Case: Access Living of Metropolitan Chicago v. City of Chicago

COMPLAINT filed by Access Living of Metropolitan Chicago; Jury Demand. Filing fee $ 400, receipt number 0752-14465328.(Rosenberg, Mary) (Entered: 05/13/2018)

CIVIL Cover Sheet (Rosenberg, Mary) (Entered: 05/13/2018)

ATTORNEY Appearance for Plaintiff Access Living of Metropolitan Chicago by Mary Elizabeth Rosenberg (Rosenberg, Mary) (Entered: 05/13/2018)

ATTORNEY Appearance for Plaintiff Access Living of Metropolitan Chicago by Kenneth M Walden (Walden, Kenneth) (Entered: 05/13/2018)

CASE ASSIGNED to the Honorable Robert M. Dow, Jr. Designated as Magistrate Judge the Honorable Jeffrey Cole. (acm)

case assigned

NOTICE TO THE PARTIES - The Court is participating in the Mandatory Initial Discovery Pilot (MIDP). The key features and deadlines are set forth in this Notice which includes a link to the (MIDP) Standing Order and a Checklist for use by the parties. In cases subject to the pilot, all parties must respond to the mandatory initial discovery requests set forth in the Standing Order before initiating any further discovery in this case. Please note: The discovery obligations in the Standing Order supersede the disclosures required by Rule 26(a)(1). Any party seeking affirmative relief must serve a copy of the following documents (Notice of Mandatory Initial Discovery and the Standing Order) on each new party when the Complaint, Counterclaim, Crossclaim, or Third-Party Complaint is served. (sxb, ) (Entered: 05/14/2018)

summons issued

SUMMONS Issued as to Defendant City Of Chicago. (kb, )

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-14479523. (Attachments: # 1 Attachment for Admissions)(Gaztambide-Arandes, Laura) (Entered: 05/16/2018)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-14481237. (Attachments: # 1 Attachment for Admissions)(Allen, Michael) (Entered: 05/17/2018)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-14481396. (May, Orly) (Entered: 05/17/2018)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-14482387. (Attachments: # 1 Attachment for Admissions)(Klar, Jennifer) (Entered: 05/17/2018)

ATTORNEY Appearance for Defendant City Of Chicago by Margaret R. Sobota (Sobota, Margaret) (Entered: 05/18/2018)

ATTORNEY Appearance for Defendant City Of Chicago by Tara D. Kennedy (Kennedy, Tara) (Entered: 05/21/2018)

MINUTE entry before the Honorable Robert M. Dow, Jr: Initial status hearing is set for 7/17/2018 at 9:00 a.m. and parties are to report the following: (1) Possibility of settlement in the case; (2) If no possibility of settlement exists, the nature and length of discovery necessary to get the case ready for trial. Plaintiff is to advise all other parties of the courts action herein. Lead counsel is directed to appear at this status hearing. The parties are requested to file a joint status report at least two days prior to the initial status. For further details see the Court's website available at www.ilnd.uscourts.gov. Mailed notice (cdh, ) (Entered: 05/21/2018)

MINUTE entry before the Honorable Robert M. Dow, Jr: Motions for leave to appear pro hac vice 6, 7, 8, and 9 are granted. Mailed notice (cdh, ) (Entered: 05/21/2018)

MOTION by Defendant City Of Chicago for extension of time to file its Rule 12(b) Motion and to defer the filing of Defendant's answer and the Parties' Joint Status Report (Sobota, Margaret) (Entered: 06/04/2018)

NOTICE of Motion by Margaret R. Sobota for presentment of extension of time 14 before Honorable Robert M. Dow Jr. on 6/13/2018 at 09:15 AM. (Sobota, Margaret) (Entered: 06/04/2018)

Notice by Access Living of Metropolitan Chicago (Gaztambide-Arandes, Laura) (Entered: 06/05/2018)

RESPONSE by Access Living of Metropolitan Chicagoin Opposition to MOTION by Defendant City Of Chicago for extension of time to file its Rule 12(b) Motion and to defer the filing of Defendant's answer and the Parties' Joint Status Report 14 (Attachments: # 1 Exhibit A - June 4, 2018 e-mails between Ken Walden and Tara Kennedy)(Gaztambide-Arandes, Laura) (Entered: 06/06/2018)

SUMMONS Returned Executed by Access Living of Metropolitan Chicago as to City Of Chicago on 5/17/2018, answer due 6/7/2018. (Gaztambide-Arandes, Laura) (Entered: 06/06/2018)

