Case: Rogers v. Sheriff of Cook County

COMPLAINT filed by Keith Rogers; Jury Demand. Filing fee $ 400, receipt number 0752-11433006.(Flaxman, Kenneth) (Entered: 12/23/2015)

CIVIL Cover Sheet (Flaxman, Kenneth) (Entered: 12/23/2015)

ATTORNEY Appearance for Plaintiff Keith Rogers by Kenneth N Flaxman (Flaxman, Kenneth) (Entered: 12/23/2015)

CASE ASSIGNED to the Honorable Edmond E. Chang. Designated as Magistrate Judge the Honorable Daniel Martin. (daj, )

ATTORNEY Appearance for Plaintiff Keith Rogers by Joel A. Flaxman (Flaxman, Joel) (Entered: 12/28/2015)

SUMMONS Issued as to Defendants Sheriff of Cook County, Cook County Illinois (jp, )

ATTORNEY Appearance for Defendants Sheriff of Cook County, Cook County Illinois by David Lee Bonner (Bonner, David) (Entered: 01/08/2016)

MOTION by Defendants Sheriff of Cook County, Cook County Illinois for extension of time to file answer (Bonner, David) (Entered: 01/08/2016)

NOTICE of Motion by David Lee Bonner for presentment of motion for extension of time to file answer 6 before Honorable Edmond E. Chang on 1/19/2016 at 08:30 AM. (Bonner, David) (Entered: 01/08/2016)

ATTORNEY Appearance for Defendants Sheriff of Cook County, Cook County Illinois by Michael Jude Sorich (Sorich, Michael) (Entered: 01/08/2016)

MOTION by Defendants Sheriff of Cook County, Cook County Illinois for extension of time to file answer (Bonner, David) (Entered: 01/08/2016)

NOTICE by Sheriff of Cook County, Cook County Illinois (Bonner, David) (Entered: 01/08/2016)

MINUTE entry before the Honorable Edmond E. Chang: Status hearing set for 03/14/2016 at 9:30 a.m. The parties must file a joint initial status report with the content described in the attached status report requirements at least 3 business days before the initial status hearing. Plaintiff must still file the report even if not all Defendants have been served or have responded to requests to craft a joint report. Additionally, the parties must read Judge Chang's Case Management Procedures on the Court's website; those Procedures are considered standing orders in this case. Judge Chang's Case Management Procedures were revised in December 2014.Emailed notice (Attachments: # 1 Status Report Requirements) (slb, ) (Entered: 01/11/2016)

1 Status Report Requirements

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MINUTE entry before the Honorable Edmond E. Chang: The defense extension motion [6, 9] to answer or respond to the complaint is granted to 03/04/2016. In view of the length of the extension, the Court does expect that there would likely not be a need for another extension. Emailed notice (slb, ) (Entered: 01/15/2016)

ANSWER to Complaint with Jury Demand by Sheriff of Cook County, Cook County Illinois(Bonner, David) (Entered: 03/04/2016)

NOTICE by Sheriff of Cook County, Cook County Illinois re answer to complaint 13 (Bonner, David) (Entered: 03/04/2016)

STATUS Report (Joint Initial Status Report) by Keith Rogers (Flaxman, Joel) (Entered: 03/09/2016)

