Case: Hilliard v. Hughes

Hilliard et al. v. Hughes

Hilliard et al. v. Hughes et al.

COMPLAINT (Class Action) filed by Shawn Eagan, Jasmine (Joseph) Herman, Keyshawn Nichols, Allen Brown, Jr, Andre Hilliard, Byron Porter, Derrick Macklin, David Hughes, Irving Madden, James Reed, Patrice Daniels, Tyran (Tiffany) Hall, Nickolas Garcia, David Mason, Victay Cooper-Voss, Charles Kucinsky, James Wright, Cordell Sanders, Afton Ferris; Filing fee $ 405, receipt number AILNDC-23354092.(Schmetterer, Kenneth) (Entered: 04/16/2025)

CIVIL Cover Sheet (Schmetterer, Kenneth) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Kenneth L. Schmetterer (Schmetterer, Kenneth) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Reema Mukesh Holz (Holz, Reema) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Constance Iris Du (Du, Constance) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Paulina M. Starostka (Starostka, Paulina) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Ana Condes (Condes, Ana) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Aima Mori (Mori, Aima) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Jessica Gingold, Equip for Equality (Gingold, Jessica) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Amanda C Antholt (Antholt, Amanda) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Nicole Rae Schult (Schult, Nicole) (Entered: 04/16/2025)

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Sophia Ruth Lau (Lau, Sophia) (Entered: 04/16/2025)

CASE ASSIGNED to the Honorable April M. Perry. Designated as Magistrate Judge the Honorable Gabriel A. Fuentes. Case assignment: Random assignment. (Civil Category 1). (txd, )

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. (txd, )

ATTORNEY Appearance for Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright by Marcus Terrell Owens (Owens, Marcus) (Entered: 05/27/2025)

ATTORNEY Appearance for Defendant Latoya Hughes by Aaron Talen Dozeman (Dozeman, Aaron) (Entered: 06/06/2025)

MOTION by Defendant Latoya Hughes to stay (opposed) (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit)(Dozeman, Aaron) (Entered: 06/06/2025)

NOTICE of Motion by Aaron Talen Dozeman for presentment of motion to stay 15 before Honorable April M. Perry on 6/18/2025 at 10:00 AM. (Dozeman, Aaron) (Entered: 06/06/2025)

ATTORNEY Appearance for Defendant Latoya Hughes by R. Douglas Rees (Rees, R.) (Entered: 06/09/2025)

MINUTE entry before the Honorable April M. Perry: The Court acknowledges receipt of Defendant's motion to stay 15, and adopts the briefing schedule proposed by the parties. Plaintiff's response is due 6/27/2025, and Defendant's reply is due 7/11/2025. This matter is set for status 7/17/2025 at 10:00 a.m. in person in Courtroom 1725. The Court strikes the motion presentment date of 6/18/2025. Mailed notice. (jcc,) (Entered: 06/09/2025)

RESPONSE by Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wrightin Opposition to MOTION by Defendant Latoya Hughes to stay (opposed) 15 (Schmetterer, Kenneth) (Entered: 06/27/2025)

REPLY by Latoya Hughes to MOTION by Defendant Latoya Hughes to stay (opposed) 15, response in opposition to motion, 19 (Dozeman, Aaron) (Entered: 07/11/2025)

MINUTE entry before the Honorable April M. Perry: Motion hearing held 7/17/2025. Defendant's motion to stay 15 is denied, for the reasons stated in Court. Defendants are to answer or otherwise plead in response to the complaint by 8/18/2025. Mailed notice. (jcc,) (Entered: 07/17/2025)

MOTION by Defendant Latoya Hughes for extension of time to file answer regarding complaint, 1 (unopposed) (Dozeman, Aaron) (Entered: 08/14/2025)

NOTICE of Motion by Aaron Talen Dozeman for presentment of motion for extension of time to file answer 22 before Honorable April M. Perry on 8/21/2025 at 10:00 AM. (Dozeman, Aaron) (Entered: 08/14/2025)