MINUTE entry before the Honorable Robert M. Dow, Jr: Out-of-town counsel may participate by telephone by using the Court's toll-free call-in number 877-336-1829, conference access code is 6963747 for the 6/13/2018 hearing. Mailed notice (cdh, ) (Entered: 06/12/2018)

MINUTE entry before the Honorable Robert M. Dow, Jr: Motion hearing held. Defendant shall file its reply in support of its Motion for an Extension of Time 14 on or before 6/27/18. Defendant's Rule 12(b) Motion shall be filed on or before 7/9/18. Initial status hearing previously set for 7/17/18 at 9:00 a.m. will stand. The parties shall file a joint status report at least two days prior to the initial status. Mailed notice (ep, ) (Entered: 06/13/2018)

REPLY by Defendant City Of Chicago to extension of time 14 and for deferral of deadline to answer and file Joint Initial Status Report (Attachments: # 1 Exhibit Corporate File Detail Report)(Sobota, Margaret) (Entered: 06/21/2018)

SUR-REPLY by Plaintiff Access Living of Metropolitan Chicago in Response to Defendant's Reply in Support of its Motion to Defer the Filing of Defendant's Answer and the Parties' Joint Status Report (Attachments: # 1 Exhibit A)(Gaztambide-Arandes, Laura) (Entered: 06/22/2018)

ATTORNEY Appearance for Defendant City Of Chicago by Christie Starzec (Starzec, Christie) (Entered: 07/06/2018)

MOTION by Defendant City Of Chicago to dismiss for lack of jurisdiction, MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant City Of Chicago (Sobota, Margaret) (Entered: 07/09/2018)

MEMORANDUM by City Of Chicago in support of motion to dismiss/lack of jurisdiction, Motion to Dismiss for Failure to State a Claim 24 (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4)(Sobota, Margaret) (Entered: 07/09/2018)

NOTICE of Motion by Margaret R. Sobota for presentment of motion to dismiss/lack of jurisdiction, Motion to Dismiss for Failure to State a Claim 24 before Honorable Robert M. Dow Jr. on 7/17/2018 at 09:00 AM. (Sobota, Margaret) (Entered: 07/09/2018)

ANSWER to Complaint by City Of Chicago(Sobota, Margaret) (Entered: 07/09/2018)

Rule 26(f) Report for Mandatory Initial Discovery Pilot (MIDP) (Joint), filed by Plaintiff Access Living of Metropolitan Chicago. (Gaztambide-Arandes, Laura) (Entered: 07/13/2018)

MINUTE entry before the Honorable Robert M. Dow, Jr:Status hearing and motion hearing held. Defendant's motion to dismiss for lack of jurisdiction 24 is taken under advisement; response is due by 8/1/2018; reply is due by 8/22/2018; the Court will issue a ruling by mail. As discussed on the record, parties to submit their proposed agreed protective order (notice of motion is not necessary). Mailed notice (cdh, ) (Entered: 07/17/2018)

MINUTE entry before the Honorable Robert M. Dow, Jr: Supplement to Minute entry 29, as stated on the record, this case is deferred from the MIDP due to pending dispute regarding subject-matter jurisdiction. Mailed notice (cdh, ) (Entered: 07/17/2018)

JOINT STIPULATED RULE 502(d) ORDER Signed by the Honorable Robert M. Dow, Jr. on 7/27/2018. Mailed notice(cdh, ) (Entered: 07/27/2018)

AGREED CONFIDENTIALITY ORDER Signed by the Honorable Robert M. Dow, Jr. on 7/27/2018. Mailed notice(cdh, ) (Entered: 07/27/2018)

RESPONSE by Access Living of Metropolitan Chicagoin Opposition to MOTION by Defendant City Of Chicago to dismiss for lack of jurisdiction MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant City Of Chicago 24 (Attachments: # 1 Exhibit A - Representative Loan Agreement)(Gaztambide-Arandes, Laura) (Entered: 08/01/2018)

REPLY by Defendant City Of Chicago to motion to dismiss/lack of jurisdiction, Motion to Dismiss for Failure to State a Claim 24, memorandum in support of motion, 25 (Sobota, Margaret) (Entered: 08/22/2018)

