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 

 Hon. Mary M. Rowland, 

 Magistrate Judge 

 

 

 

 

PLAINTIFF’S RESPONSE TO DEFENDANTS’ 

MOTION FOR LEAVE TO FILE EXCESS PAGES 

Plaintiff, JACQUES RIVERA, by his attorneys, respectfully submits this 

response to Defendants’ Motion for Leave to File Excess Pages (Doc. No. 702), 

stating in support as follows: 

1. Defendants’ post-trial motions are due August 31, 2018. 

2. On August 27, 2018, Defendants filed a motion requesting leave to file 

post-trial motions from the City of 50 pages and separate post-trial motions from 

the individual Defendants of 60 pages. To be clear, Defendants are asking for 110 

pages of combined post-trial briefing. 

3. In Plaintiff’s view, this number of pages requested is abusive and 

excessive. Unless Defendants intend to take issue with every single objection they 

lost at trial, no party needs that many pages for a post-trial motion. 

4. The Seventh Circuit limits appeal briefs to 14,000 words, and it has 

stressed repeatedly that parties must make editorial decisions in order not to 

Case: 1:12-cv-04428 Document #: 704 Filed: 08/27/18 Page 1 of 4 PageID #:39455
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burden courts with verbose briefs outlining every imaginable argument. See, e.g., 

Fleming v. County of Kane, 855 F.2d 496, 497 (7th Cir. 1988) (“Page limitations are 

important, not merely to regulate the Court’s workload, but also to encourage 

litigants to hone their arguments and to eliminate excessive verbiage.”); see also

United States v. Torres, 170 F.3d 749, 751 (7th Cir. 1999); United States v. Devine, 

768 F.2d 210, 211 (7th Cir. 1985) (en banc). 

5. If Defendants’ motion was granted, both the Court and Plaintiff (who 

will have to devote far more space in response to every argument raised in passing 

in 110 pages of briefing) will be unfairly impacted by Defendants’ refusal to exercise 

better editorial discretion. 

6. Plaintiff therefore urges the Court to direct the Defendants to combine 

their post-trial motions, collectively, into a brief of no more than 40 pages. 

RESPECTFULLY SUBMITTED, 

 JACQUES RIVERA 

By: /s/ Jon Loevy 

 One of Plaintiff’s Attorneys 

 

Case: 1:12-cv-04428 Document #: 704 Filed: 08/27/18 Page 2 of 4 PageID #:39456
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Arthur Loevy Locke E. Bowman 

Jon Loevy David Shapiro 

Russell Ainsworth Alexa Van Brunt 

Anand Swaminathan RODERICK MACARTHUR 

Steven Art JUSTICE CENTER 

Rachel Brady Northwestern University School of Law 

Sean Starr 375 E. Chicago Avenue 

LOEVY & LOEVY Chicago, Illinois 60611 

311 N. Aberdeen St. (312) 503-0844 

Third Floor 

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 #: 704 Filed: 08/27/18 Page 3 of 4 PageID #:39457
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CERTIFICATE OF SERVICE 

 I, Jon Loevy, an attorney, hereby certify that on August 27, 2018, I filed the 

foregoing via the Court’s CM/ECF system and thereby served a copy on all counsel 

of record. 

 

 /s/ Jon Loevy 

 One of Plaintiff’s Attorneys 

Case: 1:12-cv-04428 Document #: 704 Filed: 08/27/18 Page 4 of 4 PageID #:39458