MINUTE entry before the Honorable April M. Perry: Motion for extension of time 22 is granted. Defendant's deadline to answer or otherwise plead to the complaint is extended to 9/5/2025. There is no need for the parties to appear at the motion hearing scheduled for 8/21/2025. Mailed notice. (jcc,) (Entered: 08/15/2025)

MOTION by Defendant Latoya Hughes to stay (opposed) (Attachments: # 1 Exhibit)(Dozeman, Aaron) (Entered: 09/05/2025)

NOTICE of Motion by Aaron Talen Dozeman for presentment of motion to stay 25 before Honorable April M. Perry on 9/10/2025 at 10:00 AM. (Dozeman, Aaron) (Entered: 09/05/2025)

MINUTE entry before the Honorable April M. Perry: Motion hearing held 9/10/2025 on Defendant's motion to stay 25 . For the reasons stated in court, the motion to stay is denied. Defendant is to answer or otherwise plead in response to the complaint by 10/1/2025. In the event that a motion to dismiss is filed, the parties are asked to submit a proposed briefing schedule. The parties are also asked to submit by 10/1/2025 a proposed discovery plan. Mailed notice. (jcc,) (Entered: 09/10/2025)

Parties Joint Proposed Briefing Schedule and Initial Discovery Plan by Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright (Schmetterer, Kenneth) (Entered: 10/01/2025)

MINUTE entry before the Honorable April M. Perry: The Court appreciates the proposed briefing schedule submitted by the parties 28 . Defendant to file its motion to dismiss on 10/2/2025. Response to be filed by 10/30/2025; reply by 11/13/2025. This case is referred to the Magistrate Judge for discovery supervision, including the authority to set, adjust, and extend all deadlines, and to conduct a settlement conference if requested by the parties. Mailed notice. (jcc,) (Entered: 10/02/2025)

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Gabriel A. Fuentes for the purpose of holding proceedings related to: Discovery Supervision, including the authority to set, adjust, and extend all deadlines, and to conduct a settlement conference if requested by the parties. (jcc,) Mailed notice. (Entered: 10/02/2025)

MINUTE entry before the Honorable Gabriel A. Fuentes: This matter coming before the magistrate judge on referral (doc. # 30 ) for discovery supervision and settlement, the Court has reviewed the parties' proposed discovery plan (doc. # 28 ) and sets the discovery schedule as follows: Rule 26(a)(1) disclosures to be issued on or before 10/30/25; initial written discovery to be issued by 10/31/25; close of fact discovery by 9/18/26. The Court defers setting an expert discovery schedule until nearer the close of fact discovery. The parties are further directed to review the Court's Standing Order for Civil Cases Before Magistrate Judge Fuentes (including its advisory Appendix), available on the Court's website. A joint written status report on discovery progress and settlement is due by noon on 1/5/26. If the parties at any time decide they wish to engage in a settlement conference, they may contact the courtroom deputy, Lauren Knight, at 312-818-6514. Mailed notice. (lxk, ) (Entered: 10/02/2025)

MOTION by Defendant Latoya Hughes to dismiss for lack of jurisdiction Presented before District Judge, MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Latoya Hughes Presented before District Judge (Dozeman, Aaron) (Entered: 10/02/2025)

MEMORANDUM by Latoya Hughes in support of motion to dismiss/lack of jurisdiction,, Motion to Dismiss for Failure to State a Claim, 32 (Dozeman, Aaron) (Entered: 10/02/2025)

MOTION by Attorney Marcus Owens to withdraw as attorney for Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright. No party information provided Presented before District Judge (Owens, Marcus) (Entered: 10/14/2025)

MINUTE entry before the Honorable April M. Perry: Motion to withdraw as attorney for Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright 34 is granted. Mailed notice. (jcc,) (Entered: 10/15/2025)