MINUTE entry before the Honorable Edmond E. Chang: Status hearing held. Rule 26(a)(1) disclosures due 04/08/2016. The first-round of written discovery requests must be issued no later than 04/13/2016. Fact discovery, including treating physicians (Rule 26(a)(2)(C) disclosures for any treaters are due no later than 60 days before the close of fact of discovery), shall close by 08/16/2016. Rule 16(b) motions to add parties or amend pleadings are due by 06/13/2016. Any Rule 26(a)(2) expert disclosures (whether retained or not) are due 30 days after the close of fact discovery, and the 30-day deadline is adjusted automatically if the close of fact discovery is adjusted. No summary judgment motions may be filed before the close of discovery without leave of Court. The parties shall work promptly on a HIPAA order and discovery confidentiality order. As discussed in Court, Plaintiff's counsel tried to explain the length of the proposed discovery schedule by saying that, in addition to the methadone-delay claim, that there is also a claim for forced tapering for every detainee. But no such claim is in the complaint. Plaintiff must act very promptly if he wishes to seek leave to amend the complaint to assert that type of claim. With regard to settlement negotiations, Plaintiff shall send a settlement demand to Defendants by 03/16/2016, explaining in detail the basis for liability, itemizing damages, and making a good-faith demand that takes into account the risks of litigation, the time and expense of litigation. Defendants shall respond to Plaintiff's proposal by 03/31/2016, explaining in detail the basis for Defendant's offer and taking into account the same risks and costs of litigation. Defendants shall submit a copy of the proposal and response to chambers through the Proposed Order e-mail account. The parties may jointly call the courtroom deputy for a settlement referral to the magistrate judge or to schedule a settlement conference with the Court before the next status hearing. Status hearing set for 05/25/2016 at 9:00 a.m. Emailed notice (slb, ) (Entered: 03/15/2016)

MOTION by Plaintiff Keith Rogers for protective order (Agreed Motion for Entry of Agreed Qualified HIPAA Protective Order) (Flaxman, Joel) (Entered: 03/15/2016)

(Agreed Motion) NOTICE of Motion by Joel A. Flaxman for presentment of motion for protective order 16 before Honorable Edmond E. Chang on 3/21/2016 at 08:30 AM. (Flaxman, Joel) (Entered: 03/15/2016)

MINUTE entry before the Honorable Edmond E. Chang:Plaintiff's agreed motion for protective order 16 is granted. Emailed notice (slb, ) (Entered: 03/16/2016)

AGREED Qualified HIPAA Protective Order Signed by the Honorable Edmond E. Chang on 3/16/2016:Emailed notice(slb, ) (Entered: 03/16/2016)

MOTION by Plaintiff Keith Rogers to amend/correct complaint 1 (Unopposed Motion to File Amended Complaint) (Flaxman, Joel) (Entered: 03/16/2016)

NOTICE of Motion by Joel A. Flaxman for presentment of motion to amend/correct, motion for relief 21 before Honorable Edmond E. Chang on 3/21/2016 at 08:30 AM. (Flaxman, Joel) (Entered: 03/16/2016)

MINUTE entry before the Honorable Edmond E. Chang: Plaintiff's unopposed motion to file amended complaint 21] is granted. Plaintiff shall file the amended complaint on the docket as a separate entry. Defendants' answer due by 04/15/2016. Any supplemental Rule 26(a)(1) disclosures due by 04/22/2016 (still make the initial set of disclosures on the original complaint by 04/08/2016). Emailed notice (Chang, Edmond) (Entered: 03/18/2016)

AMENDED complaint by Keith Rogers against All Defendants (Flaxman, Kenneth) (Entered: 03/18/2016)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM as to Count II (Bonner, David) (Entered: 04/01/2016)

NOTICE of Motion by David Lee Bonner for presentment of Motion to Dismiss for Failure to State a Claim 25 before Honorable Edmond E. Chang on 4/11/2016 at 08:30 AM. (Bonner, David) (Entered: 04/01/2016)

MEMORANDUM by Keith Rogers in Opposition to Motion to Dismiss for Failure to State a Claim 25 (Flaxman, Joel) (Entered: 04/05/2016)

MOTION by Plaintiff Keith Rogers for protective order (Flaxman, Joel) (Entered: 04/05/2016)

NOTICE of Motion by Joel A. Flaxman for presentment of motion for protective order 28 before Honorable Edmond E. Chang on 4/11/2016 at 08:30 AM. (Flaxman, Joel) (Entered: 04/05/2016)

MINUTE entry before the Honorable Edmond E. Chang: Both motions hearings [25, 28] of 04/11/2016 are reset to 04/18/2016 at 10:30 a.m. Emailed notice (slb, ) (Entered: 04/08/2016)

