Case: United States v. Chicago Baseball Holdings, LLC

COMPLAINT filed by United States of America; Jury Demand. (Attachments: # 1 Exhibit A: Seating Map, # 2 Exhibit B: Clubs and Group Seating, # 3 Exhibit C: Current and Planned Wheelchair Seating, # 4 Exhibit D: Non-Seating Elements)(Souza, Abraham) (Entered: 07/14/2022)

1 Exhibit A: Seating Map

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2 Exhibit B: Clubs and Group Seating

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3 Exhibit C: Current and Planned Wheelchair Seating

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4 Exhibit D: Non-Seating Elements

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CIVIL Cover Sheet (Souza, Abraham) (Entered: 07/14/2022)

DESIGNATION of Patrick Walter Johnson as U.S. Attorney for Plaintiff United States of America (Johnson, Patrick) (Entered: 07/14/2022)

CASE ASSIGNED to the Honorable Martha M. Pacold. Designated as Magistrate Judge the Honorable Heather K. McShain. Case assignment: Random assignment. (emc, )

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, )

ATTORNEY Appearance for Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC by John F. Kuenstler (Kuenstler, John) (Entered: 08/03/2022)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-19707605. (Jakubowski, Teresa) (Entered: 08/03/2022)

ATTORNEY Appearance for Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC by Mark Robert Filip (Filip, Mark) (Entered: 08/03/2022)

MINUTE entry before the Honorable Martha M. Pacold: Teresa Jakubowski's motion to appear pro hac vice 5 is granted. Mailed notice (cn). (Entered: 08/04/2022)

ATTORNEY Appearance for Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC by Teresa L Jakubowski (Jakubowski, Teresa) (Entered: 08/04/2022)

WAIVER OF SERVICE returned executed by United States of America. All Defendants. (Souza, Abraham) (Entered: 08/08/2022)

MINUTE entry before the Honorable Martha M. Pacold: The parties are directed to file an initial joint status report by 9/28/2022. (Attachments: # 1 Outline for the Initial Joint Status Report) (rao, ) (Entered: 08/12/2022)

ANSWER to Complaint by Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC(Filip, Mark) (Entered: 09/26/2022)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC (Filip, Mark) (Entered: 09/26/2022)

STATUS Report Joint Initial by United States of America (Souza, Abraham) (Entered: 09/28/2022)

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Heather K. McShain for the purpose of holding proceedings related to: discovery supervision and scheduling, to set a deadline to file amended pleadings, to set a dispositive motions schedule, and for settlement. (rao, ) (Entered: 09/30/2022)

MINUTE entry before the Honorable Heather K. McShain: This case has been referred to Magistrate Judge McShain for discovery supervision and scheduling, to set a deadline to file amended pleadings, to set a dispositive motions schedule, and for settlement. By 10/14/2022, the parties shall meet and confer and file a joint status report to include: (a) a proposed schedule for fact discovery; (b) a statement as to whether the parties anticipate ESI discovery and expert witness discovery; (c) a proposed deadline to file amended pleadings; (d) any other matters the parties with to raise with the Court. Mailed notice. (pk, ) (Entered: 10/11/2022)

STATUS Report Joint by United States of America (Souza, Abraham) (Entered: 10/14/2022)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 16 and enters the parties' proposed discovery schedule: Fed. R. Civ. P. 26(a)(1) disclosures to be exchanged by 10/31/2022; initial written discovery requests to be issued by 11/14/2022; all fact discovery be completed by 08/31/2023. Joint status report due on 12/21/2022 to update the Court on: (a) the progress of discovery; (b) the status of settlement discussions (if any); and (c) any other issues the parties wish to raise with the Court. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) if they would like the Court's assistance with settlement. Mailed notice. (pk, ) (Entered: 10/17/2022)