MEMORANDUM OPINION AND ORDER Signed by the Honorable Robert M. Dow, Jr. on 3/29/2019. Defendant's motion to dismiss 24 is denied. This case is set for status hearing on April 18, 2019 at 9:00 a.m. Mailed notice(cdh, ) (Entered: 03/29/2019)

ATTORNEY Appearance for Defendant City Of Chicago by Monica Hersh Khetarpal (Khetarpal, Monica) (Entered: 04/17/2019)

ATTORNEY Appearance for Defendant City Of Chicago by Jason A. Selvey (Selvey, Jason) (Entered: 04/17/2019)

MINUTE entry before the Honorable Robert M. Dow, Jr: Status hearing held and continued to 6/18/2019 at 9:30 a.m. As discussed on the record, discovery shall be produced on a rolling basis and as expeditiously as possible. Mailed notice (cdh, ) (Entered: 04/18/2019)

MOTION by Plaintiff Access Living of Metropolitan Chicago to withdraw Appearance of Laura Gaztambide-Arandes as Counsel for Plaintiff (Klar, Jennifer) (Entered: 05/08/2019)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-15811200. (Schellenberg, Kali) (Entered: 05/10/2019)

MINUTE entry before the Honorable Robert M. Dow, Jr: Motion of Kali Schellenberg for leave to appear pro hac vice on behalf of Plaintiff Access Living of Metropolitan Chicago 40 is granted. Mailed notice (cdh, ) (Entered: 05/10/2019)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-15815917. (Miller, Lila) (Entered: 05/13/2019)

ATTORNEY Appearance for Defendant City Of Chicago by Matthew Scot Payne (Payne, Matthew) (Entered: 05/17/2019)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-15836448. Motion for Leave to Appear Pro Hac Vice - John C. Hansberry (Hansberry, John) (Entered: 05/17/2019)

MOTION by Attorney Tara Kennedy to withdraw as attorney for City Of Chicago. No party information provided (Kennedy, Tara) (Entered: 05/21/2019)

NOTICE of Motion by Tara D. Kennedy for presentment of motion to withdraw as attorney 45 before Honorable Robert M. Dow Jr. on 5/29/2019 at 09:15 AM. (Kennedy, Tara) (Entered: 05/21/2019)

MINUTE entry before the Honorable Robert M. Dow, Jr: Motion hearing held. Plaintiff did not appear. Motion to withdraw as attorney 45 is granted. Attorney Tara D. Kennedy terminated. Mailed notice (cdh, ) (Entered: 05/29/2019)

MINUTE entry before the Honorable Robert M. Dow, Jr: Telephonic request by counsel for Plaintiff to participate by telephone for tomorrow's hearing at 9:30 a.m. on 6/18/2019 is granted. The Court's toll-free call-in number 877-336-1829, conference access code is 6963747. For future status hearings out-of-state counsel may participate by telephone by contacting the courtroom deputy by e-mail at least two to three days in advance of the hearing for the call-in information. Mailed notice (cdh, ) (Entered: 06/17/2019)

MINUTE entry before the Honorable Robert M. Dow, Jr:Status hearing held. Motion to withdraw Laura J. Gaztambide-Arandes as one of the attorneys for plaintiff 39 is granted. Motion of Lila Miller to appear pro hac vice 42 is granted. Motion of John C. Hansberry to appear pro hac vice 44 is granted. Status hearing set for 8/21/2019 at 09:30 AM.Mailed notice (clw, ) (Entered: 06/18/2019)

ATTORNEY Appearance for Defendant City Of Chicago by Oscar Pina (Pina, Oscar) (Entered: 08/02/2019)

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Jeffrey Cole for the purpose of holding proceedings related to: discovery supervision. (ags, ) Mailed notice. (Entered: 08/21/2019)

MINUTE entry before the Honorable Robert M. Dow, Jr: Status hearing held. The case is referred to the magistrate judge for all discovery proceedings. A further status hearing will be set in the district court at a later date based on the progress of discovery. Mailed notice (ags, ) (Entered: 08/21/2019)

MINUTE entry before the Honorable Jeffrey Cole: A status is set for 9/25/19 at 8:30 a.m. in room 1003. Mailed notice. (jjr, ) (Entered: 09/17/2019)

