IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

JACQUES RIVERA, 

 

Plaintiff, 

v. 

REYNALDO GUEVARA, et al., 

Defendants. 

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 No. 12 C 4428 

 

 Hon. Joan B. Gottschall, 

 District Judge 

 

 

 JURY TRIAL DEMANDED 

 

 

SUPPLEMENT TO SECTION 2(b) (WITNESSES) 

OF PROPOSED FINAL PRETRIAL ORDER 
PLAINTIFF’S WITNESSES1

WILL CALL 

Jacques Rivera. Contact through counsel, Loevy & Loevy. 

Defendants object to this witness as to certain topics of testimony. See 

Officer Motion in Limine No. 12, 13, and 15. 

Reynaldo Guevara. Contact through counsel, Leinenweber & Daffada. 

 Defendants moves to bar/limit evidence of his 5th Amendment invocation. 

See Guevara Motion In Limine No. 1. 

Orlando Lopez. 9212 Roedean Dr., Cleveland, OH 44129. 

MAY CALL 

 

Joseph Fallon. Contact through counsel, Sotos Law Firm. 

Steve Gawrys. Contact through counsel, Sotos Law Firm. 

John Guzman. Contact through counsel, Sotos Law Firm. 

John Leonard* 

Gillian McLaughlin. Contact through counsel, Sotos Law Firm. 

Edward Mingey. Contact through counsel, Sotos Law Firm. 

Daniel Noon. Contact through counsel, Sotos Law Firm. 

Rocco Rinaldi. Contact through counsel, Sotos Law Firm. 

Joseph Sparks. Contact through counsel, Sotos Law Firm. 

Russell Weingart. Contact through counsel, Sotos Law Firm. 

Paul Zacharias. Contact through counsel, Sotos Law Firm. 

Mike Brasfield. Retained expert, contact through Loevy & Loevy.

Defendants object to this witness. See Officer Motion in Limine No. 2; City 

Motion In Limine No. 6. 

Jennifer Dysart. Retained expert, contact through Loevy & Loevy. 

Defendants object to this witness. See Officer Motion in Limine No. 3. 

                                                            

1 Defendants’ Objection: To the extent Plaintiff’s Witness List violates L.R. 16.1, see City’s Motion in 

Limine No. 8. 
3 

Gary Wells. Retained expert, contact through Loevy & Loevy. 

Defendants object to this witness. See Officer Motion in Limine No. 1; City 

Motion In Limine No. 7. 

Ken Wadas. Criminal Division of the Cook County Courthouse, Chicago, Illinois. 

Defendants object to this witness as to certain topics of testimony. See 

Officer Motion in Limine No. 7. 

John DeLeon. John DeLeon & Associates, 53 W Jackson Blvd #1428, Chicago, IL 60604

Defendants object to this witness because Mr. DeLeon was not disclosed 

pursuant to Fed. R. Civ. P. 26(a) and would cause undue prejudice to Defendants. 

FRE 403. See, Officer MIL No. 4. 

 

Judy Royal. Contact through counsel, Loevy & Loevy 

Jane Raley* 

Cynthia Estes. Contact through counsel, Loevy & Loevy 

Jennifer Linzer. Contact through counsel, Loevy & Loevy 

Cathryn Crawford. Contact through counsel, Loevy & Loevy 

Julie Rosner. Contact through Cook County State’s Attorney’s Office, Chicago, Illinois. 

Larry Victorson. Contact through Cook County State’s Attorney’s Office, Chicago, 

Illinois. 

Craig Letrich. Contact through counsel for City of Chicago. 

John McDonald. Contact through counsel for City of Chicago. 

James Moriarty. Contact through counsel for City of Chicago. 

William Dorsch. 201 N. Salem Dr., Schaumburg, IL 60194. 

Defendants object to testimony by this witness offered pursuant to Fed. R. 

Evid. 404(b). See Officer Motion in Limine No. 18. 

Stephen Machain. Contact through counsel for City of Chicago. 

Lori Amaro. 4919 Econ Circle, Apt. 271, Orlando, FL 32817. 

Pastor Thomas Bryant. 631 Lincoln Street, Steelton, PA 17112. 

Felipe Nieves. 605 N Reed St Joliet, IL 60435; 2615 Sherman St., Hollywood, FL 

33020.Ida Osorio Serrano (aka Ada Osorio). 730 N. Throop, 1st Fl, Chicago, IL 60642. 