STATUS Report Joint by United States of America (Souza, Abraham) (Entered: 12/21/2022)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 18 which includes a short statement that parties exchanged initial Rule 26(a) disclosures and initial written discovery requests. Further joint status report due 02/28/2023 to update the Court on: (a) the status of discovery, including the progress of written discovery; (b) the state of settlement discussions, if any; and (c) any other matters the parties believe should be brought to the Court's attention. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) should they be interested in discussing settlement. The Court expects the parties' future status reports to include specific details as to the progress of discovery, including a detailed description of what discovery remains to be completed. Mailed notice. (pk, ) (Entered: 12/23/2022)

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)

STATUS Report (Joint) by United States of America (Johnson, Patrick) (Entered: 02/28/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 21 which reports parties responded to written discovery requests. Parties are discussing deficiencies in each other's responses. Defendants continue to produce documents. Plaintiff subpoenaed five third-party entities involved in the design and construction of Wrigley Field's 1060 Project. Parties indicate they will complete outstanding document production and document subpoenas between end of April and mid-May. Parties will begin depositions in late May to early June. Plaintiff plans to inspect Wrigley Field over the summer. Further joint status report updating the Court on the same items as in the instant status due 05/01/2023. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) should they be interested in discussing settlement. Mailed notice. (pk, ) (Entered: 03/01/2023)

STATUS Report (Joint) by Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC (Jakubowski, Teresa) (Entered: 05/01/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 23 which reports parties intend to supplement discovery responses and produce additional documents in the next several weeks. Plaintiff received documents from subpoenaed third parties and issued additional subpoenas. Parties now indicate completing written discovery by late June to mid-July and beginning depositions in August. Further joint status report updating the Court on the same items as in the instant status due 07/14/2023. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) should they be interested in discussing settlement. Mailed notice. (pk, ) (Entered: 05/02/2023)

MOTION by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC for protective order (Unopposed Motion Requesting Approval and Entry of Parties' Agreed Confidentiality Order) Presented before Magistrate Judge (Attachments: # 1 Exhibit 1 - Proposed Agreed Confidentiality Order with Exhibit A)(Jakubowski, Teresa) (Entered: 07/14/2023)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 07/14/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court is in receipt of defendants' unopposed motion for entry of an agreed confidentiality order 25 . The defendants' unopposed motion is taken under advisement. By 07/28/2023, defendant is to email the following to the proposed order inbox (Proposed_Order_McShain@ilnd.uscourts.gov): (1) a copy of the proposed confidentiality order; and (2) a redlined version of the proposed order showing any changes to the L.R. 26.2 model order. Mailed notice. (pk, ) (Entered: 07/24/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 26 which reports plaintiff supplemented its discovery responses and produced additional documents. Plaintiff continues to receive documents from subpoenaed parties. Parties have tentatively agreed to conduct the inspection of Wrigley Filed on 09/11/2023-09/12/2023. Parties anticipate filing a joint motion to extend the fact discovery deadline to ensure defendants have sufficient time to review plaintiff's supplemental discovery responses and document productions prior to conducting depositions. Further joint status report updating the Court on the same items as in the instant status due 09/18/2023. Parties should file any motion to extend the fact discovery deadline prior to the current deadline of 08/31/2023. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) should they be interested in discussing settlement. Mailed notice. (pk, ) (Entered: 07/24/2023)

MINUTE entry before the Honorable Heather K. McShain: The defendants' unopposed motion for entry of an agreed confidentiality order 25 is granted. Enter order. Mailed notice. (pk, ) (Entered: 08/03/2023)

AGREED CONFIDENTIALITY ORDER. Signed by the Honorable Heather K. McShain on 8/3/2023. Mailed notice. (pk, ) (Entered: 08/03/2023)