MINUTE entry before the Honorable Edmond E. Chang: Motion hearing held on Defendants' partial motion to dismiss 25 and Plaintiff's motion for protective order 28 . The Court discussed various issues and concerns with the parties. On the dismissal motion, Defendants shall file a reply by 04/25/2016. Plaintiff may file a sur-reply by 05/09/2016. The motion for protective order 28 is entered and continued. In light of the pending motion to dismiss, the answer deadline to the complaint is suspended, but the parties must proceed with discovery on the forced tapering claim (it was not targeted by the dismissal motion). Status hearing set for 05/19/2016 at 10:30 a.m.Emailed notice (slb, ) (Entered: 04/18/2016)

REPLY by Sheriff of Cook County, Cook County Illinois to MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM as to Count II 25 (Bonner, David) (Entered: 04/22/2016)

NOTICE by Sheriff of Cook County, Cook County Illinois re reply to response to motion 32 (Bonner, David) (Entered: 04/22/2016)

WITHDRAWING Michael J. Sorich as counsel for Defendants Sheriff of Cook County, Cook County Illinois and substituting Anthony E. Zecchin as counsel of record (Zecchin, Anthony) (Entered: 04/25/2016)

SUR-REPLY by Plaintiff Keith Rogers to Motion to Dismiss for Failure to State a Claim 25 (Plaintiff's Sur-Reply in Opposition to Defendants' Motion to Dismiss) (Flaxman, Joel) (Entered: 05/09/2016)

MINUTE entry before the Honorable Edmond E. Chang: Defendants' partial motion to dismiss 25 and Plaintiff's related motion for HIPAA protective order 28 are under advisement. The parties must continue to make progress on discovery for the forced tapering claim. Status hearing of 05/19/2016 (as well as the previously set status hearing of 05/25/2016) is reset to 06/08/2016 at 10:15 a.m.Emailed notice (slb, ) (Entered: 05/18/2016)

MINUTE entry before the Honorable Edmond E. Chang: The Court has under advisement Defendants' partial motion to dismiss 25 (and the related motion for HIPAA protective order 28 filed by Plaintiff). The parties should continue to take discovery for the tapering claim. Status hearing of 06/08/2016 is reset to 06/28/2016 at 10:15 AM.Emailed notice (slb, ) (Entered: 06/07/2016)

MOTION by Plaintiff Keith Rogers to vacate Deadlines for Rule 16(b) Motions and Rule 26(a)(2)(C) Disclosures (Flaxman, Joel) (Entered: 06/13/2016)

NOTICE of Motion by Joel A. Flaxman for presentment of motion to vacate 38 before Honorable Edmond E. Chang on 6/16/2016 at 08:30 AM. (Flaxman, Joel) (Entered: 06/13/2016)

MINUTE entry before the Honorable Edmond E. Chang: Plaintiff's motion to vacate Rule 16(b) and Rule 26(a)(2)(C) disclosures 38 is granted, in view of the pending partial dismissal motion and the discovery back/forth cited in the motion. The Court will reset the schedule at the next status hearing. Emailed notice (slb, ) (Entered: 06/15/2016)

MINUTE entry before the Honorable Edmond E. Chang: After reviewing the briefs on Defendants' motion to dismiss Count 2 25, the Court denies the motion, though it is a close call. Despite the parties' arguments to the contrary, there is no bright-line rule either way when it comes to adequately alleging Monell claims. The substantive elements of the underlying constitutional right and the particular circumstances of each factual setting will vary too much from case to case for there to be a bright line. Here, proving the methadone-delay claim will require Plaintiff to prove deliberate indifference to that medical need, meaning, that policy makers disregarded a serious risk that there would be a delay in administering methadone till the fourth day of detention (Day Four is the benchmark that Plaintiff focuses on). The 2009-2011 data relied on by Plaintiff show 73 detainees did not get methadone until the fourth day -- but many more detainees (1,368 of them) *did* receive methadone sometime during Days Zero through Tree. And Plaintiff was not detained until 01/20/2014, so the data's usefulness is questionable. But this type of scrutiny of the facts is not for the dismissal-motion stage. So the motion is denied, and Defendants must answer the Amended Complaint by 07/11/2016. Moreover, discovery will proceed to reflect the substantive standard and the need to balance efficiency and proportionality. Specifically, Plaintiff may seek data concerning other detainees on Count 2, but must start with the time period of 09/20/2013 through 01/20/2014. This four-month time period, at least to start, makes sense because Monell requires that the municipality's policy or custom be the moving force to the violation. If discovery does not unearth some evidence of the unlawful policy or custom for the four-month period before Plaintiff's detention, then the discovery will stop. On the other hand, if discovery for this time period shows a reason to keep going, then the time period can be expanded. The motion for HIPAA protective order 28 is granted, in light of the anticipated discovery. The HIPAA order will be entered on the docket separately. At the next status hearing, the Court will set the remainder of the discovery schedule.Emailed notice (Chang, Edmond) (Entered: 06/27/2016)