MINUTE entry before the Honorable Jeffrey Cole: Status hearing held and continued by agreement to 11/12/2019 at 08:30 AM. Certain out of town counsel, for the plaintiff, participated by phone. In discussions with counsel for both sides, it was their view that given the nature of the particular case, the provisions of the MIDP were not appropriate to effectively and expeditiously govern discovery here, and it was requested by all counsel that the MIDP not apply in this case. That request was granted, and discovery will proceed under the usual Federal Rules of Civil Procedure. The parties initially shall engage in formal discovery regarding the 139 properties discussed in court today. Counsel shall submit a Joint Proposed Discovery Schedule by 10/9/2019. A few preliminary observations may be in order. [P]rotracted discovery, [is] the bane of modern litigation. Rossetto v. Pabst Brewing Co., Inc., 217 F.3d 539, 542 (7th Cir.2000). The undeniable fact is that under the realities of modern litigation[,] [p]re-trial discovery has become a monster on the loose.... Pre-trial proceedings have become more costly and important than trials themselves. A.H. Robins Co. v. Piccinin, 788 F.2d 994, 1013 (4th Cir. 1986). Thus, it is perhaps more imperative today than ever before that parties engage in discovery in good faith, without gamesmanship, In re Sulfuric Acid Antitrust Litigation 231 F.R.D. 331, 342 (N.D.Ill. 2005), and to cooperate with and facilitate forthright discovery. Johnson v. J.B. Hunt Transport, Inc., 280 F.3d 1125, 1132 (7th Cir.2002). See also Mills v. East Gulf Coal Preparation Co., LLC, 259 F.R.D. 118, 130 (S.D.W.Va. 2009). Accordingly, parties must respond with specificity to discovery requests, including by making particularized objections. Hall v. Sullivan, 231 F.R.D. 468, 474 (D.Md.2005). General or boilerplate objections to discovery requests are invalid. BankDirect Capital Finance LLC v. Capital Premium Financing, Inc., 2017 WL 5890923, *2 (N.D.Ill. 2017). This is not to suggest that any of these cautions will not be observed in this case. But given the importance of the case and the inevitable complexity of the discovery that is to follow, it is certainly not inappropriate to share with counsel some of the consistent views of judges throughout the country. See also Frank Easterbrook, Discovery As Abuse, 69 B.U.L.Rev. 635 (1989). Counsel are reminded of Local Rule 16.1(4) requiring that discovery be completed before the discovery closing date. If any issues arise during depositions, counsel are urged to call chambers at 312-435-5601.Mailed notice (jms, ) (Entered: 09/25/2019)

MOTION by Plaintiff Access Living of Metropolitan Chicago for extension of time to file Joint Proposed Discovery Schedule (Klar, Jennifer) (Entered: 10/01/2019)

NOTICE of Motion by Jennifer Irene Klar for presentment of motion for extension of time to file 55 before Honorable Jeffrey Cole on 10/8/2019 at 08:30 AM. (Attachments: # 1 Joint Motion)(Klar, Jennifer) (Entered: 10/04/2019)

MINUTE entry before the Honorable Jeffrey Cole:Plaintiff's motion for extension of time to 10/10/2019 to file the joint agreed discovery schedule 55 is granted.Mailed notice (jms, ) (Entered: 10/07/2019)

Joint Proposed Discovery Schedule by Access Living of Metropolitan Chicago and Defendant City of Chicago (Schellenberg, Kali) (Entered: 10/10/2019)