MOTION by Plaintiff United States of America for extension of time to complete discovery JOINT AGREED MOTION Presented before Magistrate Judge (Souza, Abraham) (Entered: 08/28/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint agreed motion to extend the fact discovery deadline until 12/22/2023 31 . Parties explain that additional time is needed to review the thousands of documents produced, schedule depositions, and inspect Wrigley Field. In light of the parties' diligence in pursuing and completing discovery, and the fact that this is the parties' first request to extend the fact discovery deadline, the parties' motion 31 is granted. Fact discovery is extended until 12/22/2023. This is a firm deadline, and any future requests for extensions will need to be presented in a formal motion and will not be granted absent good cause. The joint status report due 09/18/2023 stands 28 . Mailed notice. (pk, ) (Entered: 08/29/2023)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 09/18/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 33 which reports parties inspected Wrigley Field and issued additional subpoenas to the City of Chicago. Defendants have completed the bulk of their document productions and are working to produce supplemental documents along with a privilege log. Plaintiff intends to issue deposition notices to defendants and deposition subpoenas to third parties in the next three to four weeks. Parties are placed on notice that the Court has updated its standing order on discovery motion requirements. This update makes changes to the parties' meet-and-confer requirements. In advance of the filing of any discovery motion, parties are directed to review Magistrate Judge McShain's updated requirements for discovery motions (available on the Court's website at www.ilnd.uscourts.gov by selecting the link for Magistrate Judge McShain and then the link for " Discovery Motion Requirements "). Moving forward, any motion that does not comply with the Court's standing order will be considered unripe for the Court's consideration. Further joint status report updating the Court on the same items as in the instant status due 10/18/2023. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) should they be interested in discussing settlement. Mailed notice (ags) (Entered: 09/19/2023)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 10/18/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 35 which reports the City of Chicago responded to the parties' subpoenas and the parties are currently reviewing the City's initial document production. Further joint status report updating the Court on the same items as in the instant status due 12/08/2023. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) should they be interested in discussing settlement. Mailed notice (ec) (Entered: 10/20/2023)

MOTION by Plaintiff United States of America for discovery (Motion to Deny Privilege Claim) Presented before Magistrate Judge (Johnson, Patrick) (Entered: 11/09/2023)

SEALED DOCUMENT by Plaintiff United States of America (Johnson, Patrick) (Entered: 11/09/2023)

SEALED DOCUMENT by Plaintiff United States of America (No. 2) (Johnson, Patrick) (Entered: 11/09/2023)

MINUTE entry before the Honorable Heather K. McShain: Plaintiff's motion for discovery seeking to deny defendants' claim of privilege as to two documents 37 is entered and continued, and plaintiff's unopposed request to file the two documents under seal is granted (and the Court notes that the documents have already been filed under seal 38, 39 ). Plaintiff's memorandum in support of its motion is due 11/29/2023, and defendants' response is due 12/13/2023. No reply to be filed without leave of the Court. Once the Court has reviewed the briefs, it will decide whether it can rule on the papers or whether a motion hearing is required. Mailed notice. (pk, ) (Entered: 11/13/2023)

MEMORANDUM by United States of America in support of motion for discovery 37 REDACTED (Attachments: # 1 Exhibit A: Excerpt From Def. Answers to Interrogatories, # 2 Exhibit B: Jan. 2013 Letter, # 3 Exhibit C: McGuire Emails, # 4 Exhibit D: Mar. 2013 Email)(Souza, Abraham) (Entered: 11/29/2023)

MOTION by Plaintiff United States of America to seal unredacted brief in support of motion for discovery (Dkt. 37) Presented before Magistrate Judge (Souza, Abraham) (Entered: 11/29/2023)

SEALED EXHIBIT by Plaintiff United States of America UNREDACTED MEMORANDUM regarding MOTION by Plaintiff United States of America for discovery (Motion to Deny Privilege Claim) Presented before Magistrate Judge 37 (Souza, Abraham) (Entered: 11/29/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court grants plaintiff's motion to seal 42 its brief in support of its motion to deny defendants' privilege claim 37 . The Court observes that plaintiff already filed a sealed version on the docket 43 . The Court also acknowledges that along with a redacted version of its brief 41, plaintiff filed four supporting exhibits which plaintiff does not appear to request be sealed. [41-141-4] Mailed notice. (pk, ) (Entered: 11/30/2023)

ATTORNEY Appearance for Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC by Donna M. Welch (Welch, Donna) (Entered: 12/06/2023)

ATTORNEY Appearance for Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC by Theresa N. Horan (Horan, Theresa) (Entered: 12/06/2023)

ATTORNEY Appearance for Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC by Daniel Richard Murdock (Murdock, Daniel) (Entered: 12/06/2023)

