IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

DANIEL MEDINA and NIKITA GROSS, 

Plaintiffs, 

v. 

PUBLIC STORAGE, INC., a Maryland Real 

Estate Investment Trust, WILLIS INSURANCE 

SERVICES OF CALIFORNIA, INC., a 

California Corporation, and PS ILLINOIS 

TRUST, 

Defendants. 

 

Civil Action No. 1:12-cv-00170 

Honorable Charles R. Norgle, Sr.

RULE 68 OFFER OF JUDGMENT

In accordance with Rule 68 of the Federal Rules of Civil Procedure, Defendants Public 

Storage (erroneously sued as Public Storage, Inc.) and PS Illinois Trust (collectively “Public 

Storage”) hereby offer to allow judgment to be taken in favor of Plaintiffs Daniel Medina and 

Nikita Gross (collectively “Plaintiffs”) and an award to be entered in accordance with the terms 

and conditions set forth below: 

I. PAYMENT FOR LOSS BY BURGLARY

Within fourteen (14) days of acceptance of this agreement, Public Storage will, up to a 

maximum of $5,000.00, pay the losses Plaintiffs realized as a result of the robbery alleged in the 

Complaint filed in the Circuit Court of Cook County, Illinois under the caption Medina, et al. v. 

Public Storage, Inc., et al., Case No. 2011-L-11664, removed to the United States District Court 

for the Northern District of Illinois, Case No. 12-cv-170.

II. ATTORNEYS’ FEES AND COSTS

Within fourteen (14) days of Plaintiffs’ acceptance of this offer, Public Storage shall pay 

to Plaintiffs’ counsel the actual amount of attorneys’ fees and costs incurred by Plaintiffs’ 

counsel in this action, up to a maximum sum of $5,000.00. Said payment shall constitute 

Case: 1:12-cv-00170 Document #: 10 Filed: 01/24/12 Page 1 of 3 PageID #:63
- 2 - 

payment in full for all costs, attorneys’ fees, and any other expensed incurred by Plaintiffs and 

their counsel. 

III. RELEASE

Within five (5) days after receipt of the payments referenced above, Plaintiffs will 

dismiss the current action entitled, Medina, et al. v. Public Storage, Inc., et al., Case No. 2011-L11664, removed to the United States District Court for the Northern District of Illinois, Case 

No. 12-cv-170, subject to the terms and conditions set forth above. The Court will retain 

continuing jurisdiction over the enforcement and interpretation of this agreement. 

IV. METHOD OF ACCEPTANCE

Plaintiffs may accept this offer via written notice. 

V. EXPIRATION

In accordance with Rule 68 of the Federal Rules of Civil Procedure, this offer will be 

deemed withdrawn if not accepted within ten (10) days. 

VI. LIMITATIONS UPON USE

Evidence of this offer, if not accepted, shall only be admissible pursuant to the conditions 

of Fed R. Civ. P. 68(b) in a proceeding to determine costs or in briefing submitted to the Court. 

Dated: January 24, 2012 s/ Dean A. Dickie 

 Dean A. Dickie 

Ryan C. Williams 

MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. 

225 West Washington Street, Suite 2600 

Chicago, IL 60606 

Phone: (312) 460-4200 

Fax: (312) 460-4288 

Counsel for Defendants Public Storage and 

PS Illinois Trust 

 

Case: 1:12-cv-00170 Document #: 10 Filed: 01/24/12 Page 2 of 3 PageID #:64
- 3 - 

CERTIFICATE OF SERVICE

I hereby certify that on January 24, 2012, the foregoing Rule 68 Offer of Judgment was 

filed and served on all counsel of record via the Court’s CM/ECF system. 

On January 24, 2012, the foregoing Rule 68 Offer of Judgment was served by U.S. Mail, 

postage prepaid, on the following: 

Henri Harmon, Esq. 

Ethan Dunn, Esq. 

MAXWELL DUNN, PLC 

26339 Woodward Avenue 

Huntington Woods, MI 48070 

s/ Dean A. Dickie 

Dean A. Dickie 

 

Case: 1:12-cv-00170 Document #: 10 Filed: 01/24/12 Page 3 of 3 PageID #:65