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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Case No. 12 C 4428 

Hon. Joan B. Gottschall, 

District Judge 

Hon. Mary M. Rowland, 

Magistrate Judge 

JURY TRIAL DEMANDED 

PLAINTIFF’S AGREED MOTION FOR LEAVE TO FILE 

NUNC PRO TUNC TWO BUSINESS DAYS LATE HIS OVERSIZED RESPONSE BRIEF

Plaintiff, JACQUES RIVERA, by his attorneys, respectfully requests leave to file his 

Response materials nunc pro tunc. In support, Plaintiff states as follows: 

1. Plaintiff’s Response to Defendants’ Motions for Summary Judgment was due 

Friday, September 15, 2017. 

2. Plaintiff’s counsel have worked diligently on this project, but due to the press of 

other professional commitments, Plaintiff’s counsel required two additional days to complete 

their Response and to gather the exhibits. 

3. Plaintiff’s counsel filed the response today, but because it is late, leave of Court 

nunc pro tunc is required. Plaintiff’s counsel has inquired with Defendants’ counsel, who have 

indicated no objection. 

4. Plaintiff also seeks leave to file an oversized consolidated Response 

memorandum, responding to two separate summary judgment motions filed by the individual 

Defendants and the City of Chicago. There are many issues in dispute, and the record is 

extremely voluminous, including at least 20 depositions and thousands of pages of documents. 

Case: 1:12-cv-04428 Document #: 314 Filed: 09/19/17 Page 1 of 3 PageID #:23845
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Plaintiff has worked hard to provide the Court with sufficient assistance in considering his 

position. The proposed response is 70 pages, and the Defendants have indicated no objection. 

5. Finally, Plaintiff seeks leave to file a combined 161 statements of fact, covering 

both the individual and Monell claims. Again, the Defendants have indicated no objection. 

6. Because of the new schedule and the volume of Plaintiff's filings, as well as an 

upcoming vacation by Defendants’ counsel, Defendants have asked to communicate to the Court 

their request that the date for their reply be October 16, 2017. Plaintiff has no objection. 

WHEREFORE, Plaintiff respectfully asks the Court to grant leave to file nunc pro tunc

his oversized summary judgment response pleadings, and allow Defendants until October 16 to 

file their reply. Plaintiff’s proposed response pleadings are being filed along with this motion. 

 RESPECTFULLY SUBMITTED, 

 JACQUES RIVERA 

 By: /s/ Steve Art 

 One of Plaintiff’s Attorneys 

Arthur Loevy Locke E. Bowman 

Jon Loevy Sheila Bedi 

Russell Ainsworth David Shapiro 

Anand Swaminathan Alexa Van Brunt 

Steve Art MACARTHUR JUSTICE CENTER 

LOEVY & LOEVY Northwestern University School of Law 

311 N. Aberdeen St., Third Floor 375 E. Chicago Ave., 8th Floor 

Chicago, IL 60607 Chicago, IL 60611 

(312) 243-5900 (312) 503-0844 

steve@loevy.com 

 J. Samuel Tenenbaum 

BLUHM LEGAL CLINIC 

Northwestern University School of Law 

375 E. Chicago Ave., 8th Floor 

Chicago, IL 60611 

(312) 503-8576

Case: 1:12-cv-04428 Document #: 314 Filed: 09/19/17 Page 2 of 3 PageID #:23846
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CERTIFICATE OF SERVICE 

I, Steve Art, an attorney, hereby certify that, on September 19, 2017, I filed the foregoing 

PLAINTIFF’S AGREED MOTION FOR LEAVE TO FILE NUNC PRO TUNC TWO 

BUSINESS DAY LATE HIS OVERSIZED RESPONSE BRIEF using the Court’s CM/ECF 

system, which effected service on all counsel of record. 

 /s/ Steve Art 

 One of Plaintiff’s Attorneys 

Arthur Loevy Locke E. Bowman 

Jon Loevy Sheila Bedi 

Russell Ainsworth David Shapiro 

Anand Swaminathan Alexa Van Brunt 

Steve Art MACARTHUR JUSTICE CENTER 

LOEVY & LOEVY Northwestern University School of Law 

311 N. Aberdeen St., Third Floor 375 E. Chicago Ave., 8th Floor 

Chicago, IL 60607 Chicago, IL 60611 

(312) 243-5900 (312) 503-0844 

steve@loevy.com 

 J. Samuel Tenenbaum 

BLUHM LEGAL CLINIC 

Northwestern University School of Law 

375 E. Chicago Ave., 8th Floor 

Chicago, IL 60611 

(312) 503-8576 

Case: 1:12-cv-04428 Document #: 314 Filed: 09/19/17 Page 3 of 3 PageID #:23847