MINUTE entry before the Honorable Jeffrey Cole: On September 25, 2019, the parties were ordered to submit a Joint Proposed Discovery Order by October 9, 2019. [Dkt. # 54]. They asked for, and received a one-day extension of that deadline. However, a joint discovery Order was not forthcoming, despite its title. Apparently the parties could not agree on a schedule. Instead, two versions of a discovery schedule were submitted: one by the plaintiff and one by the defendant. The plaintiff's version sought one year of fact discovery and an additional three months of expert discovery. Under this timetable, all discovery is to end on 1/4/21. The Defendant, however, has proposed a different schedule. It wants two years for all discovery [Dkt. # 58] which would end on 10/8/21. In essence, the joint schedule is that in name only. This case was filed on May 13, 2018. On June 4, 2018, defendant asked for, and received, an extension of time in which to file a motion to dismiss and a stay of discovery until that motion was ruled on. [Dkt. # 14, 30]. The defendant's motion to dismiss was denied on March 29, 2018 [Dkt. #35] and, at the next status hearing on April 18, 2019, Judge Dow ordered that discovery proceed "on a rolling basis as expeditiously as possible." [Dkt. # 38](Emphasis supplied). Given what has already gone on, with a long break from discovery at the defendant's behest and Judge Dow's understandable and perfectly proper desire that lost time be made up for, the plaintiff's shorter schedule is more appropriate and will be adopted. Mindful of what the instant case involves, care must be taken not to be consumed by excessive and needless demands for discovery, which are "the bane of modern litigation." Rossetto v. Pabst Brewing Co., Inc., 217 F.3d 539, 542 (7th Cir.2000). See generally Frank H. Easterbrook, "Discovery as Abuse," 69 B.U. L.Rev. 635, 639 (1989). The public interest in the prompt and efficient resolution of legal disputes cannot and should not be ignored. See Fort Howard Paper Co. v. Standard Havens, Inc., 901 F.2d 1373, 1380 (7th Cir. 1990); Weingarten Realty Investors v. Miller, 661 F.3d 904, 913 (5th Cir.2011); Gray v. Schaub, 182 F.3d 921 (7th Cir.1999). Experience, which has a role to play in all cases, United States v Montoya De Hernandez, 473 U.S. 531, 542 (1985), teaches that the farther in the future a deadline looms, the less seems to be done in the time allowed. If things are not done until the last minute, as is unfortunately so often the case in the law, Gilliam v. Verizon Pennsylvania, Inc., 2014 WL 901296, at *4 (W.D. Pa. 2014), then it is better that the last minute comes earlier rather than later. Accordingly, the plaintiff's schedule is adopted. Any requests for extensions must comply with Fed.R.Civ.P. 6(b). The defendant's position that the length of 30(b)(6) depositions be determined on an as needed basis is adopted. The duration of depositions is defined by the Federal Rules of Civil Procedure, which govern the discovery in the case absent a showing of some reason why the amount of time provided in the Rules should not be adhered to. Of course, counsel can agree among themselves to vary the prescribed time limits.Mailed notice (jms, ) (Entered: 10/17/2019)

TRANSCRIPT OF PROCEEDINGS held on 09/25/19 before the Honorable Jeffrey Cole. Order Number: 36267. Court Reporter Contact Information: Patrick Mullen, (312) 435-5565, patrick_mullen@ilnd.uscourts.gov. 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 11/13/2019. Redacted Transcript Deadline set for 11/25/2019. Release of Transcript Restriction set for 1/21/2020. (Mullen, Patrick) (Entered: 10/23/2019)

NOTICE by Access Living of Metropolitan Chicago Regarding Plaintiff's Discovery Plan (Klar, Jennifer) (Entered: 11/06/2019)

MOTION by Defendant City Of Chicago for protective order Defendant City of Chicago's Motion for Protective Order (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Khetarpal, Monica) (Entered: 11/08/2019)

NOTICE of Motion by Monica Hersh Khetarpal for presentment of motion for protective order 62 before Honorable Jeffrey Cole on 11/14/2019 at 08:30 AM. (Khetarpal, Monica) (Entered: 11/08/2019)

NOTICE by Access Living of Metropolitan Chicago re MOTION by Defendant City Of Chicago for protective order Defendant City of Chicago's Motion for Protective Order 62 (Attachments: # 1 Exhibit A - Email Correspondence and Letter Attachment)(Klar, Jennifer) (Entered: 11/08/2019)

MINUTE entry before the Honorable Jeffrey Cole: Status hearing held and continued to 12/2/2019 at 08:30 AM. Defendant's motion for a protective order 62 is taken under advisement. Plaintiff's oral motion for leave to file a response by 11/18/2019 is granted. Reply is to be filed by 11/25/2019. Counsel for plaintiff is reminded that compliance with Local Rule 5.2(f) is mandatory. Plaintiff's oral motion to have regular status hearings is granted. Status hearings are set for 12/16/2019 at 8:30 am, 1/6/2020 at 8:30 am, 1/22/2020 at 8:30 am, 2/5/2020 at 8:30 am, 2/19/2020 at 8:30 am, 3/4/2020 at 8:30 am, 3/18/2020 at 8:30 am, 4/1/2020 at 8:30 am, 4/15/2020 at 8:30 am. Biweekly written status reports shall be filed and delivered to chambers, Room 1088, no later than 2 business days before the scheduled status hearing. While counsel can prepare the report, the underlying representations regarding any claimed difficulties in acquisition or production of information must be supported by a detailed declaration or declarations from those who are responsible for and involved in the gathering of information that will be included in or will underlie the status of production.Mailed notice (jms, ) (Entered: 11/12/2019)