Jose Rodriguez. 911 Peters St., Albert Lea, MN 56007; 1456 N Maplewood, 2nd Fl. 

Defendants object to this witness. See, Officer Motion in Limine No. 4. 
4 

Guillermo Osorio. 1406 N. Harlem, River Forest, IL. 

Fernando Rivas. Chicago Victory Church, 3445 North Ave., Chicago, IL 606047. 

Darlene Perry. 3125 W. Fullerton, Apt. 306, Chicago, IL. 

Defendants object to this witness as to certain topics of testimony. See 

Officer Motion in Limine No. 13. 

Sofia Matarazzo. Contact through counsel, Loevy & Loevy. 

Gwen Rivera*. Contact through counsel, Loevy & Loevy. 

Jennifer Rivera. Contact through counsel, Loevy & Loevy. 

Richard Rivera. Contact through counsel, Loevy & Loevy. 

Juan Rivera. Contact through counsel, Loevy & Loevy. 

Defendants object to this witness as to certain topics of testimony. See Officer 

Motion In Limine No. 5. 

Arthur Sharkey, M.D.* The Orthopaedic Institute, 4500 Newberry Road, Gainesville, FL. 

Defendants object to this witness because Dr. Sharkey’s testimony is no 

longer relevant in light of the Court’s MSJ ruling. See Officer Motion In Limine No. 

9. 

Carlos Olivero*. 3348 N. Neenah, Chicago, IL 60634. 

George Ruiz*. 5340 S. Keeler, Chicago, IL 60632; 2558 Harding, Chicago, Illinois. 

Angel Villafane*. 2718 N. Mango, Chicago, IL 60639. 

James Spratte*. Contact through counsel for City of Chicago. 

Karen Sullivan*. Contact through counsel for City of Chicago. 

James Hickey. Contact through counsel for City of Chicago. 

Elizabeth Ekl. Reiter Burns, 311 S. Wacker Dr., Chicago, IL 60606. 

Defendants object to this witness because Ms. Ekl was not disclosed pursuant 

to Fed. R. Civ. P. 26(a) and would cause undue prejudice to Defendants. FRE 403. 

See Officer Motion In Limine No. 4. 

Anthony Wronkowski. Contact through counsel for City of Chicago. 

Jose Melendez*, FCI Lompoc, 3600 Guard Rd, Lompoc, CA 93436. 

Defendants object to this witness pursuant to FRE 404(b). See Officers’ 

Motion In Limine No. 18. 
5 

Sam Perez*. Sam Perez, 4106 N. Moody, Chicago, IL.

Defendants object to this witness pursuant to FRE 404(b). See Officers’ 

Motion In Limine No. 18. See also Defendants’ Motion for Sanction to Bar Sam 

Perez From Testifying for Failing to Comply with a Subpoena for His Deposition. 

Dkt. # 229. 

Wilfred Rosario*. 2117 S. Ashland, First Floor, Chicago. 

Defendants object to this witness pursuant to FRE 404(b). See Officers’ 

Motion In Limine No. 18. 

Robert Ruiz*. 5660 W Grand Ave, Chicago, IL 60639. 

Defendants object to this witness pursuant to FRE 404(b). See Officers’ 

Motion In Limine No. 18. 

Sal Ortiz. 5455 W. Newport Ave., Chicago, IL 60641. 

Defendants object to this witness pursuant to FRE 404(b). See Officers’ 

Motion In Limine No. 18. 

Evelyn Diaz, 4821 W. Wolfram, Chicago, IL 60641. 

Defendants object to this witness pursuant to FRE 404(b). See Officers’ 

Motion In Limine No. 18. 

Demetrius Johnson. 4949 W. St. Paul Ave., FL 1, Chicago, Illinois. 

Individual Defendants object to this witness, who was disclosed by Plaintiff 

in support of his Monell claim against the City, based on materiality, relevance 

(FRE 402), and prejudice (FRE 403). To the extent this witness’s testimony is 

admitted against the City, it should be limited against the remaining Defendants 

pursuant to FRE 105. See City’s Motion in Limine No. 5 

Aby Gonzalez. 165 Main St, Bldg 18, Wernersville, PA 19565; 1314 N. Claremont, 2nd 

Fl,, Chicago. 

