IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

ROBERT G. ALAMO, ) 

) 

Plaintiff, ) 

) 

v. ) No. 12-cv-04327 

)

THE CITY OF CHICAGO ) Judge Sharon Johnson Coleman 

and CHARLIE BLISS, in his ) Magistrate Judge Sidney I. Schenkier 

individual capacity, ) 

) 

Defendants. ) 

THE PARTIES’ JOINT DISCOVERY STATUS REPORT

Plaintiff and defendants, pursuant to the Court’s order regarding the status of 

discovery, submit their joint status report outlining which depositions have been completed, 

which depositions are scheduled to be taken, which unscheduled depositions remain to be 

taken, and what other outstanding discovery issues exist. Their responses are as follows:

I. Depositions

A. Completed Depositions

The plaintiff has taken the depositions of the following individuals:

• Defendant Charlie Bliss, 

• Carmelita Wiley-Earls, 

• Mike Daniels, 

• Steven Chikorotis, and 

• Edgar Ignacio (under Federal Rule of Civil Procedure 30(b)(6)).

B. Scheduled Depositions

The plaintiff and defendants have scheduled depositions for the following individuals:

• Gary Kuykendall on May 7 or 9, 2019,

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• Sylvia Tienda on May 16, 2019, and 

• Adrienne Bryant on May 21, 2019. 

C. Remaining Depositions to be Scheduled

The plaintiff and defendants have not yet scheduled depositions for the following fact 

witnesses. The plaintiffs intend to depose:

• William Wong, 

• Edgar Ignacio, 

• Hugh Russell, and

• Individual firefighters identified as similarly-situated.

The defendants intend to depose:

• Dr. Daniel Martinez,

• Dr. Thomas Brennan,

• Dr. Carlos Reyes,

• Plaintiff Robert Alamo, and

• Any other witnesses yet to be identified by Plaintiff.

II. Other Discovery Issues: Production of Firehouse Journals

Alamo alleged in his Fourth Amended Complaint that while assigned to CFD Engine 

Company 55, he was excessively detailed to other firehouses as compared to his colleagues.

During his deposition on February 5, 2019, defendant Charlie Bliss acknowledged that 

written journals were maintained at the firehouse that described the day-to-day operations

and staffing of Engine Company 55. February 5, 2019 Tr. 109:25, 110:1–11. Bliss further 

admitted that these journals would include the dates Alamo was detailed to other firehouses.

Id Tr. 110:21–24. This information supports the claim that Alamo was excessively detailed to 

other firehouses as compared to his colleagues. It is the plaintiff’s position that the firehouse 

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journals are covered by Plaintiff’s First Set of Requests to Produce, Number 6, which 

requests “[a]ll documents referring or relating to Plaintiff, including, but not limited to his 

personnel files, if any, and any documents containing evaluations, views, or opinions 

regarding his performance, or which otherwise relate to his employment for the City of 

Chicago Fire Department.” The plaintiff has asked the City to produce the firehouse journals 

for Engine Company 55 and Tower Ladder 63.

In response, the City has requested that the parties meet and confer regarding the 

scope of the request, including date range and firehouse, and the specific information being 

requested, as the journals are maintained in a book format at each of the firehouses and 

thereafter, are warehoused. If a requested journal is located and available, the journal will 

need to be manually reviewed page by page to determine its contents.

Respectfully submitted this 15th day of April 2019, 

Roberto Alamo City of Chicago and Charles Bliss

/s/ Jamie S. Franklin /s/ Melanie Patrick Neely

Jamie S. Franklin, ARDC No 6242916 Melanie Patrick Neely 

The Franklin Law Firm LLC Howard P. Levine 

53 West Jackson Boulevard, Suite 803 City of Chicago 

Chicago, IL 60604 30 North LaSalle Street, Suite 1000

(312) 662-1008 312-744-0898 

(312) 662-1015 (fax) mneely@cityofchicago.org

jsf@thefranklinlawfirm.com Howard.Levine@cityofchicago.org 

Randall D. Schmidt, ARDC No. 3124450

Edwin F. Mandel Legal Aid Clinic

6020 South University Avenue

Chicago, IL 60637

(773) 702-9611

r-schmidt@ucicago.edu

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CERTIFICATE OF SERVICE

 

I, the undersigned, certify that the foregoing document was served on the parties listed 

below via the ECF Service of the United States District Court for the Northern District of 

Illinois on April 15, 2019. 

 

 /s/ Jamie S. Franklin

 

Service List: 

 

Melanie Patrick Neely 

Howard P. Levine 

City of Chicago 

30 North LaSalle Street, Suite 1000 

Chicago, IL 60602 

312-744-0898 

mneely@cityofchicago.org

Howard.Levine@cityofchicago.org 

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