SECOND Quailified HIPAA Protective Order Signed by the Honorable Edmond E. Chang on 6/27/2016:Emailed notice(slb, ) (Entered: 06/27/2016)

MINUTE entry before the Honorable Edmond E. Chang: Status hearing held. Fact discovery, including treating physicians (Rule 26(a)(2)(C) disclosures for any treaters are due no later than 45 days before the close of fact discovery), shall close by 12/05/2016. Any Rule 26(a)(2) expert disclosures (whether retained or not) are due 30 days after the close of fact discovery, and the 30-day deadline is adjusted automatically if the close of fact discovery is adjusted. No summary judgment motions may be filed before the close of discovery without leave of Court. Plaintiff's counsel mentioned the possibility of class-action treatment, but right now the case is alleged as an individual action. Plaintiff may seek leave to amend the complaint, but the parties must bear this in mind for discovery so that the parties are able to brief a motion for class certification after the close of discovery (if the complaint is amended to allege a class). Status hearing set for 08/31/2016 at 9:30 AM.Emailed notice (slb, ) (Entered: 06/28/2016)

ATTORNEY Appearance for Defendant Cook County Illinois by Thomas E. Cargie (Cargie, Thomas) (Entered: 07/06/2016)

ANSWER to amended complaint and Affirmative Defenses by Cook County Illinois(Cargie, Thomas) (Entered: 07/11/2016)

ANSWER to amended complaint by Sheriff of Cook County(Bonner, David) (Entered: 07/11/2016)

NOTICE by Sheriff of Cook County re answer to amended complaint 46 (Bonner, David) (Entered: 07/11/2016)

MOTION by Plaintiff Keith Rogers to compel (Flaxman, Joel) (Entered: 08/08/2016)

NOTICE of Motion by Joel A. Flaxman for presentment of motion to compel 48 before Honorable Edmond E. Chang on 8/11/2016 at 08:30 AM. (Flaxman, Joel) (Entered: 08/08/2016)

MINUTE entry before the Honorable Edmond E. Chang: On the Court's own initiative, the motion hearing on Plaintiff's motion to compel 48 is reset to 1:30 p.m. on the same date, 08/11/2016.Emailed notice (slb, ) (Entered: 08/09/2016)

MINUTE entry before the Honorable Edmond E. Chang: Motion hearing held on Plaintiff's motion compel 48 . The County disclosed data in response to Document Request 1. With regard to the remaining issues, by 08/16/2016, the parties shall confer on the motion. After the initial conferral, the parties shall have a follow-up conferral on 08/22/2016. The motion is entered and continued to 08/23/2016 at 1:30 p.m., at which time the Court will address any remaining disputes.Emailed notice (slb, ) (Entered: 08/11/2016)

TRANSCRIPT OF PROCEEDINGS held on 3-14-16 before the Honorable Edmond E. Chang. Court Reporter Contact Information: Krista Flynn Burgeson, Krista_Burgeson@ilnd.uscourts.gov, 312-435-5567. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 9/5/2016. Redacted Transcript Deadline set for 9/15/2016. Release of Transcript Restriction set for 11/14/2016. (Burgeson, Krista) (Entered: 08/15/2016)