MOTION by Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright for extension of time to file response/reply (Unopposed) Presented before District Judge (Schmetterer, Kenneth) (Entered: 10/23/2025)

NOTICE of Motion by Kenneth L. Schmetterer for presentment of motion for extension of time to file response/reply, 36 before Honorable April M. Perry on 10/28/2025 at 10:00 AM. (Schmetterer, Kenneth) (Entered: 10/23/2025)

MINUTE entry before the Honorable April M. Perry: Motion for extension of time 36 is granted, and the court adopts the parties' modified briefing schedule: Plaintiffs to respond to Defendant's Motion to Dismiss by 11/6/2025; Defendant to file a reply brief by 11/20/2025. There is no need for the parties to appear at the motion hearing scheduled for 10/28/2025. Mailed notice. (jcc,) (Entered: 10/24/2025)

MOTION by Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright for leave to file excess pages Unopposed Motion for Leave to File Brief of up to Thirty Pages in Response to Defendant's Motion to Dismiss Presented before District Judge (Attachments: # 1 Exhibit Plaintiffs' Response to Motion to Dismiss)(Schmetterer, Kenneth) (Entered: 11/06/2025)

MINUTE entry before the Honorable April M. Perry: Motion for leave to file brief of up to thirty pages 39 is granted. Plaintiffs are directed to file their Response to the Motion to Dismiss, which may be up to 30 pages in length, as a separate docket entry within two business days. Mailed notice. (jcc,) (Entered: 11/07/2025)

RESPONSE by Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wrightin Opposition to MOTION by Defendant Latoya Hughes to dismiss for lack of jurisdiction Presented before District Judge MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Latoya Hughes Presented before District Judge 32 Plaintiffs' Response to Motion to Dismiss (Schmetterer, Kenneth) (Entered: 11/07/2025)

MOTION by Defendant Latoya Hughes for extension of time to file response/reply (unopposed) Presented before District Judge (Dozeman, Aaron) (Entered: 11/19/2025)

NOTICE of Motion by Aaron Talen Dozeman for presentment of motion for extension of time to file response/reply 42 before Honorable April M. Perry on 11/25/2025 at 10:00 AM. (Dozeman, Aaron) (Entered: 11/19/2025)

MINUTE entry before the Honorable April M. Perry: Motion for extension of time 42 is granted. Defendant's deadline to file a reply to the motion to dismiss is extended to 11/26/2025. There is no need for the parties to appear at the motion hearing scheduled for 11/25/2025. Mailed notice. (jcc,) (Entered: 11/20/2025)

REPLY by Latoya Hughes to response in opposition to motion,, 41, MOTION by Defendant Latoya Hughes to dismiss for lack of jurisdiction Presented before District Judge MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Latoya Hughes Presented before District Judge 32 (Dozeman, Aaron) (Entered: 11/26/2025)

STATUS Report Joint by Andre Hilliard Presented before Magistrate Judge (Schult, Nicole) (Entered: 01/05/2026)

MINUTE entry before the Honorable Gabriel A. Fuentes: On review of the parties' joint status report (doc. # 46 ), the Court makes no adjustment to the 9/18/26 fact discovery cutoff. The next joint written status report on discovery progress and settlement status is due by noon on 3/25/26. If the parties at any time decide they wish to engage in a settlement conference, they may contact the courtroom deputy, Jannette Nunez, at 312-818-6514 to initiate scheduling. Mailed notice. (jn,) (Entered: 01/07/2026)

MOTION by Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright for leave to file Plaintiffs' Unopposed Motion for Leave to file Brief Surreply to Defendant LaToya Hughes' Motion to Dismiss Reply Presented before District Judge (Attachments: # 1 Exhibit A)(Schmetterer, Kenneth) (Entered: 01/22/2026)

