IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

DIANE BOND, ) 

 ) 

Plaintiff, ) No. 04 C 2617 

 ) 

 v. ) Judge Joan Humphrey Lefkow 

 ) 

) Magistrate Judge Ashman 

CHICAGO POLICE OFFICERS EDWIN ) 

UTRERAS (Star No. 19901), et. al., ) 

 ) 

 Defendants. ) 

PLAINTIFF’S MOTION TO PERMIT FILING OF PLAINTIFF’S

RESPONSE TO DEFENDANT CITY OF CHICAGO’S MOTION TO

STRUCTURE DISCOVERY AND REPLY IN SUPPORT OF PLAINTIFF’S

MOTION TO COMPEL INTERROGATORY RESPONSES AND

DOCUMENT PRODUCTION FROM DEFENDANT CITY OF CHICAGO

Plaintiff, by and through her counsel, respectfully requests that this Court permit the 

filing of Plaintiff’s Response to Defendant City of Chicago's Motion to Structure Discovery and 

Reply in Support of Plaintiff's Motion to Compel Interrogatory Responses and Document 

Production from Defendant City of Chicago (“Plaintiff’s Response and Reply Brief”). In 

support, Plaintiff states: 

1. Plaintiff’s Response and Reply Brief combines both Plaintiff’s Response to the City’s 

Motion to Structure, and a Reply in support of Plaintiff’s previously filed Motion to Compel 

Interrogatory Responses and Document Production from Defendant City of Chicago. This 

Response and Reply Brief totals 17 pages, excluding the Certificate of Service. 

2. According to Local Rule 7.1, briefs opposing or replying to opposition to a motion 

may not exceed 15 pages without prior approval from the Court. In the event that a brief is filed 

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that exceeds 15 pages, Local Rule 7.1 directs that the clerk file the brief, subject to the brief 

being stricken by the Court. 

3. Plaintiff respectfully submits that the Response and Reply Brief exceeds the 15 page 

limit only because Plaintiff has combined her responses on two related issues: (1) whether policy 

discovery in this case should be stayed, as asserted in the City’s Motion to Structure Discovery, 

and (2) whether this Court should compel the City to respond to certain discovery requests, as 

asserted in Plaintiff’s Motion to Compel Interrogatory Responses and Document Production 

from Defendant City of Chicago. This is in accord with ¶ 3 of the Agreed Order entered by 

Judge Lefkow on December 8, 2005. 

4. In addition, Plaintiff wishes to note that the Agreed Order entered by Judge Lefkow 

set the due date for the City to file its motion to structure, and respond to Plaintiff’s motion to 

compel, as Tuesday, January 3, 2006. The Agreed Order further set the due date for Plaintiff’s 

response to the City’s motion to structure, and her reply in support of her motion to compel, as 

two weeks later, Tuesday, January 17, 2006. 

5. Plaintiff filed her Response and Reply Brief on Monday, January 23, 2006, instead of 

on Tuesday, January 17, 2006, because she did not receive the City’s Motion to Structure until 

Monday, January 9, 2006 (six days after the due date noted in the Agreed Order), and did not 

receive the City’s Response to her Motion to Compel until Tuesday, January 10, 2006 (seven 

days after the due date noted in the Agreed Order). 

6. In keeping with the structure of the Agreed Order entered by Judge Lefkow, Plaintiff 

filed her Response and Reply Brief within two weeks of receiving the City’s Motion to Structure. 

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WHEREFORE, Plaintiff respectfully requests that this Court permit the filing of 

Plaintiff’s Response to Defendant City of Chicago's Motion to Structure Discovery and Reply in 

Support of Plaintiff's Motion to Compel Interrogatory Responses and Document Production from 

Defendant City of Chicago. 

 Respectfully Submitted, 

 /s/ H. Melissa Mather_______ 

One of Plaintiff’s Attorneys 

Date: January 26, 2006 

Craig B. Futterman 

H. Melissa Mather 

EDWIN F. MANDEL LEGAL AID CLINIC 

University of Chicago Law School 

6020 S. University 

Chicago, IL 60637 

(773) 702-9611 

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CERTIFICATE OF SERVICE

 The undersigned, an attorney, certifies that she caused the foregoing document to be 

served on counsel for Defendants, who are “Filing Users” pursuant to ECF, on Thursday, 

January 26, 2006, in accordance with the rules on electronic filing of documents. 

/s/ H. Melissa Mather______________ 

H. Melissa Mather 

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