NOTICE by Access Living of Metropolitan Chicago re MOTION by Defendant City Of Chicago for protective order Defendant City of Chicago's Motion for Protective Order 62 (Klar, Jennifer) (Entered: 11/14/2019)

MINUTE entry before the Honorable Jeffrey Cole:Status hearing date of 2/19/2020 is stricken. All other previously set status hearing dates shall stand.Mailed notice (jms, ) (Entered: 11/21/2019)

STATUS Report Defendant City of Chicago's First Discovery Status Report by City Of Chicago (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit E, # 4 Exhibit F, # 5 Exhibit G)(Khetarpal, Monica) (Entered: 11/27/2019)

STATUS Report for December 2, 2019 Hearing by Access Living of Metropolitan Chicago (Klar, Jennifer) (Entered: 11/27/2019)

MINUTE entry before the Honorable Jeffrey Cole: Status hearing held and continued to 12/16/20190 at 8:30 am. Initial discovery shall continue to be limited to the 135 properties previously identified, not to the much larger number again somewhat obliquely requested by the plaintiff. Based on representations made by defendants' counsel, loan agreements and regulatory agreements for the 135 properties are readily available and shall be turned over by 1/31/2020. The remaining discovery on the 135 properties discussed in the City's 11/27/19 report to the court 69 shall, as previously ordered, be on a rolling basis and must be completed by 6/30/2020, the date the City's counsel informed the court today she believed discovery could be completed. Despite intimations from counsel for the plaintiff, that is more than a reasonable amount of time in which to complete discovery. Counsel for the plaintiff are permitted, although not required, to take the depositions of those who submitted an affidavit/declaration in support of the City's Status Report relating to discovery. 68 . See, e.g. FTC v. Advocate Health Care Network, 162 F.Supp.3d 666, 671 (N.D. Ill. 2016); Tellabs v. Fujitsu, 283 F.R.D. 374 (N.D.Ill. 2012). Compare Schmidt v. Astrue, 496 F.3d 833, 842 (7th Cir. 2007). Should the plaintiff decide to take one or more such depositions, the subject matter is limited to the declarations in the case. Counsel are urged to call chambers at 312-435-5601 if any issues arise during any depositions. Counsel shall continue to file a written status report with declarations three business days before each status hearing with a copy delivered to chambers pursuant to Local Rule 5.2(f). The reports should focus not only on the difficulties claimed to prevent discovery, but on what discovery is next and when it will be made. Mailed notice (jms, ) (Entered: 12/02/2019)

MINUTE entry before the Honorable Jeffrey Cole:At the request of the parties, the status hearing set for 12/16/19 is reset to 12/19/19 at 8:30 a.m. (rbf, ) (Entered: 12/04/2019)

TRANSCRIPT OF PROCEEDINGS held on 06-13-18 before the Honorable Robert M. Dow, Jr. Court Reporter Contact Information: Kristin M Ashenhurst, CSR, RDR, CRR, (312)818-6549. <P>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.</P> Redaction Request due 1/2/2020. Redacted Transcript Deadline set for 1/13/2020. Release of Transcript Restriction set for 3/10/2020. (Ashenhurst, Kristin) (Entered: 12/11/2019)

TRANSCRIPT OF PROCEEDINGS held on 07-17-18 before the Honorable Robert M. Dow, Jr. Court Reporter Contact Information: Kristin M Ashenhurst, CSR, RDR, CRR, (312)818-6549. <P>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.</P> Redaction Request due 1/2/2020. Redacted Transcript Deadline set for 1/13/2020. Release of Transcript Restriction set for 3/10/2020. (Ashenhurst, Kristin) (Entered: 12/11/2019)

TRANSCRIPT OF PROCEEDINGS held on 04-18-19 before the Honorable Robert M. Dow, Jr. Court Reporter Contact Information: Kristin M Ashenhurst, CSR, RDR, CRR, (312)818-6549. <P>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.</P> Redaction Request due 1/2/2020. Redacted Transcript Deadline set for 1/13/2020. Release of Transcript Restriction set for 3/10/2020. (Ashenhurst, Kristin) (Entered: 12/11/2019)