NOTICE of Motion by Kenneth L. Schmetterer for presentment of motion for leave to file,, 48 before Honorable April M. Perry on 1/29/2026 at 10:00 AM. (Schmetterer, Kenneth) (Entered: 01/22/2026)

MINUTE entry before the Honorable April M. Perry: Unopposed motion to file surreply to motion to dismiss 48 is granted. The Court requests that the surreply promptly be filed as a separate docket entry. The Court strikes the motion presentment date of 1/29/2026. Mailed notice. (jcc,) (Entered: 01/23/2026)

SUR-REPLY by Plaintiffs Allen Brown, Jr, Victay Cooper-Voss, Patrice Daniels, Shawn Eagan, Afton Ferris, Nickolas Garcia, Tyran (Tiffany) Hall, Jasmine (Joseph) Herman, Andre Hilliard, David Hughes, Charles Kucinsky, Derrick Macklin, Irving Madden, David Mason, Keyshawn Nichols, Byron Porter, James Reed, Cordell Sanders, James Wright to reply to response to motion, 45 Plaintiffs' Surreply to Defendant Latoya Hughes' Motion to Dismiss Reply (Schmetterer, Kenneth) (Entered: 01/23/2026)

OPINION and Order: For the reasons set forth in the accompanying opinion, Defendant's motion to dismiss 32 is denied. Signed by the Honorable April M. Perry on 3/5/2026. Mailed notice. (jcc,)

STATUS Report Joint Discovery Progress Report by Andre Hilliard Presented before Magistrate Judge (Lau, Sophia) (Entered: 03/25/2026)

MINUTE entry before the Honorable Gabriel A. Fuentes: On review of the parties' joint status report (doc. # 55 ), the Court makes no adjustment to the 9/18/26 fact discovery cutoff. The next joint written status report on discovery progress and settlement status is due by noon on 6/3/26. If the parties at any time decide they wish to engage in a settlement conference, they may contact the courtroom deputy, Jannette Nunez, at 312-818-6514 to initiate scheduling. Emailed notice (yt) (Entered: 03/26/2026)

ATTORNEY Appearance for Defendant Latoya Hughes by Dylan James Barnick (Barnick, Dylan) (Entered: 05/08/2026)

NOTICE of Motion by Aaron Talen Dozeman for presentment of motion for extension of time to file answer 63 before Honorable April M. Perry on 5/20/2026 at 10:00 AM. (Dozeman, Aaron) (Entered: 05/13/2026)

ATTORNEY Appearance for Defendant Latoya Hughes by Patricia Brito Salazar (Brito Salazar, Patricia) (Entered: 05/20/2026)

NOTICE of Motion by Dylan James Barnick for presentment of motion for extension of time to file answer 67 before Honorable April M. Perry on 6/9/2026 at 10:00 AM. (Barnick, Dylan) (Entered: 06/03/2026)

STATUS Report (Joint) by Latoya Hughes Presented before Magistrate Judge (Barnick, Dylan) (Entered: 06/03/2026)

MINUTE entry before the Honorable Gabriel A. Fuentes: On review of the status report (doc. # 69 ), the 9/18/26 fact discovery cutoff stands, and any motion to extend it, along with any motion for a proposed expert discovery schedule, must be on file before 6/30/26. Any motion to compel document production by a date certain should be on file after conferral before 6/30/26. Mailed notice. (jn,) (Entered: 06/04/2026)

ANSWER to Complaint with Jury Demand by Latoya Hughes(Barnick, Dylan) (Entered: 06/10/2026)

NOTICE by Nicole Rae Schult of Change of Address (Schult, Nicole) (Entered: 07/17/2026)

ATTORNEY Appearance for Defendant Latoya Hughes by Kajal Patel (Patel, Kajal) (Entered: 07/31/2026)

NOTICE of Motion by Kajal Patel for presentment of motion to substitute attorney 77 before Honorable April M. Perry on 8/12/2026 at 10:00 AM. (Patel, Kajal) (Entered: 08/04/2026)