MOTION by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC to compel Chicago Cubs' Motion to Compel Production of Documents from the City of Chicago Presented before Magistrate Judge (Attachments: # 1 Exhibit A - Subpoena, # 2 Exhibit B - Parties' Email Exchange, # 3 Exhibit C - City Ordinance)(Welch, Donna) (Entered: 12/06/2023)

1 Exhibit A - Subpoena

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2 Exhibit B - Parties' Email Exchange

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3 Exhibit C - City Ordinance

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Local Rule 37.2 Statement STATEMENT by Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC (Horan, Theresa) (Entered: 12/06/2023)

ATTORNEY Appearance for Respondent CITY OF CHICAGO by Jackson P. Garrity (Garrity, Jackson) (Entered: 12/07/2023)

MOTION by Respondent CITY OF CHICAGO for leave to file Response to Defendant's Motion to Compel Production of Documents Presented before Magistrate Judge (Garrity, Jackson) (Entered: 12/07/2023)

STATUS Report JOINT STATUS REPORT by Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC Presented before District Judge (Filip, Mark) (Entered: 12/08/2023)

MINUTE entry before the Honorable Heather K. McShain: Defendants' motion to compel 48 production of documents from third-party City of Chicago is entered and continued. Respondent City of Chicago filed a motion 51 for leave to file a response, requesting until 12/22/2023 to file a response to defendants' motion. Fact discovery is set to close on 12/22/2023. 32 In their latest joint status report 52, the parties indicate that although they "expect to substantially complete party fact discovery" by the current deadline, there are several outstanding issues "primarily relating to third-party discovery that will necessitate a forthcoming joint agreed motion for a modest extension of fact discovery." 52 1. The Court grants the City's motion 51 for leave to file a response to defendants' motion to compel 48 ; respondent City of Chicago's response due 12/22/2023. No reply to be filed without leave of the Court. Once the Court has reviewed the briefs, it will decide whether it can rule on the papers or whether a motion hearing is required. Mailed notice. (pk, ) (Entered: 12/11/2023)

MOTION by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC for extension of time JOINT MOTION FOR AN EXTENSION OF FACT DISCOVERY Presented before District Judge (Filip, Mark) (Entered: 12/11/2023)

MINUTE entry before the Honorable Heather K. McShain: Before the Court is the parties' joint motion for an extension of the fact discovery deadline 54 . The parties have incorrectly presented their motion before the District Judge; this case has been referred to the Magistrate Judge for, among other things, "discovery supervision and scheduling." [ 14, 15 ] Requests to extend discovery deadlines should be addressed to Judge McShain, not the District Judge. The parties' motion indicates that they have been working diligently and cooperatively to complete fact discovery and expect to substantially complete party fact discovery by the current 12/22/2023 deadline. The parties acknowledge that limited additional party discovery may be required depending on the Court's ruling on the privilege issue the parties are currently briefing 37 . The parties report several outstanding issues concerning third-party discovery, including depositions that cannot occur until January 2024, productions that are still forthcoming, and discovery involving defendants' recent motion to compel documents from third-party City of Chicago 48 . The parties assert that a short extension for fact discovery will not impact the case's current schedule because the Court has not yet set a deadline for expert discovery, dispositive motions, or trial. The parties request an extension until "the later of February 20, 2024, or 30 days after the City of Chicago completes any document production the Court may order in connection with the defendants' pending motion to compel." For the reasons stated in the motion 54, the Court finds good cause to extend the fact discovery deadline 32 until 02/20/2024. Joint status report due 01/12/2024 to update the Court on the progress of discovery. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) if they would like the Court's assistance with settlement. Mailed notice. (pk, ) (Entered: 12/13/2023)

SEALED RESPONSE by Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC to MOTION by Plaintiff United States of America for discovery (Motion to Deny Privilege Claim) Presented before Magistrate Judge 37 CHICAGO CUBS' RESPONSE TO UNITED STATES' MOTION TO DENY DEFENDANTS' PRIVILEGE CLAIM (Attachments: # 1 Exhibit 1)(Welch, Donna) (Entered: 12/13/2023)