TRANSCRIPT OF PROCEEDINGS held on 5/29/19 before the Honorable Robert M. Dow, Jr. Court Reporter Contact Information: Kristin M Ashenhurst, CSR, RDR, CRR, (312)818-6549. <P>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.</P> Redaction Request due 1/2/2020. Redacted Transcript Deadline set for 1/13/2020. Release of Transcript Restriction set for 3/10/2020. (Ashenhurst, Kristin) (Entered: 12/11/2019)

TRANSCRIPT OF PROCEEDINGS held on 06-28-19 before the Honorable Robert M. Dow, Jr. Court Reporter Contact Information: Kristin M Ashenhurst, CSR, RDR, CRR, (312)818-6549. <P>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.</P> Redaction Request due 1/2/2020. Redacted Transcript Deadline set for 1/13/2020. Release of Transcript Restriction set for 3/10/2020. (Ashenhurst, Kristin) (Entered: 12/11/2019)

TRANSCRIPT OF PROCEEDINGS held on 08-21-19 before the Honorable Robert M. Dow, Jr. Court Reporter Contact Information: Kristin M Ashenhurst, CSR, RDR, CRR, (312)818-6549. <P>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.</P> Redaction Request due 1/2/2020. Redacted Transcript Deadline set for 1/13/2020. Release of Transcript Restriction set for 3/10/2020. (Ashenhurst, Kristin) (Entered: 12/11/2019)

MOTION by Plaintiff Access Living of Metropolitan Chicago for leave to file excess pages for Plaintiff's Motion for Clarification on the Scope of Discovery (Klar, Jennifer) (Entered: 12/16/2019)

MOTION by Plaintiff Access Living of Metropolitan Chicago to clarify the Scope of Discovery and/or Enforcement of the Court's Decision Denying the Motion to Dismiss (Attachments: # 1 Declaration of Lila Miller, # 2 Exhibit List, # 3 Exhibit 1 - April 17, 2019 Email from L. Arandes, # 4 Exhibit 2 - Excerpts from April 18, 2019 Hearing Transcript, # 5 Exhibit 3 - May 24, 2019 Letter from M. Khetarpal, # 6 Exhibit 4 - June 13, 2019 Letter from M. Khetarpal, # 7 Exhibit 5 - Excerpts from June 18, 2019 Hearing Transcript, # 8 Exhibit 6 - June 24, 2019 Email from J. Klar, # 9 Exhibit 7 - July 19, 2019 Email from M. Khetarpal, # 10 Exhibit 8 - July 16, 2019 Email from J. Klar, # 11 Exhibit 9 - August 14, 2019 Email from M. Khetarpal, # 12 Exhibit 10 - August 15, 2019 Email from J. Klar, # 13 Exhibit 11 - August 20, 2019 Letter from J. Klar, # 14 Exhibit 12 - August 21, 2019 Hearing Transcript, # 15 Exhibit 13 - August 26, 2019 Email from J. Klar, # 16 Exhibit 14 - September 4, 2019 Letter from J. Klar, # 17 Exhibit 15 - September 11, 2019 Letter from M. Khetarpal, # 18 Exhibit 16 - Excerpts from September 25, 2019 Hearing Transcript, # 19 Exhibit 17 - Excerpts from November 12, 2019 Hearing Transcript, # 20 Exhibit 18 - Defendant's Objections to Instructions for Plaintiff's First Set of Requests for Production, # 21 Exhibit 19 - Excerpts from December 2, 2019 Hearing Transcript)(Klar, Jennifer) (Entered: 12/16/2019)

1 Declaration of Lila Miller

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2 Exhibit List

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3 Exhibit 1 - April 17, 2019 Email from L. Arandes

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4 Exhibit 2 - Excerpts from April 18, 2019 Hearing Transcript

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5 Exhibit 3 - May 24, 2019 Letter from M. Khetarpal

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6 Exhibit 4 - June 13, 2019 Letter from M. Khetarpal

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7 Exhibit 5 - Excerpts from June 18, 2019 Hearing Transcript

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8 Exhibit 6 - June 24, 2019 Email from J. Klar

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9 Exhibit 7 - July 19, 2019 Email from M. Khetarpal

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10 Exhibit 8 - July 16, 2019 Email from J. Klar

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11 Exhibit 9 - August 14, 2019 Email from M. Khetarpal

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12 Exhibit 10 - August 15, 2019 Email from J. Klar

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13 Exhibit 11 - August 20, 2019 Letter from J. Klar

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14 Exhibit 12 - August 21, 2019 Hearing Transcript

