IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

JACQUES RIVERA, ) 

 ) No. 12 C 4428 

 Plaintiff, ) 

 ) Hon. Joan B. Gottschall, 

 v. ) District Judge 

 ) 

REYNALDO GUEVARA, et al., ) Hon. Mary M. Rowland, 

 ) Magistrate Judge 

Defendants. ) 

 ) JURY TRIAL DEMANDED 

 ) 

PLAINTIFF’S MOTION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL

 Pursuant to Local Rules 5.8 and 26.2, Plaintiff JACQUES RIVERA, by his attorneys, 

respectfully requests an Order granting Plaintiff permission to file exhibits to his reply in support 

of Plaintiff’s Motion to Compel Production of Monell-Related Discovery, Doc. No. 164, under 

seal, stating as follows: 

1. Exhibits to Plaintiff’s reply in support of his Motion to Compel Production of 

Monell-Related Discovery, which is to be filed later today, will include documents that have 

been marked confidential pursuant to the Court’s protective order in this case. Doc. No. 41. 

2. Accordingly, good cause exists to allow Plaintiff to file these documents under 

seal rather than publicly. 

3. In compliance with Local Rules 5.8 and 26.2, Plaintiff: (a) will provisionally file 

exhibits to his reply electronically under seal after filing this motion; (b) will file electronically a 

public-record version of his exhibits; and (c) is now moving this Court for leave to file the nonredacted version of the exhibits to his reply under seal. 

WHEREFORE, Plaintiff respectfully requests that the Court enter an Order granting him 

permission to file the aforementioned exhibits under seal. 

Case: 1:12-cv-04428 Document #: 179 Filed: 04/15/15 Page 1 of 3 PageID #:3342
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 RESPECTFULLY SUBMITTED, 

 JACQUES RIVERA 

 By: /s/ Steven Art 

 Counsel for Jacques Rivera 

Arthur Loevy Locke E. Bowman 

Jon Loevy Sheila Bedi 

Michael Kanovitz David Shapiro 

Russell Ainsworth Alexa Van Brunt 

Elizabeth Mazur RODERICK MACARTHUR JUSTICE CENTER 

Anand Swaminathan Northwestern University School of Law 

Steve Art 375 E. Chicago Avenue 

LOEVY & LOEVY Chicago, Illinois 60611 

312 N. May St., Ste. 100 (312) 503-0844 

Chicago, IL 60607 

(312) 243-5900 J. Samuel Tenenbaum 

BLUHM LEGAL CLINIC 

Northwestern University School of Law 

375 E. Chicago Avenue 

Chicago, Illinois 60611 

(312) 503-8576 

Case: 1:12-cv-04428 Document #: 179 Filed: 04/15/15 Page 2 of 3 PageID #:3343
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CERTIFICATE OF SERVICE

 I, Steven Art, an attorney, certify that on April 15, 2015, I filed the foregoing 

PLAINTIFF’S MOTION FOR LEAVE TO FILE DOCUMENTS UNDER SEAL using the 

Court’s CM/ECF system, which effected service on all counsel of record listed below. 

 /s/ Steven Art 

 Steven Art 

 Counsel for Jacques Rivera 

 

Attorneys for Defendants Guevara, Gawrys, Noon, Guzman, Fallon, Sparks, Zacharias, 

McLaughlin, Leonard, Mingey, Weingart, and the Estate of Rocco Rinaldi

James G. Sotos 

Elizabeth A. Ekl 

Jeffrey N. Given 

Caroline P. Golden 

Andrew Grill 

The Sotos Law Firm 

550 E. Devon Ave., Suite 150 

Itasca, Illinois 60143 

Attorneys for Defendant City of Chicago

Eileen E. Rosen 

John J. Rock 

Silvia M. Masters 

Stacy A. Benjamin 

Erin N. Bybee 

Catherine Barber 

Rock Fusco & Connelly, LLC 

321 N. Clark Street, Suite 2200 

Chicago, Illinois 60654 

(312) 494-1000 

Case: 1:12-cv-04428 Document #: 179 Filed: 04/15/15 Page 3 of 3 PageID #:3344