RESPONSE by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC to motion for discovery 37 REDACTED VERSION OF DKT 56-CHICAGO CUBS' RESPONSE TO UNITED STATES MOTION TO DENY DEFENDANTS' PRIVILEGE CLAIM (Attachments: # 1 Exhibit 1)(Welch, Donna) (Entered: 12/13/2023)

MOTION by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC to seal document sealed response, 56 CHICAGO CUBS' MOTION TO SEAL UNREDACTED BRIEF Presented before Magistrate Judge (Welch, Donna) (Entered: 12/13/2023)

MINUTE entry before the Honorable Heather K. McShain: The Court grants defendants' motion to seal 58 their brief in opposition to plaintiffs' motion to deny defendants' claim of privilege 37 and accompanying exhibit. The Court observes that defendants already filed sealed versions of their response brief and supporting exhibit on the docket. [56, 56-1]. Plaintiff's motion to deny privilege claim 37 is now fully briefed and under advisement. Parties are reminded no reply is to be filed without leave of the Court 40 . Mailed notice. (pk, ) (Entered: 12/14/2023)

ATTORNEY Appearance for Respondent CITY OF CHICAGO by Jennifer Zlotow (Zlotow, Jennifer) (Entered: 12/18/2023)

MOTION by Plaintiff United States of America for leave to file reply in support of motion to deny privilege claim Presented before Magistrate Judge (Attachments: # 1 Exhibit proposed reply in support of motion to deny privilege claim)(Souza, Abraham) (Entered: 12/20/2023)

1 Exhibit proposed reply in support of motion to deny privilege claim

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MINUTE entry before the Honorable Heather K. McShain: The Court grants plaintiff's motion 61 for leave to file a reply in support of its motion to deny defendants' privilege claim 37 . The Court observes that plaintiff has already filed its reply brief. [61-1] The motion is now fully briefed and under advisement. Mailed notice. (pk, ) (Entered: 12/21/2023)

RESPONSE by CITY OF CHICAGO in Opposition to MOTION by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC to compel Chicago Cubs' Motion to Compel Production of Documents from the City of Chicago Presented 48 and Motion to Quash (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Zlotow, Jennifer) (Entered: 12/22/2023)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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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 12/28/2023: Mailed notice. (tg, ) (Entered: 12/29/2023)

MOTION by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC for leave to file REPLY IN SUPPORT OF ITS MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND A RESPONSE TO CITY OF CHICAGO'S MOTION FOR ORDER QUASHING SUBPOENA Presented before Magistrate Judge (Attachments: # 1 Reply, # 2 Exhibit A to Reply)(Welch, Donna) (Docket Text modified by Clerk's Office) Modified on 1/2/2024 (rc, ). (Entered: 01/02/2024)

MOTION by Respondent CITY OF CHICAGO for leave to file Reply in Support of its Motion for Entry of Order Quashing Subpoena Presented before Magistrate Judge (Garrity, Jackson) (Entered: 01/04/2024)

Entered in error. (pk, ) Modified on 1/5/2024 (pk, ). (Entered: 01/05/2024)

MINUTE entry before the Honorable Heather K. McShain: The Court grants defendants' motion 65 for leave to file a reply in support of its motion to compel document production 48 . The Court also grants defendants' request 65 to file a response to third-party City of Chicago's motion to quash the subpoena that is the subject of the pending motion to compel. On 12/22/2023, City of Chicago filed its opposition 63 to defendants' motion to compel document production 48 and included within that filing a motion to quash the subject subpoena. See 63 612. Defendants point out that they have not yet had the opportunity to address the arguments contained in the City of Chicago's response and new motion to quash. The Court observes that defendants have already filed their combined reply/response on the docket [65-1]. Defendants' motion to compel 48 and City of Chicago's motion to quash 63 are now fully briefed and under advisement. Due to a clerical error, the Minute Order entered at 67 is to be removed from the docket. Mailed notice. (pk, ) (Entered: 01/05/2024)