Individual Defendants object to this witness, who was disclosed by Plaintiff 

in support of his Monell claim against the City, based on materiality, relevance 

(FRE 402), and prejudice (FRE 403). To the extent this witness’s testimony is 

admitted against the City, it should be limited against the remaining Defendants 

pursuant to FRE 105. See City’s Motion in Limine No. 5 
6 

Crystal Marchigiani. Cook County Public Defender, 2650 S California, 8th Floor, 

Chicago, Illinois. 

Individual Defendants object to this witness, who was disclosed by Plaintiff 

in support of his Monell claim against the City, based on materiality, relevance 

(FRE 402), and prejudice (FRE 403). To the extent this witness’s testimony is 

admitted against the City, it should be limited against the remaining Defendants 

pursuant to FRE 105. See City’s Motion in Limine No. 5 

Curtis Kirkland. 4806 W. Congress Pkwy, Chicago, Illinois. 

Individual Defendants object to this witness, who was disclosed by Plaintiff 

in support of his Monell claim against the City, based on materiality, relevance 

(FRE 402), and prejudice (FRE 403). To the extent this witness’s testimony is 

admitted against the City, it should be limited against the remaining Defendants 

pursuant to FRE 105. See City’s Motion in Limine No. 5 

Judge Clarence Burch. Circuit Court of Cook County, 555 W. Harrison St., Rm. 303 

Chicago, Illinois 60607. 

Individual Defendants object to this witness, who was disclosed by Plaintiff 

in support of his Monell claim against the City, based on materiality, relevance 

(FRE 402), and prejudice (FRE 403). To the extent this witness’s testimony is 

admitted against the City, it should be limited against the remaining Defendants 

pursuant to FRE 105. See City’s Motion in Limine No. 5 

Record Keepers: Chicago Police Department, Cook County Public Defender’s Office, 

Cook County State’s Attorney’s Office, Stroger Hospital and Cook County Hospital, 

Medical Records of Dr. Arthur Sharkey, Northwestern University School of Law. 

Plaintiff reserves the right to call any of the witnesses listed by Defendants City of 

Chicago or Defendants Fallon, Gawrys, Guevara, Guzman, Leonard, McLaughlin, Mingey, 

Noon, Rinaldi, Sparks, Weingart, or Zacharias. 

* denotes witnesses who may also provide testimony by depositions 
7 

DEFENDANTS’ WITNESSES 

 MAY CALL 

Jacques Rivera - Contact through counsel, Loevy & Loevy 

Joseph Fallon – Contact through counsel, The Sotos Law Firm, P.C. 

Steve Gawrys – Contact through counsel, The Sotos Law Firm, P.C. 

Reynaldo Guevara – Contact through counsel, The Sotos Law Firm, P.C. 

John Guzman – Contact through counsel, The Sotos Law Firm, P.C.

Jack Leonard* 

Gillian McLaughlin – Contact through counsel, The Sotos Law Firm, P.C. 

Ed Mingey – Contact through counsel, The Sotos Law Firm, P.C. 

Daniel Noon – Contact through counsel, The Sotos Law Firm, P.C 

Rocco Rinaldi* – Contact through counsel, The Sotos Law Firm, P.C. 

Joseph Sparks - Contact through counsel, The Sotos Law Firm, P.C. 

Russell Weingart* – Contact through counsel, The Sotos Law Firm, P.C. 

Paul Zacharias – Contact through counsel, The Sotos Law Firm, P.C. 

John Boyle - Chicago, Illinois 

Plaintiff objects to this witness because Defendants agreed during discovery to 

withdraw their reliance on this witness and not to call him at trial. 

Cathryn Crawford 

Bill Dorsch – Schaumburg, Illinois 

Cynthia Estes – Contact through Loevy & Loevy 

Jennifer Linzer – Contact through Lovey & Loevy 

Orlando Lopez 

Ramon Lopez – 2058 N. Kilpatrick Street, Chicago 

Stephen Machain 

Thomas McGreal (impeachment only) – Contact through Cook County State’s Attorney’s 

Office, Chicago, Illinois 

Plaintiff objects to this witness because he was not disclosed pursuant to Federal 

Rule of Civil Procedure 26(a) and calling him would cause undue prejudice to Plaintiff. 

Felipe Nieves* - Omaha, Nebraska 

Plaintiff objects to this witness on certain subjects. See Plaintiff’s motion in limine

regarding Felipe Nieves. 