MINUTE entry before the Honorable Edmond E. Chang: Motion hearing held on Plaintiff's motion to compel 48 . As a formal matter, the motion is terminated as no longer necessary in view of the conferrals and agreed disclosures, and because pre-motion conferrals were not really sufficient to justify a compulsion order. As discussed during the hearing, Defendants shall respond to Plaintiff's Interrogatories 4, 5, and 14 by 08/26/2016. By 09/17/2016, Defendants shall produce documents responsive to the pending production requests, covering the time period 01/01/2011 to 01/20/2014. Pending the entry of a protective order as to certain designated documents, the documents shall be disclosed under attorney's-eyes only protection (but also allowing Plaintiff's experts to review them) to avoid delay. Defendants' motion for protective order, invoking the Medical Studies Act or other privilege, statute, or regulation, due 09/17/2016. Plaintiff's response, if any, due 09/24/2016. Defense reply due 10/03/2016. The status hearing of 08/31/2016 is reset to 10/11/2016 at 9:30 a.m. Emailed notice (slb, ) (Entered: 08/25/2016)

TRANSCRIPT OF PROCEEDINGS held on August 23, 2016, before the Honorable Edmond E. Chang. Court Reporter Contact Information: Nancy L. Bistany, CSR, RPR, FCRR - nancy_bistany@ilnd.uscourts.gov - 312.435.7626. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 10/4/2016. Redacted Transcript Deadline set for 10/14/2016. Release of Transcript Restriction set for 12/12/2016. (Bistany, Nancy) (Entered: 09/13/2016)

MOTION by Defendant Cook County Illinois for protective order and support for claim of privilege pursuant to Illinois Medical Studies Act. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Cargie, Thomas) (Entered: 09/19/2016)

1 Exhibit 1

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2 Exhibit 2

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MEMORANDUM by Keith Rogers in Opposition to motion for protective order 55 (Flaxman, Joel) (Entered: 09/26/2016)

REPLY by Defendant Cook County Illinois to motion for protective order 55 (Attachments: # 1 Exhibit 1)(Cargie, Thomas) Modified on 10/3/2016 (kp, ). (Docket Text modified by Clerks Office). (Entered: 10/03/2016)

1 Exhibit 1

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MINUTE entry before the Honorable Edmond E. Chang: With regard to the motion for protective order 55, Defendant Cook County shall file on the electronic docket, under seal and ex parte, a copy of both the redacted and unredacted Opioid Treatment Program documents referred to in the briefing. (If Defendant files the documents under seal electronically, it will automatically be ex parte because no party/attorney will be able to access it.) The filing shall be made by 10/12/2016. The status hearing of 10/11/2016 is reset to 10/26/2016 at 9:15 AM.Emailed notice (slb, ) (Entered: 10/07/2016)

SEALED DOCUMENT by Defendant Cook County Illinois (Cargie, Thomas) (Entered: 10/11/2016)

SEALED DOCUMENT by Defendant Cook County Illinois (Cargie, Thomas) (Entered: 10/11/2016)

SEALED DOCUMENT by Defendant Cook County Illinois Amended filing (Cargie, Thomas) (Entered: 10/11/2016)

MINUTE entry before the Honorable Edmond E. Chang: Due to the Court's trial schedule, the status hearing of 10/26/2016 is reset to 11/03/2016 at 9 a.m. Emailed notice (slb, ) (Entered: 10/14/2016)

ATTORNEY Appearance for Defendant Sheriff of Cook County by John Power (Power, John) (Entered: 10/27/2016)

MOTION by Plaintiff Keith Rogers to compel (Flaxman, Joel) (Entered: 10/31/2016)

NOTICE of Motion by Joel A. Flaxman for presentment of motion to compel 64 before Honorable Edmond E. Chang on 11/3/2016 at 08:30 AM. (Flaxman, Joel) (Entered: 10/31/2016)

MINUTE entry before the Honorable Edmond E. Chang: On Plaintiff's motion to compel 64 certain detainee information, the defense shall respond by 11/09/2016. Plaintiff may reply by 11/14/2016. The status and motion hearing are reset to 11/16/2016 at 10:45 AM.Emailed notice (slb, ) (Entered: 11/01/2016)

MOTION by Plaintiff Keith Rogers to vacate and Reset Discovery Cutoff Date in Light of Pending Discovery Motions (Flaxman, Joel) (Entered: 11/09/2016)