MINUTE entry before the Honorable Heather K. McShain: The Court grants third-party City of Chicago's motion for leave to file a reply 66 to its motion to quash the subpoena, which the Court notes was contained in the City's response 63 to defendants' motion to compel 48 . City of Chicago's reply is due 01/12/2024 and must not exceed five pages. Mailed notice. (pk, ) (Entered: 01/08/2024)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 01/12/2024)

MOTION by Respondent CITY OF CHICAGO for extension of time to file response/reply as to order on motion for leave to file,, text entry, 69 Reply in Support of Motion to Quash Subpoena Presented before Magistrate Judge (Garrity, Jackson) (Entered: 01/12/2024)

REPLY by CITY OF CHICAGO to response in opposition to motion, 63 (Zlotow, Jennifer) (Entered: 01/16/2024)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 70, which reports that the parties have completed a deposition of a Cubs fact witness and a Rule 30(b)(6) deposition of the Cubs. The parties indicate that the final Cubs witness deposition is scheduled for 01/30/2024. The parties anticipate conducting several additional depositions of third-party witnesses, including a third-party accessibility consultant, two third-party architects, and a witness from the City of Chicago. The parties state that they are working diligently to schedule all depositions prior to the current 02/20/2024 fact discovery deadline, "subject to third party witness availability." "The parties request permission to alert the Court if they conclude that one or more of the remaining third party depositions will need to take place after February 20, 2024," either based on witness availability or the outcome of the pending motions. If the parties determine that they are unable to complete discovery by the 02/02/2024 deadline, they shall file a formal motion requesting an extension of the discovery deadline and establishing good cause for the extension. Further joint status report due 02/12/2024 to update the Court on the progress of discovery. The Court also grants third-party City of Chicago's unopposed motion 71 for an extension of time to file its reply in support of its motion to quash. The Court deems the City's reply 72 timely filed. Mailed notice. (pk, ) (Entered: 01/23/2024)

MINUTE entry before the Honorable Heather K. McShain: The Court's minute order dated 01/23/2024 73 is amended as follows: The Court has reviewed the parties' joint status report 70, which reports that the parties have completed a deposition of a Cubs fact witness and a Rule 30(b)(6) deposition of the Cubs. The parties indicate that the final Cubs witness deposition is scheduled for 01/30/2024. The parties anticipate conducting several additional depositions of third-party witnesses, including a third-party accessibility consultant, two third-party architects, and a witness from the City of Chicago. The parties state that they are working diligently to schedule all depositions prior to the current 02/20/2024 fact discovery deadline, "subject to third party witness availability." "The parties request permission to alert the Court if they conclude that one or more of the remaining third party depositions will need to take place after February 20, 2024," either based on witness availability or the outcome of the pending motions. If the parties determine that they are unable to complete discovery by the 02/20/2024 deadline, they shall file a formal motion requesting an extension of the discovery deadline and establishing good cause for the extension. Further joint status report due 02/12/2024 to update the Court on the progress of discovery. The Court also grants third-party City of Chicago's unopposed motion 71 for an extension of time to file its reply in support of its motion to quash. The Court deems the City's reply 72 timely filed.Mailed notice. (pk, ) (Entered: 01/23/2024)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 02/12/2024)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 75, which reports that the parties have completed depositions of the final Cubs fact witness and a third-party architect. The United States has issued a subpoena to depose another third-party architect, John Scherer, on 02/15/2024, but the United States is working to determine whether Scherer is available on that day. The parties also report that there are four third-party depositions (McGuire, Izzo, Roubik, and Zafiris) that remain to be completed but that relate to and depend on the Court's rulings on the pending discovery motions [ 37, 48, 63 ]. And the United States indicates that it has reserved the right to reopen the deposition of the final Cubs fact witness, Carl Rice, for the limited purpose of asking about the matters subject to the Cubs' privilege claim. "To accommodate witness availability and depending on the timing of the Court's rulings," the parties state that they may seek a modest extension of third-party fact discovery to complete these depositions. The parties agree that party fact discovery is complete, subject only to the potential limited reopening of Rice's deposition. The Court will refrain from setting the next joint status report deadline at this time. Mailed notice. (pk, ) (Entered: 02/13/2024)