Darren O’Brien – Contact through Cook County State’s Attorney’s Office, Chicago, 

Illinois 

Jane Raley* 
8 

Julie Rosner – Contact through counsel, Cook County State’s Attorney’s Office, Chicago, 

Illinois 

Judith Royal – Contact through counsel, Loevy & Loevy 

George Ruiz – 2558 Harding, Chicago, Illinois 

James Spratte – Contact through counsel, Rock Fusco & Connelly 

Plaintiff objects to the extent this witness seeks to provide any opinion testimony 

under Rules 702, 703, or 705, since he was not disclosed under Fed. R. Civ. P. 26(a)(2). 

Larry Victorson – Contact through Cook County State’s Attorney’s Office, Chicago, 

Illinois 

Ken Wadas – Criminal Division of the Cook County Courthouse, Chicago, Illinois. 

The following witnesses relate solely to Plaintiff’s Monell claims, and are subject to the 

Defendants’ Motion to Bifurcate Trial. 

James Hickey - Contact through counsel, Rock, Fusco & Connelly, LLC 

Plaintiff objects to the extent this witness seeks to provide any opinion testimony 

under Rules 702, 703, or 705, since he was not disclosed under Fed. R. Civ. P. 26(a)(2). 

Cmdr. Robert Klimas – Contact through counsel, Rock, Fusco & Connelly, LLC 

Plaintiff objects to the extent this witness seeks to provide any opinion testimony 

under Rules 702, 703, or 705, since he was not disclosed under Fed. R. Civ. P. 26(a)(2). 

Lt. Karen Sullivan - Contact through counsel, Rock, Fusco & Connelly, LLC 

Plaintiff objects to the extent this witness seeks to provide any opinion testimony 

under Rules 702, 703, or 705, since he was not disclosed under Fed. R. Civ. P. 26(a)(2). 

EXPERTS 

John Mallul 

Judge John Wasilewski 

Dr. John Wixted 

The following witnesses relate solely to Plaintiff’s Monell claims, and are subject to the 

Defendants’ Motion to Bifurcate Trial. 

Jeffrey Noble 

Plaintiff objects to this witness. See Plaintiff’s motion in limine regarding Jeffrey 

Noble. 
9 

Bernard Murray 

Plaintiff objects to this witness. See Plaintiff’s motion in limine regarding Jeffrey 

Noble. 

Defendants have sought to bar evidence pursuant to Fed. R. Evid. 404(b). See Officer’s 

Motion in Limine No. 18. If Defendants motion is denied in whole or in part, Defendants may 

also call the following witnesses: 

Plaintiff’s general objection to Defendants’ 404(b) list: Plaintiff objects to these 

witnesses based on relevance, as cumulative, and as unfairly prejudicial. Plaintiff was 

ordered to limit himself to ten 404(b) witnesses and did so. Defendants did not do so and 

instead improperly seek to call multiple 404(b) witnesses in rebuttal to each 404(b) witness 

called by Plaintiff. 

Alberto Rodriguez (other vic/wit), FCI Forrest City Fed. Penitentiary, 1400 Dale 

Bumpers Rd., Forrest City, AR. 72335. 

Plaintiff objects because this witness is one of three witnesses disclosed in response 

to Plaintiff’s witness Jose Melendez, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

ASA William Farrel, Cook County State’s Attorney Office, Chicago, IL 

Plaintiff objects because this witness is one of three witnesses disclosed in response 

to Plaintiff’s witness Jose Melendez, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

Det. John McMurray, available upon request of counsel 

Plaintiff objects because this witness is one of three witnesses disclosed in response 

to Plaintiff’s witness Jose Melendez, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

Juan Michael Delgado, 10301 Delmar Cir., Tampa, FL. 

Plaintiff objects because this witness is one of six witnesses disclosed in response to 

Plaintiff’s witness Sal Ortiz, and the testimony is therefore cumulative of other witnesses. 

See also Plaintiff’s general objection, above. 

Guillermo Vasquez, 1732 Pratt Blvd. , Chicago, IL 773-381-1536. 
10 

Plaintiff objects because this witness is one of six witnesses disclosed in response to 

Plaintiff’s witness Sal Ortiz, and the testimony is therefore cumulative of other witnesses. 

See also Plaintiff’s general objection, above. 

Edwin Gomez, 4619 W. Schubert, Chicago, IL. 

Plaintiff objects because this witness is one of six witnesses disclosed in response to 

Plaintiff’s witness Sal Ortiz, and the testimony is therefore cumulative of other witnesses. 

See also Plaintiff’s general objection, above. 

