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IN THE UNITED STATES DISTRICT COURT FOR

THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

SEAN PAUL REYES, )

)

Plaintiff, )

)

v. )

) Case No. 22 CV 07339

RICHARD VOLANTI, DETECTIVE ) 

MONACO, OFFICER GHILONI, RUTH )

SIABA GREEN, individually, and the ) 

CITY OF BERWYN, )

a municipal corporation, )

)

Defendants. )

PLAINTIFF’S MOTION TO COMPEL

NOW COMES the Plaintiff, SEAN PAUL REYES, by and through his attorneys of 

Gregory E. Kulis & Associates, Ltd., and in support of his Motion to Compel the Depositions

of all named Defendants, states the following:

1. This action was filed before this Court on December 30, 2022.

2. The discovery deadline is currently set for March 15, 2024. [Dkt. 54].

3. On February 26, 2024, Plaintiff served defense counsel with a Notice of Video Deposition 

in order to depose all named defendants: (1) Ruth Siaba; (2) Richard Volanti; and (3) 

Detective Monaco via video conference. (see Exhibit A).

4. Counsel for defendants acknowledged said Notice and the date, time, and conditions of 

depositions were mutually agreed upon by both parties.

5. On February 27, 2024, Plaintiff served again an amended Notice of Video Deposition upon 

counsel for Defendants. (see Exhibit B).

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6. Counsel for Defendants notified counsel for Plaintiff on March 1, 2024, that they would 

not agree to the depositions being conducted via video conference after initially agreeing 

upon the February 26, 2024, notice of deposition for all named defendants.

7. Plaintiff has recently filed a Motion to Extend Fact Discovery in order to conduct the final 

depositions that remain. [Dkt. 54].

8. Defense counsel’s objection to the terms of deposing all named Defendants has unduly 

prejudiced the Plaintiff from prosecuting his case.

9. On March 1, 2024, lead counsel for Plaintiff and lead counsel for Defendants attempted 

(pursuant to FRCP Rule 37.2) to hash out differences and come to an agreement but no 

agreement was reached as to the terms of the video depositions.

10. Pursuant to the Federal Rules of Civil Procedure, Plaintiff has the right to have the 

depositions of all named Defendants on video.

11. Counsel for defendants notified Plaintiff’s counsel they would be sending and filing a 

Protective Order and proposed language for said Order, but Plaintiff has not received 

anything to that effect.

12. In order to efficiently prosecute his case, not waste this Court’s time, and to abide by the 

recently extended fact discovery deadline, Plaintiff is filing the current motion to compel 

the oral testimony of the above-listed named defendants via video conference.

WHEREFORE, the Plaintiff respectfully requests that this Honorable Court grant his motion and 

order the Defendants to make themselves available to attend their video-taped depositions, to and 

reimburse Plaintiff for all costs and attorney’s fees associated with bringing this motion, along with any 

other relief that this Court deems equitable, reasonable, and just.

Case: 1:22-cv-07339 Document #: 55 Filed: 03/04/24 Page 2 of 3 PageID #:105
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Respectfully submitted, 

Plaintiff Sean Paul Reyes

By: /s/ Scott P. Granfeldt

Atty. Scott P. Granfeldt

Atty. Gregory E. Kulis

Gregory E. Kulis & Associates, Ltd.

134 N. LaSalle, #444

Chicago, Illinois 60602

p. 312-580-1830

e. service@kulislawltd.com

e. gkulis@kulislawltd.com

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