MOTION by Plaintiff United States of America for extension of time to complete third-party fact discovery (JOINT AGREED MOTION) Presented before Magistrate Judge (Souza, Abraham) (Entered: 02/16/2024)

MINUTE entry before the Honorable Heather K. McShain: Before the Court is the parties' joint motion 77 for an extension of time to complete third-party fact discovery. The parties agree that party fact discovery is complete (with one potential exception) but report that there are five third-party depositions that remain to be completed. The parties indicate that four of these depositions relate to and depend upon pending discovery motions [ 37, 48, 63 ]. Accordingly, the parties request that the Court extend the fact discovery deadline until the later of 30 days after the Court issues its ruling on the parties' pending discovery motions or 30 days after the City of Chicago completes any document production the Court may order in connection with the pending motion to compel. For the reasons stated in the motion, the Court grants the parties' joint motion 77 and the deadline will be entered after the Court issues its rulings on the pending discovery motions in line with the parties' request. Mailed notice. (pk, ) (Entered: 02/16/2024)

MINUTE entry before the Honorable Heather K. McShain: For the reasons set forth in the corresponding Order, plaintiff's motion to deny defendants' privilege claim 37 is granted. The Clerk of Court is directed to file this Order under seal, and the Order shall remain sealed for 14 days from the date of this Order or until any appeal of this Order to the District Judge shall be resolved, whichever is later. After 14 days from the date of this Order or until any appeal of this Order is resolved, whichever is later, the Clerk of Court is also directed to unseal the documents filed at Docket Entries 38, 39, 43, 56, and 56-1. (pk, ) (Entered: 03/01/2024)

SEALED ORDER. Signed by the Honorable Heather K. McShain on 3/1/2024. (pk, ) (Entered: 03/01/2024)

MINUTE entry before the Honorable Heather K. McShain: Telephonic motion hearing on defendant Chicago Cubs' Motion to Compel Production of Documents from the City of Chicago 48 and the City of Chicago's motion to quash 63 set for 04/03/2024 at 10:00 a.m. To participate in the telephonic motion hearing, the dial-in number is 888-684-8852, followed by access code 8623687#. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice. (pk, ) (Entered: 03/28/2024)

MINUTE entry before the Honorable Heather K. McShain: Due to a scheduling conflict for third-party subpoena recipient counsel, and by agreement of the parties, telephonic motion hearing on defendant Chicago Cubs' Motion to Compel Production of Documents from the City of Chicago 48 and the City of Chicago's motion to quash 63 set for 04/03/2024 is reset to 04/12/2024 at 1:00 p.m. Dial-in information remains the same 81 . Mailed notice. (pk, ) (Entered: 04/02/2024)

MINUTE entry before the Honorable Heather K. McShain: In response to parties' email, telephonic motion hearing on defendant Chicago Cubs' Motion to Compel Production of Documents from the City of Chicago 48 and the City of Chicago's motion to quash 63 set for 04/12/2024 is reset to 04/26/2024 at 10:00 a.m. Dial-in information remains the same 81 . Mailed notice. (pk, ) (Entered: 04/12/2024)

MINUTE entry before the Honorable Heather K. McShain: Clerk of Court is directed to unseal the documents filed at Docket Entries 80 38, 39, 43, 56, and 56-1. Mailed notice. (pk, ) (Entered: 04/12/2024)

MINUTE entry before the Honorable Heather K. McShain: Status Report due by 5/31/2024.The parties' joint motion made via email to chambers on 04/25/2024, to adjourn all outstanding discovery motions and stay discovery is granted due to the parties settlement efforts. Defendant Chicago Cubs' Motion to Compel Production of Documents from the City of Chicago 48 and the City of Chicago's motion to quash 63 are denied without prejudice and discovery is stayed. The telephonic motion hearing set for 04/25/2024 83 is also stricken. By 05/31/2024, the parties are to file a joint status report with an update on settlement. Mailed notice. (pk, ) (Entered: 04/25/2024)