Det. William O'Donnell, available upon request of counsel 

Plaintiff objects because this witness is one of six witnesses disclosed in response to 

Plaintiff’s witness Sal Ortiz, and the testimony is therefore cumulative of other witnesses. 

See also Plaintiff’s general objection, above. 

James Bailey, 312-603-6932 

Plaintiff objects because this witness is one of six witnesses disclosed in response to 

Plaintiff’s witness Sal Ortiz, and the testimony is therefore cumulative of other witnesses. 

See also Plaintiff’s general objection, above. 

Eileen Rubin, Cook County State’s Attorney Office, Chicago, IL 

Plaintiff objects because this witness is one of six witnesses disclosed in response to 

Plaintiff’s witness Sal Ortiz, and the testimony is therefore cumulative of other witnesses. 

See also Plaintiff’s general objection, above. 

Maria Rodriguez, 3317 N. Keeler, Apt. #2, Chicago, IL. 

Plaintiff objects because this witness is one of two witnesses disclosed in response to 

Plaintiff’s witness Wilfred Rosario, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

Det. John McKenna, available upon request of counsel 

Plaintiff objects because this witness is one of two witnesses disclosed in response to 

Plaintiff’s witness Wilfred Rosario, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

Ofc. Kenneth Moore, available upon request of counsel 

Plaintiff objects because this witness was disclosed solely to rebut Plaintiff’s 404(b) 

witness Julio Sanchez, who Plaintiff has withdrawn. 
11 

Jose Reyes, 10310 Zachary Cir. 51, Riverview, FL. 33578. 

Plaintiff objects because this witness is one of three witnesses disclosed in response 

to Plaintiff’s witness Robert Ruiz, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

Sean Gallagher, Cook County State’s Attorney Office, Chicago, IL 

Plaintiff objects because this witness is one of three witnesses disclosed in response 

to Plaintiff’s witness Robert Ruiz, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

Chiao Lee, Cook County State’s Attorney Office, Chicago, IL 

Plaintiff objects because this witness is one of three witnesses disclosed in response 

to Plaintiff’s witness Robert Ruiz, and the testimony is therefore cumulative of other 

witnesses. See also Plaintiff’s general objection, above. 

Individual Defendants also reserve the right to call any of the witnesses listed by Plaintiff 

or Defendant City. 

Defendant City reserves the right to call any of the witnesses listed by Plaintiff or 

Individual Defendants. 

* denotes witnesses who may also provide testimony by depositions 
12 

        Respectfully Submitted, 

/s/Jon Loevy 

Counsel for Plaintiff 

Jon Loevy 

Russell Ainsworth 

Anand Swaminathan 

Steven Art 

Rachel Brady 

Loevy & Loevy 

311 N. Aberdeen St. 

Third Floor 

Chicago, Illinois 60607 

(312) 243-5900 

steve@loevy.com 

Locke Bowman 

Solange and Roderick 

MacArthur Justice Center 

Northwestern University 

Pritzker School of Law 

375 E. Chicago Ave. 

Chicago, Illinois 60611 

(312) 503-3100 

/s/ Jeffrey Given 

Counsel for Defendants 

Gawrys, Noon, Fallon, 

Sparks, Zacharias, Guzman, 

McLaughlin, Mingey, 

Weingart, Rinaldi; and the 

Estate of John Leonard 

James G. Sotos 

Jeffrey N. Given 

Caroline P. Golden 

Joseph M. Polick 

David A. Brueggen 

The Sotos Law Firm, P.C. 

550 E. Devon Ave., Suite 150 

Itasca, IL 60143 

(630) 735-3300 

jgiven@sotoslaw.com 

/s/ Thomas Leinenweber 

Counsel for Defendant 

Guevara 

Thomas M. Leinenweber 

James V. Daffada 

Leinenweber Baroni & 

Daffada, LLC 

120 N. LaSalle St., Suite 2000 

Chicago, IL 60602 

(312) 663-3003 

thomas@ilesq.com

/s/ Eileen Rosen 

Counsel for City of Chicago

Eileen E. Rosen 

Catherine M. Barber 

Theresa B. Carney 

Rock Fusco & Connelly, LLC 

321 N. Clark Street, 

Suite 2200 

Chicago, Illinois 60654 

(312) 494-1000 

erosen@rfclaw.com 

 
13 

CERTIFICATE OF SERVICE

 I, Jon Loevy, an attorney, certify that on May 25, 2018, I filed the foregoing Supplement 

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

 /s/ Jon Loevy 

One of Plaintiff’s Attorneys