NOTICE of Motion by Joel A. Flaxman for presentment of motion to vacate 67 before Honorable Edmond E. Chang on 11/15/2016 at 08:30 AM. (Flaxman, Joel) (Entered: 11/09/2016)

RESPONSE by Sheriff of Cook Countyin Opposition to MOTION by Plaintiff Keith Rogers to compel 64 (Attachments: # 1 Notice of Filing)(Power, John) (Entered: 11/09/2016)

1 Notice of Filing

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MINUTE entry before the Honorable Edmond E. Chang: Plaintiff's discovery extension motion 67 is entered and continued to 11/16/2016, at 10:45 a.m., to coincide with the status hearing. Emailed notice (slb, ) (Entered: 11/14/2016)

REPLY by Keith Rogers to response in opposition to motion 69 (Flaxman, Joel) (Entered: 11/14/2016)

MINUTE entry before the Honorable Edmond E. Chang: The Court has under advisement the defense motion for protective order 55 and Plaintiff's motion to compel 64 . The status and motion hearings of 11/16/2016 are reset to 12/02/2016 at 10:45 a.m. The extension motion on fact discovery 67 is granted; even if the protective order is granted and the motion to compel denied, still the parties would need to consider whether additional discovery is needed. A new deadline will be set at the next hearing. Emailed notice (slb, ) (Entered: 11/15/2016)

RESPONSE by Defendant Sheriff of Cook County to response in opposition to motion 69 Supplemental Response (Attachments: # 1 Notice of Filing)(Power, John) (Entered: 11/18/2016)

1 Notice of Filing

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MOTION by Plaintiff Keith Rogers to certify class (Flaxman, Kenneth) (Entered: 11/21/2016)

NOTICE of Motion by Kenneth N Flaxman for presentment of motion to certify class 74 before Honorable Edmond E. Chang on 11/30/2016 at 08:30 AM. (Flaxman, Kenneth) (Entered: 11/21/2016)

MOTION by Defendant Sheriff of Cook County for protective order, MOTION by Defendant Sheriff of Cook County to quash (Attachments: # 1 Exhibit Exhibit 1)(Power, John) (Entered: 11/22/2016)

1 Exhibit Exhibit 1

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NOTICE of Motion by John Power for presentment of motion for protective order, motion to quash 76 before Honorable Edmond E. Chang on 11/30/2016 at 08:30 AM. (Power, John) (Entered: 11/22/2016)

AMENDED NOTICE of Motion by Kenneth N Flaxman for presentment of motion to certify class 74 before Honorable Edmond E. Chang on 12/2/2016 at 10:45 AM. (Flaxman, Kenneth) (Entered: 11/27/2016)

MINUTE entry before the Honorable Edmond E. Chang: Plaintiff's motion to certify class 74 is reset to coincide with the status hearing of 12/02/2016 at 10:45 a.m., when the Court will discuss whether the motion is ready to be briefed. Defendant Sherriff's motion for protective order 76 is also reset to the status hearing date and time; in the meantime, the discovery requests that are the subject of the motion are suspended.Emailed notice (slb, ) (Entered: 11/29/2016)

MINUTE entry before the Honorable Edmond E. Chang: To allow more time for the Court to review the filings, the status and motion hearings of 12/02/2016 are reset to 12/13/2016 at 10 a.m. Emailed notice (slb, ) (Entered: 12/01/2016)

RESPONSE by Keith Rogersin Opposition to MOTION by Defendant Sheriff of Cook County for protective order MOTION by Defendant Sheriff of Cook County to quash 76 (Flaxman, Joel) (Entered: 12/06/2016)

MINUTE entry before the Honorable Edmond E. Chang: The Court has the pending motions under advisement and resets the status hearing of 12/13/2016 to 12/19/2016 at 2:30 p.m. Emailed notice (slb, ) (Entered: 12/12/2016)

MINUTE entry before the Honorable Edmond E. Chang: The status hearing and pending motions 55 74 76 are reset from 12/19/2016 to 01/06/2017 at 09:30 AM.Emailed notice (Chang, Edmond) (Entered: 12/18/2016)