NOTICE by Theresa N. Horan of Change of Address (Horan, Theresa) (Entered: 04/29/2024)

NOTICE by Daniel Richard Murdock of Change of Address (Murdock, Daniel) (Entered: 04/29/2024)

NOTICE by Donna M. Welch of Change of Address (Welch, Donna) (Entered: 04/29/2024)

NOTICE by Mark Robert Filip of Change of Address (Filip, Mark) (Entered: 04/29/2024)

MOTION by Defendants Chicago Baseball Holdings, LLC, Chicago Cubs Baseball Club, LLC, WF Master Tenant, LLC, Wrigley Field Holdings, LLC to withdraw MOTION TO WITHDRAW ATTORNEY APPEARANCE-Daniel Murdock Presented before District Judge (Welch, Donna) (Entered: 05/21/2024)

MINUTE entry before the Honorable Martha M. Pacold: Motion to Withdraw Attorney Appearance, 90, is granted. Attorney Daniel Richard Murdock terminated. Mailed notice. (lxk, ) (Entered: 05/23/2024)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 05/31/2024)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 92, which reports on the status of the parties' settlement efforts and outlines the parties' plan to reach an agreement and resolve this case. The parties jointly request that discovery remain stayed to give them additional time to work towards a final written settlement agreement and consent decree. The parties do not indicate exactly how much additional time they require. By 08/01/2024, the parties are to file a joint status report with an update on settlement. Mailed notice. (pk, ) (Entered: 06/03/2024)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 08/01/2024)

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report 94, updating that the parties continue to make progress with their settlement negotiations. Another joint status report is due by 10/01/2024 to update on settlement. Mailed notice. (pk, ) (Entered: 08/01/2024)

STATUS Report JOINT by United States of America Presented before Magistrate Judge (Souza, Abraham) (Entered: 10/01/2024)

GENERAL ORDER 24-0028 Daniel P. Mclaughlin has entered on duty as a Magistrate Judge for the Northern District of Illinois, with a duty station in Chicago, Illinois, effective September 30, 2024; and Internal Operating Procedure 17 provides for the creation of an initial calendar for a newly appointed magistrate judge; therefore It is hereby ordered that on October 1, 2024, the attached list of civil consent cases and civil referrals are hereby reassigned to form the initial calendar of the Honorable Daniel P. Mclaughlin; and It is furthered ordered that on October 1, 2024, the Clerk of Court is to add Magistrate Judge McLaughlin to the case assignment system so that he receives a full share of new case assignments; and It is furthered ordered pursuant to Local Rule 72.1 that Magistrate Judge Mclaughlin is to become the designated magistrate judge in any pending civil or criminal cases where Magistrate Judge Sunil R. Harjani was the designated magistrate judge and future judicial action is necessary; and It is further ordered pursuant to Local Rule 73.1 (e), the attached list of civil cases where the parties previously consented to proceed before the magistrate judge, pursuant to Local Rule 72.1, the parties may object within 21 days of reassignment. If a timely objection is filed by any party, the case will be reassigned to the district judge before whom it was last pending; and It is further ordered that any civil case that has been reassigned pursuant to this Order will not be randomly reassigned to create the initial calendar of a new magistrate judge for twelve months from the date of this Order; and It is further ordered that, unless otherwise ordered by Magistrate Judge McLaughlin, all hearing dates, deadlines, and schedules set by the magistrate judges in the attached list of cases are to remain in effect. Signed by Honorable Virginia M. Kendall on 9/30/24.(lw, ) (Entered: 10/02/2024)

MINUTE entry before the Honorable Daniel P McLaughlin: This case has been referred to Judge McLaughlin for discovery supervision and scheduling, to set a deadline to file amended pleadings, to set a dispositive motions schedule, and for settlement. The Court has reviewed the parties' joint status report 96 . The parties advise that they anticipate that they will reach final agreement and be in a position to seek entry of the consent decree by the District Court by 11/1/24. In light of the parties' settlement progress, discovery shall remain stayed. The parties are to file a further joint status report on settlement no later than 11/1/24. Mailed notice(maf) (Entered: 10/07/2024)