' joint motion for leave to amend complaint and pleading schedule 31 is granted, except that the Court will set a responsive pleading date for all defendants. Plaintiff shall file an amended complaint by 11/14/2022. Defendant City of Chicago shall respond to the amended complaint by 1/4/2023. The individual officer defendants shall respond to the amended complaint by 1/13/2023. Given the timeline of this case and the generous schedule, there will be no extensions absent extraordinary circumstances. The parties are directed to confer no later than 1/13/2023 to discuss the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case, and they shall also discuss deadlines for any Rule 26(a)(1) disclosures that have not already been exchanged and a proposed discovery plan. Plaintiff is responsible for initiating such a conference, and all lead counsel for all parties must participate. In lieu of an initial status hearing, the parties shall file a joint written initial status report and proposed discovery plan by 1/20/2023. Failure or refusal to participate in such a conference or to cooperate in the preparation of the written report may constitute a basis for sanctions. After the Court receives the parties' written report, it will issue an order setting a discovery schedule if appropriate. Mailed notice. (kp, ) (Entered: 10/24/2022)

AMENDED complaint by Lucy Parsons Labs, Michael Williams, Daniel Ortiz, Derick Scruggs against Eduardo Almanza, Salvatore Aloisio, David O'Neal Brown, Scott Brownley, City Of Chicago, Robert Costello, Nestor De Jesus, Michael Dougherty, Nicholas Evangelides, Michael Kociolek, Mark LaPadula, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff, Brian Roney, Fidel Legorreta, Theodore Andrews, Jr, Sarah Keckley, Jane Doe and terminating Mark Flechsig (#1733) and Arthur Harb (#311) (Manes, Jonathan) (Entered: 11/14/2022)

SUMMONS Issued as to Defendant Fidel Legorreta (emc, )

SUMMONS Issued as to Defendant Theodore Andrews, Jr (emc, )

summons issued

SUMMONS Issued as to Defendant Sarah Keckley (emc, )

SUMMONS Returned Executed by Lucy Parsons Labs, Michael Williams, Daniel Ortiz, Derick Scruggs as to Theodore Andrews, Jr on 11/21/2022, answer due 12/12/2022; Sarah Keckley on 11/21/2022, answer due 12/12/2022; Fidel Legorreta on 11/21/2022, answer due 12/12/2022. (Manes, Jonathan) (Entered: 11/23/2022)

ATTORNEY Appearance for Defendants Theodore Andrews, Jr, Fidel Legorreta by Shneur Z. Nathan (Nathan, Shneur) (Entered: 12/06/2022)

ATTORNEY Appearance for Defendants Theodore Andrews, Jr, Fidel Legorreta by Avi T. Kamionski (Kamionski, Avi) (Entered: 12/06/2022)

ATTORNEY Appearance for Defendants Theodore Andrews, Jr, Fidel Legorreta by Helen Catherine O'Shaughnessy (O'Shaughnessy, Helen) (Entered: 12/06/2022)

ATTORNEY Appearance for Defendants Theodore Andrews, Jr, Fidel Legorreta by Matthew James Mc Carter (Mc Carter, Matthew) (Entered: 12/06/2022)

ATTORNEY Appearance for Defendants Theodore Andrews, Jr, Fidel Legorreta by Neha Sharma Locke (Locke, Neha) (Entered: 12/06/2022)

MOTION by Defendant City Of Chicago for leave to file excess pages Defendants City of Chicago and Superintendent Brown's Unopposed Motion for Leave to File an Oversized Motion (Sheehan, Michael) (Entered: 12/22/2022)

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice. (tg, ) (Entered: 12/29/2022)

MINUTE entry before the Honorable Ronald A. Guzman: The unopposed motion for leave to file an oversized brief filed by the City of Chicago and Superintendent Brown 45 is granted. Defendants, however, should consider that the Court values concision and economy, encourages joint briefs and exhibits and adopting parts of a co-defendant's brief, and may strike redundant and uncoordinated briefing. Briefing should contain only such facts as are foundational to the legal analysis. Plaintiff shall respond to the motion by 2/6/2023. Any reply shall be filed by 2/24/2023. (kp, ) (Entered: 12/30/2022)

MOTION by Defendants Eduardo Almanza, Salvatore Aloisio, Theodore Andrews, Jr, Scott Brownley, Robert Costello, Nestor De Jesus, Michael Dougherty, Nicholas Evangelides, Sarah Keckley, Michael Kociolek, Mark LaPadula, Fidel Legorreta, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff, Brian Roney for leave to file excess pages INDIVIDUAL OFFICER DEFENDANTS' UNOPPOSED MOTION FOR LEAVE TO FILE EXCESS PAGES (Locke, Neha) (Entered: 01/03/2023)

RESPONSE by Lucy Parsons Labs, Daniel Ortiz, Derick Scruggs, Michael Williamsin Opposition to MOTION by Defendants Eduardo Almanza, Salvatore Aloisio, Theodore Andrews, Jr, Scott Brownley, Robert Costello, Nestor De Jesus, Michael Dougherty, Nicholas Evangelides, Sarah Keckley, Michael Kociolek, Mark LaPadula, Fidel Legorreta, David Magana, Caro 48 for leave to file excess pages. (Manes, Jonathan) (Entered: 01/03/2023)