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15 Exhibit 13 - August 26, 2019 Email from J. Klar

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16 Exhibit 14 - September 4, 2019 Letter from J. Klar

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17 Exhibit 15 - September 11, 2019 Letter from M. Khetarpal

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18 Exhibit 16 - Excerpts from September 25, 2019 Hearing Transcript

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19 Exhibit 17 - Excerpts from November 12, 2019 Hearing Transcript

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20 Exhibit 18 - Defendant's Objections to Instructions for Plaintiff's Fi

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21 Exhibit 19 - Excerpts from December 2, 2019 Hearing Transcript

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NOTICE of Motion by Jennifer Irene Klar for presentment of motion to clarify,,,,, 79, motion for leave to file excess pages 78 before Honorable Robert M. Dow Jr. on 12/19/2019 at 10:00 AM. (Klar, Jennifer) (Entered: 12/16/2019)

STATUS Report for December 19, 2019 Hearing by Access Living of Metropolitan Chicago (Klar, Jennifer) (Entered: 12/16/2019)

STATUS Report Defendant City of Chicago's Second Discovery Status Report by City Of Chicago (Attachments: # 1 Exhibit A)(Khetarpal, Monica) (Entered: 12/16/2019)

MINUTE entry before the Honorable Robert M. Dow, Jr: Motion hearing held. Motion for leave to file excess pages 78 is granted. Motion to clarify 79 is taken under advisement; response is due 1/21/2020; the courtroom deputy will contact the parties to set a further hearing after the Court reviews all of the documents. Mailed notice (cdh, ) (Entered: 12/20/2019)

MINUTE entry before the Honorable Jeffrey Cole:Status hearing held and continued to 1/22/19 at 8:30 a.m.Mailed notice (jms, ) (Entered: 12/20/2019)

MINUTE entry before the Honorable Jeffrey Cole: Status hearing date of 1/6/2020 is stricken.Mailed notice (jms, ) (Entered: 12/20/2019)

TRANSCRIPT OF PROCEEDINGS held on 11/12/19 before the Honorable Jeffrey Cole. Order Number: 36874. Court Reporter Contact Information: Patrick Mullen, (312) 435-5565, patrick_mullen@ilnd.uscourts.gov. 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 1/24/2020. Redacted Transcript Deadline set for 2/3/2020. Release of Transcript Restriction set for 4/2/2020. (Mullen, Patrick) (Entered: 01/03/2020)

NOTICE by Jennifer Irene Klar of Change of Address (Klar, Jennifer) (Entered: 01/16/2020)

NOTICE by Michael Allen of Change of Address (Allen, Michael) (Entered: 01/16/2020)

NOTICE by Lila Rebecca Miller of Change of Address (Miller, Lila) (Entered: 01/16/2020)

NOTICE by Kali Jones Schellenberg of Change of Address (Schellenberg, Kali) (Entered: 01/16/2020)

STATUS Report for January 22, 2020 Hearing by Access Living of Metropolitan Chicago (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6)(Klar, Jennifer) (Entered: 01/16/2020)

STATUS Report Defendant City of Chicago's Third Discovery Status Report by City Of Chicago (Khetarpal, Monica) (Entered: 01/16/2020)

RESPONSE by City Of Chicagoin Opposition to MOTION by Plaintiff Access Living of Metropolitan Chicago to clarify the Scope of Discovery and/or Enforcement of the Court's Decision Denying the Motion to Dismiss 79 DEFENDANT CITY OF CHICAGO'S RESPONSE IN OPPOSITION TO PLAINTIFF ACCESS LIVING'S MOTION FOR CLARIFICATION ON THE SCOPE OF DISCOVERY AND/OR ENFORCEMENT OF THE COURT'S DECISION DENYING THE MOTION TO DISMISS (Khetarpal, Monica) (Entered: 01/21/2020)

MINUTE entry before the Honorable Jeffrey Cole: Status held on 1/22/2020. Status set for 2/5/2020 is stricken. However, status reports will continue to be filed every two weeks. Telephonic status is set for 2/28/2020 at 9:30 am. Mailed notice (yt) (Entered: 01/22/2020)

STATUS Report Defendant City of Chicago's Fourth Discovery Status Report by City Of Chicago (Khetarpal, Monica) (Entered: 02/05/2020)

STATUS Report by Access Living of Metropolitan Chicago (Klar, Jennifer) (Entered: 02/05/2020)