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, through their undersigned attorneys, submit this Joint Status 

Report on remaining discovery issues.

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,

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

• Gary Kuykendall (on May 16, 2019),

• Adrienne Bryant (on May 21, 2019), and

• Sylvia Tienda (on June 6, 2019). 

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B. Depositions to be Taken

The plaintiff and defendants are working on scheduling depositions for the individuals

identified below. The City may also need the depositions of three additional treaters after a 

review of their complete medical files.

The plaintiff intends to depose:

• Dr. William Wong (scheduled for July 24), 

• Edgar Ignacio, 

• Dr. Hugh Russell (scheduled for July 18), and

• Dr. James Cavanaugh (possibly).

The defendants intend to depose:

• Dr. Daniel Martinez,

• Dr. Thomas Brennan,

• Gail Dreas, LCSW,

• Dr. Carlos Reynes (scheduled for July 11), and

• Plaintiff Robert Alamo.

II. Other Discovery Issues

A. Production of Firehouse Journals

The plaintiff 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 dayto-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 plaintiff was detailed to 

other firehouses. Id Tr. 110:21–24. It is the plaintiff’s position that the firehouse journals are 

covered by Plaintiff’s First Set of Requests to Produce, Number 6, which requests “[a]ll 

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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 asked the City to produce the firehouse journals for Engine 

Company 55 and Tower Ladder 63.

The City’s position is that the plaintiff did not specifically request the journals in his 

prior discovery requests. Nevertheless, the parties have met and conferred and have agreed 

that journals for specific firehouses and specific time periods will be made available for 

plaintiff’s attorneys on July 9, 2019 to review subject to the “Attorney Eyes Only” addendum 

to the Protective Order entered in this matter.

B. Additional Medical Releases

On May 24, 2019, Defendant requested that Mr. Alamo sign an additional release to 

obtain the medical records for Drs. Hartmann, McLaughlin, and Vaughn, who were each 

identified in Plaintiffs Amended 26(a)(1) Disclosures and Supplemental Interrogatory 

Responses, served on April 5, 2019. On April 16, 2019, the Court stated that no additional 

written discovery could be issued, so it is plaintiff’s position that this request is untimely. 

However, the plaintiff is willing to allow Defendant limited discovery for just these three 

doctors. 

Plaintiff has proposed to limit the broad scope of the proposed release to mental 

health records prepared between June 1, 2015 and April 16, 2019 (the close of written 

discovery). The City’s position is that the release should be tendered and signed using the 

same language and time frame as was presented in the prior release, which was used to obtain 

the Hines VA Hospital records.

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Respectfully submitted, 

Roberto Alamo City of Chicago and Charles Bliss

/s/ Jamie S. Franklin___________ /s/ Melanie Patrick Neely_________

One of Plaintiff’s Attorneys One of Defendants’ Attorneys

Dated this 18th day of June, 2019

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

Jamie S. Franklin, ARDC No 6242916

The Franklin Law Firm LLC

53 West Jackson Boulevard, Suite 803

Chicago, IL 60604

(312) 662-1008

jsf@thefranklinlawfirm.com

For the plaintiff

Melanie Patrick Neely

Howard P. Levine

City of Chicago

30 North LaSalle Street, Suite 1000

Chicago, IL 60602

Melanie.Neely@cityofchicago.org

Howard.Levine@cityofchicago.org

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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 June 18, 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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