REPLY by Eduardo Almanza, Salvatore Aloisio, Theodore Andrews, Jr, Scott Brownley, Robert Costello, Nestor De Jesus, Michael Dougherty, Nicholas Evangelides, Sarah Keckley, Michael Kociolek, Mark LaPadula, Fidel Legorreta, David Magana, Carol Maresso, Michael Matias, Joseph Merkel, Juan Perez, Dale Potter, Jr, Harsimran Powar, Scott Reiff, Brian Roney to response in opposition to motion, 49 (Locke, Neha) (Entered: 01/03/2023)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants David O'Neal Brown, City Of Chicago (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Sheehan, Michael) (Entered: 01/04/2023)

1

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2

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3

View on RECAP

ATTORNEY Appearance for Plaintiffs Lucy Parsons Labs, Daniel Ortiz, Derick Scruggs, Michael Williams by Elizabeth N. Mazur (Mazur, Elizabeth) (Entered: 01/05/2023)

MINUTE entry before the Honorable Ronald A. Guzman: The Individual Officer Defendants' motion for leave to file an oversize motion to dismiss 48, which Plaintiffs oppose 49, is denied. Defendants are, however, given leave, by 1/13/2023, to file a 35-page motion to dismiss, which, in the Court's view, should be sufficient to develop arguments appropriate for resolution at this stage. Defendants should prioritize their arguments accordingly. Plaintiffs' response shall not exceed the page length of the Individual Defendants' motion and shall be filed by 2/13/2023; any Reply shall be filed by 3/6/2023. The briefing schedule 47 on the motion to dismiss filed by the City of Chicago and Superintendent Brown is modified as follows: by 2/6/2023, Plaintiffs shall file a response of no more than 15 pages, addressing only the Rule 12(b)(1) Argument and Section V of the Rule 12(b)(6) Argument. Any reply on those topics shall be filed by 2/24/2023. The Court may direct additional briefing on that motion. The dates the Court previously set 37 for the parties to confer and file a joint initial status report and proposed discovery plan stand. The Court does not typically stay discovery during the pendency of motions to dismiss. Mailed notice. (kp, ) (Entered: 01/06/2023)

MOTION by Defendants Juan Perez, Eduardo Almanza, Dale Potter, Jr, Theodore Andrews, Jr, Salvatore Aloisio, Harsimran Powar, Robert Costello, Michael Matias, Scott Brownley, Nestor De Jesus, Nicholas Evangelides, Sarah Keckley, Scott Reiff, Mark LaPadula, Fidel Legorreta, David Magana, Carol Maresso, Joseph Merkel, Michael Kociolek, Brian Roney, Michael Dougherty to dismiss INDIVIDUAL DEFENDANTS' MOTION TO DISMISS (Locke, Neha) (Entered: 01/13/2023)

STATUS Report Joint Initial Status Report and Proposed Discovery Plan by Lucy Parsons Labs, Daniel Ortiz, Derick Scruggs, Michael Williams (Manes, Jonathan) (Entered: 01/20/2023)

ATTORNEY Appearance for Plaintiffs Lucy Parsons Labs, Daniel Ortiz, Derick Scruggs, Michael Williams by Daniel Massoglia (Massoglia, Daniel) (Entered: 01/25/2023)

MINUTE entry before the Honorable Ronald A. Guzman: The Court has reviewed the parties joint initial status report and proposed discovery plan and sets the following deadlines. Amendment of pleadings and joinder of parties is to be completed eight weeks before the close of fact discovery. Fact discovery shall close on 7/28/2023, except that discovery as to any Monell claims shall be bifurcated and stayed. Discovery supervision and scheduling and all discovery motions and discovery disputes, including requests for and entry of any protective orders, are referred to the magistrate judge without authority to extend the above fact discovery deadlines. The matter is also referred to the magistrate judge for any settlement proceedings or conferences. Mailed notice. (kp, ) (Entered: 01/26/2023)

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Young B. Kim for the purpose of holding proceedings related to and all discovery disputes without authority to extend the discovery cutoff date. The referral to the magistrate judge shall also include authority to conduct a settlement conference if deemed appropriate. Mailed notice. (kp, ) (Entered: 01/26/2023)

MINUTE entry before the Honorable Young B. Kim: Parties are to proceed with fact discovery (except on Monell claims) despite the pending motions to dismiss. Parties are ordered to adhere to the following written discovery schedule: (1) exchange Rule 26(a)(1) disclosures by February 10, 2023; (2) serve written discovery requests by February 17, 2023 (requests to admit may be timely served before the end of fact discovery); (3) serve answers to written discovery requests by March 17, 2023; (4) confer about the adequacy of the discovery responses by March 31, 2023; and (5) file a joint status report identifying each side's written discovery issues (must identify the specific interrogatories and requests to produce), along with the relevant written discovery responses as exhibits, by April 7, 2023. The court will not consider general objections to written discovery requests if the court must address and rule on written discovery disputes. If the parties do not have any disputed written discovery issues, a status report is not required. Pursuant to Rule of Evidence 502(d), this court orders that inadvertent disclosures of attorney-client privileged and attorney work materials will not constitute a waiver of the associated privilege. The court further orders that upon written notification (including emails) from the opposing side that an inadvertent disclosure has occurred, the party shall return and/or destroy the materials at issue or file a motion for a determination on the claimed privilege within seven calendar days of the written notification. Mailed notice (ec) (Entered: 01/26/2023)

Clarify

Clarify

Order on Motion to Clarify AND Order on Motion to Clarify

Extension of Time to File Response/Reply

Order on Motion for Extension of Time to File Response/Reply