MINUTE entry before the Honorable Edmond E. Chang: In light of an appellate-argument scheduling conflict on Plaintiff's counsel's calendar, the hearing of 01/06/2017 is reset to 01/11/2017 at 11 a.m. Emailed notice (slb, ) (Entered: 01/04/2017)

MINUTE entry before the Honorable Edmond E. Chang: The Court will post an order dealing with the pending discovery motions in due course, and will reset the status hearing at that time. The status hearing of 01/11/2017 is vacated.Emailed notice (Chang, Edmond) (Entered: 01/10/2017)

ATTORNEY Appearance for Defendant Cook County Illinois by James J. Chandler (Chandler, James) (Entered: 08/07/2017)

MOTION by Plaintiff Keith Rogers to expedite ruling (Flaxman, Joel) (Entered: 09/22/2017)

NOTICE of Motion by Joel A. Flaxman for presentment of motion to expedite 87 before Honorable Edmond E. Chang on 9/28/2017 at 08:30 AM. (Flaxman, Joel) (Entered: 09/22/2017)

MINUTE entry before the Honorable Edmond E. Chang: The Court plans to issue a decision on the discovery motions in the next week, so the motion to expedite 87 is denied. Emailed notice (slb, ) (Entered: 09/27/2017)

ORDER signed by the Honorable Edmond E. Chang on 9/29/2017: For the reasons stated in the Order, Defendants' motion for protective order as to OTP Committee 55 is denied in large part and granted in part; Plaintiff's motion to compel data 64 is granted in part and denied in part; Defendants' motion 76 to quash 30(b)(6) notice is granted in light of the decision on the motion to compel data; and Plaintiff's motion 74 to certify class is terminated without prejudice as premature. At the next status hearing, the Court will discuss the discovery plan, including class-certification discovery, with the parties. The status hearing is set for 10/11/2017, at 10 a.m. Emailed notice(Chang, Edmond) (Entered: 09/29/2017)

PROTECTIVE Order signed by the Honorable Edmond E. Chang on 10/6/2017: This is the confidentiality order governing discovery materials.Emailed notice(Chang, Edmond) (Entered: 10/06/2017)

CERTIFICATE of Service of Defendant, Cook County's Production of Un-Redacted Documents Pursuant to Judge Emdond Chang's Order dated September 29, 2017 by James J. Chandler on behalf of Cook County Illinois (Chandler, James) (Entered: 10/10/2017)

MINUTE entry before the Honorable Edmond E. Chang: Status hearing held. The Court discussed a reasonable deadline to close fact discovery on the merits of Plaintiff's individual claim and the propriety of class certification. Plaintiff reported that he will not need a retained expert for class certification; the defense was not yet sure. To the extent that the defense will use County employees as Rule 26(a)(2)(C) experts, the summaries are due by 12/11/2017. Fact discovery on individual merits and the propriety of class certification shall close by 02/08/2018, and if no retained experts are disclosed that will be the close of all discovery (the parties should have a firmer idea on retained experts by the next status hearing). Status hearing is set for 12/12/2017 at 10:15 a.m. Mailed notice (ags, ) (Entered: 10/11/2017)

WITHDRAWING James J. Chandler as counsel for Defendant Sheriff of Cook County and substituting Jessica Megan Scheller as counsel of record (Scheller, Jessica) (Entered: 11/07/2017)

WITHDRAWING David Lee Bonner, Jessica Megan Scheller, John Power and Anthony E. Zecchin as counsel for Defendant Sheriff of Cook County and substituting Gerald Michael Dombrowski as counsel of record (Dombrowski, Gerald) (Entered: 11/30/2017)

WITHDRAWING James J. Chandler as counsel for Defendant Cook County Illinois and substituting Jessica Megan Scheller as counsel of record (Scheller, Jessica) (Entered: 12/07/2017)

MOTION by Defendant Cook County Illinois for extension of time to complete discovery Unopposed (Scheller, Jessica) (Entered: 12/07/2017)

Unopposed NOTICE of Motion by Jessica Megan Scheller for presentment of motion for extension of time to complete discovery 97 before Honorable Edmond E. Chang on 12/12/2017 at 08:30 AM. (Scheller, Jessica) (Entered: 12/07/2017)