IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

JACQUES RIVERA, ) 

) No. 12 CV 004428 

 Plaintiff, ) 

) 

 v. ) The Honorable Joan B. Gottschall 

) 

REYNALDO GUEVARA, et al., ) 

 ) 

 Defendants. ) 

 UNOPPOSED MOTION FOR SHORT EXTENSION OF TIME TO FILE 

SUMMARY JUDGMENT AND MOTION FOR LEAVE TO FILE OVERSIZED BRIEFS 

 Defendants Reynaldo Guevara, Steve Gawrys, Daniel Noon, Joseph Fallon, Joseph 

Sparks, Paul Zacharias, John Guzman, Gillian McLaughlin, the Estate of John Leonard, Edward 

Mingey, Russell Weingart and Rocco Rinaldi (“Defendant Officers”), and Defendant City of 

Chicago, by their attorneys, and with no objections from Plaintiff, move this Court for a short 

extension of time to file their motions for summary judgment and for leave to file oversized 

briefs and state: 

 1. Defendants’ motions for summary judgment are currently due on Friday, August 

18, 2017. The Defendant Officers and the City are filing separate motions on the distinct claims 

against them. 

 2. Due to a number of both personal and professional obligations, Defendants 

request a short extension of three business days, until Wednesday, August 23, to file their 

motions. 

 3. Also, Defendants each move this Court for leave to file oversized briefs. Each of 

Defendants’ motions, which are case-dispositive, involves a large number of complex claims, 

issues and facts. The twelve individual Defendant Officers’ motion must address claims of 

Case: 1:12-cv-04428 Document #: 295 Filed: 08/15/17 Page 1 of 4 PageID #:6082
2 

Brady violations, fabrication of evidence, manipulation of a witness, conspiracy, failure to 

intervene, malicious prosecution, and intentional infliction of emotional distress; the City must 

address several broad Monell claims. 

 4. In light of the number and complexity of the claims, Defendants ask leave to file 

oversized briefs of an additional ten pages each. That said, Defendants are very hopeful their 

final briefs will not reach that number of additional pages. 

 5. Consistent with their motions, Defendants also move to adjust the full briefing 

schedule by an additional three business days, and Defendants have no objection if Plaintiff 

requests additional pages for his own oversized briefs. 

 6. This motion is not being made for the purpose of causing undue delay, and will 

not result in prejudice to any party. 

 7. Counsel for Defendants have communicated with counsel for Plaintiff regarding 

these motions, and Plaintiff has stated he has no objection. 

 WHEREFORE, Defendants request this Court extend the time that Defendants’ 

summary judgment motions are due by three days, to August 23, 2017, to adjust the remaining 

briefing schedule accordingly, and to allow Defendants to each file oversized memoranda in 

support of up to 25 pages each. 

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Date: August 15, 2017 Respectfully Submitted,

/s/ Eileen E. Rosen /s/ Jeffrey N. Given 

EILEN E. ROSEN JEFFREY N. GIVEN 

One of the Attorneys for City of Chicago One of the Attorneys for Individual 

 Defendants 

Eileen E. Rosen James G. Sotos

Stacy A. Benjamin Jeffrey N. Given

Catherine M. Barber Caroline P.Golden 

Theresa B. Carney Jeffrey R. Kivetz 

Rock Fusco & Connelly, LLC The Sotos Law Firm, P.C. 

321 N. Clark, Suite 2200 550 E. Devon Avenue, Suite 150.

Chicago, IL 60654 Itasca, IL 60143 

Chicago, IL 60654 Itasca, IL 60143 

Tel: (312)494-1000 Tel: (630) 735-330 

erosen@rfclaw.com jgiven@jsotoslaw.com 

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CERTIFICATE OF SERVICE

 I hereby certify under penalty of perjury pursuant to 28 U.S.C.A. § 1746 that on August 

15, 2017, I electronically filed the foregoing Defendants’ Unopposed Motion for Short 

Extension of Time to File Summary Judgment and Motion for Leave to File Oversized 

Briefs with the Clerk of the Court using the CM/ECF system which will send notification of 

such filing to the following CM/ECF participants below. 

Attorneys for Plaintiff Attorneys for City of Chicago 

Arthur R. Loevy Eileen E. Rosen

Jonathan I. Loevy Stacy A. Benjamin 

Elizabeth N. Mazur Catherine M. Barber 

Russel Ainsworth Theresa B. Carney 

Michael I. Kanovitz Rock Fusco & Connelly, LLC 

Steven E. Art 321 N. Clark Street, Suite 2200 

Anad Swaminathan Chicago, IL 60654 

311 N. Aberdeen (312)494-1000 

Chicago, IL 60607 (312)494-1001 (fax) 

(312)243-5900 erosen@rfclaw.com

(312) 243-5902 (Fax) sbenjamin@rfclaw.com

loevylaw@loevy.com cbarber@rfclaw.com

jon@loevy.com tcarney@rfclaw.com

Elizabethm@loevy.com

russell@loevy.com

mike@loevy.com

steve@loevy.com

annad@loevy.com

J. Samuel Tenebaum 

Bluhm Legal Clinic 

375 East Chicago Avenue 

Chicago, IL 60611 

(312) 503-4808 

s-tenenbaum@law.northwestern.edu

Locke E. Bowman, III 

Alexa Van Brunt 

Roderick MacArthur Justice Center 

Northwestern University School of Law 

375 East Chicago Aveneu 

Chicago, IL 60611 

(312)503-0844 

(312)503-1272 (fax) 

l-bowman@law.northwestern.edu

a-vanbrunt@law.northwestern.edu

 

/s/ Jeffrey N. Given 

 JEFFREY N. GIVEN, Attorney No. 6184989 

One of the Attorneys for Individual Defendants 

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