IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Larry Ollins and Omar Saunders, 

Plaintiffs, 

vs. 

City of Chicago, et al., 

Defendants. 

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No. 03 C 5795 

Judge Ronald A. Guzman 

Magistrate Judge Martin C. Ashman 

AGREED MOTION FOR AN ORDER ENTERING TERMS OF SETTLEMENT

 Plaintiffs Larry Ollins and Omar Saunders (“Plaintiffs”), by and through their attorneys, 

Jenner & Block LLP, Defendants the City of Chicago (“City”) and Defendants David Nowak, 

James Maurer, Harry Drochner, Thomas Lahm, and James Mercurio (collectively “Defendant 

Officers” and together with the City “Defendants”), by and through their attorneys, James G. 

Sotos & Associates, Ltd., respectfully submit this Agreed Motion for an Order Entering Terms of 

Settlement. In support of this motion, the parties state as follows. 

1. The parties are in the process of finalizing an agreed settlement agreement and 

release subject to approval by the City Council. 

2. One of the critical elements of the parties’ settlement agreement is that upon City 

Council approval of the agreement, the City SHALL pay each Plaintiff the first agreed upon 

installment payment no later than 30 days after the City Council’s approval, made payable to 

Jenner & Block LLP, and SHALL pay each Plaintiff the second agreed upon installment 

payment, made payable to Jenner & Block LLP, no later than June 30, 2008. 

3. Plaintiffs will agree to release all claims against Defendants and to dismissal of 

the above titled case. 

Case: 1:03-cv-05795 Document #: 374 Filed: 03/22/07 Page 1 of 4 PageID #:5572
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 WHEREFORE, the parties jointly and respectfully request that this Court enter the 

proposed Order, attached as Exhibit A, which provides as follows: 

 Subject to the City Council’s approval of the parties’ settlement agreement: 

a) The City shall pay each Plaintiff the first agreed upon installment payment 

no later than 30 days after the City Council’s approval, made payable to Jenner & 

Block LLP, and shall pay each Plaintiff the second agreed upon installment 

payment, made payable to Jenner & Block LLP, no later than June 30, 2008; 

 b) Plaintiffs will agree to release all claims against Defendants and to 

dismissal of the above titled case; 

 c) The Court shall retain jurisdiction to enforce the Order and the Settlement 

Agreement reached by the parties; and 

 d) Ordering such additional or further relief as the Court may deem just and 

equitable. 

Respectfully submitted on this 22nd day of 

March, 2007, by: 

CITY OF CHICAGO 

DAVID NOWAK, JAMES MAURER, 

HARRY DROCHNER, THOMAS LAHM, 

JOHN McHUGH, and JAMES MERCURIO 

LARRY OLLINS 

OMAR SAUNDERS 

By: s/ John Timbo By: s/ David J. Bradford 

 One of the its Attorneys (signed 

with consent) 

 One of Plaintiffs' Attorneys 

James G. Sotos 

John Timbo 

James G. Sotos & Associates, Ltd. 

550 E. Devon, Suite 150 

Itasca, IL 60143 

Telephone: 

Facsimile: 630-773-0980 

 

David J. Bradford 00272094 

Andrew W. Vail 6279951 

JENNER & BLOCK LLP 

One IBM Plaza 

Chicago, IL 60611 

Telephone: 312-222-9350 

Facsimile: 312-527-0484 

Scott T. Kamin 

Law Office of Scott T. Kamin 

20 East Jackson Blvd., Suite 600 

Chicago, IL 60604 

Facsimile: 312-322-1041 

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CERTIFICATE OF SERVICE

I, Andrew W. Vail, an attorney, certify that true and correct copies of this Agreed Motion 

for an Order Entering the Terms of Settlement were transmitted to and served upon counsel 

listed below by the Court’s ECF system on March 22, 2007. 

Penelope M. George Scott T. Kamin 

Stephen P. Baker Law Office of Scott T. Kamin 

City of Chicago Asst. Corporation Counsel 20 East Jackson Blvd., Suite 600 

30 N. LaSalle St., Ste. 1040 Chicago, IL 60604 

Chicago, IL 60602 Fax No. 312-322-1041 

Fax No. 312-744-6912 

Stephen Pugh 

John M. Broderick 

Pugh, Jones, Johnson & Quandt, P.C. 

180 N. LaSalle St., Ste. 3400 

Chicago, IL 60601 

Fax. No. 312-768-7801 

 

James G. Sotos 

John J. Timbo 

Elizabeth A. Ekl 

James G. Sotos & Associates 

550 East Devon, Suite 150 

Itasca, IL 60143 

Fax No. 630-773-0980 

 s/ Andrew W. Vail 

 

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IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Larry Ollins and Omar Saunders, 

Plaintiffs, 

vs. 

City of Chicago, et al., 

Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

No. 03 C 5795 

Judge Ronald A. Guzman 

Magistrate Judge Martin C. Ashman 

ORDER

 This cause coming on to be heard on Plaintiffs Larry Ollins and Omar Saunders 

(“Plaintiffs”), Defendants the City of Chicago (“City”) and Defendants David Nowak, James 

Maurer, Harry Drochner, Thomas Lahm, and James Mercurio (collectively “Defendant Officers” 

and together with the City “Defendants”) Agreed Motion for an Order Entering the Terms of 

Settlement, due notice has been given and the Court being fully advised in the premises. 

THE COURT FINDS AND IT IS HEREBY ORDERED THAT: 

Subject to the City Council’s approval of the parties’ settlement agreement: 

a) The City shall pay each Plaintiff the first agreed upon installment payment 

no later than 30 days after the City Council’s approval, made payable to Jenner & 

Block LLP, and shall pay each Plaintiff the second agreed upon installment 

payment, made payable to Jenner & Block LLP, no later than June 30, 2008; 

 

 b) Plaintiffs will agree to release all claims against Defendants and to 

dismissal of the above titled case; and 

 c) The Court shall retain jurisdiction to enforce this Order and the Settlement 

Agreement reached by the parties. 

 THIS ORDER IS HEREBY ENTERED 

 

 __________________________________________________ 

Hon. Ronald. A. Guzman, Judge - United States District Court 

DATED:___________________________________ 

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