UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JOINT STATUS REPORT

Plaintiff Elizabeth Gonzalez, by her appointed pro se attorneys, Riley Safer Holmes & 

Cancila LLP, and defendant Charlotte A. Burrows, Chair of the U.S. Equal Employment 

Opportunity Commission, by John R. Lausch, Jr., United States Attorney for the Northern District 

of Illinois, provide the following joint status report pursuant to the Court’s October 19, 2021 

minute entry, Dkt. 57, as follows:

1. This employment discrimination case alleges that plaintiff Elizabeth Gonzalez, a 

former probationary-period employee of the EEOC, was constructively terminated due to 

disability discrimination.

2. Plaintiff has completed written discovery. She does not intend to serve additional 

written discovery, has responded to all requests by Defendant, and will supplemental if/as required.

3. Defendant has responded to plaintiff’s written discovery and completed its first 

production, USA-Gonzalez 1 - 3214. Defendant will provide its second production to respond to 

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 Janet Dhillon is no longer the Chair of the United States Equal Employment Opportunity 

Commission, and the current Chair is now Charlotte Burrows. By automatic operation of the 

Federal Rule of Civil Procedure 25(d), the current chair is substituted in for the previous chair.

ELIZABETH GONZALEZ,

Plaintiff,

v.

CHARLOTTE A. BURROWS, Chair of the 

U.S. Equal Employment Opportunity 

Commission,1

Defendant.

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No. 20 C 2111

Judge Kennelly

Case: 1:20-cv-02111 Document #: 58 Filed: 11/01/21 Page 1 of 4 PageID #:464
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plaintiff’s ESI requests in pdf format tomorrow, November 2, 2021, and the same production in 

load file format by the end of this week. Due to the size of the production, the production has taken 

multiple hours today to process (unanticipated by defendant) and is currently still processing, 

causing a 1-day delay of defendant’s delivery to plaintiff. Defendant has served written discovery 

and received plaintiff’s responses and corresponding production. Defendant will supplement as 

needed.

4. Plaintiff served the eight additional subpoenas for medical records (see Dkt. 53) in 

compliance with the Court’s October 9, 2021 order (Dt. 54). 

5. The parties have met and conferred about the following depositions:

Witness Requesting Party Status

Plaintiff Gonzalez Defendant Plaintiff is available for 

deposition on November 30 

or December 1, 2, or 3

beginning at 10:00 a.m. at 

Riley Safer Holmes & 

Cancila LLP and/or by 

remote means.

Tyron Irvin, EEOC employee Plaintiff Defense counsel will produce 

Mr. Irvin for deposition on 

December 1 beginning at 

10:00 a.m. at the U.S. 

Attorney’s Office and/or by 

remote means.

Julianne Bowman, EEOC 

employee

Plaintiff Defense counsel will produce 

Ms. Bowman for deposition 

on December 3 beginning at 

10:00 a.m. at the U.S. 

Attorney’s Office and/or by 

remote means.

Patricia Jaramillo, EEOC 

employee

Plaintiff Defense counsel will produce 

Ms. Jaramillo for deposition 

on December 2 beginning at 

10:00 a.m. at the U.S. 

Case: 1:20-cv-02111 Document #: 58 Filed: 11/01/21 Page 2 of 4 PageID #:465
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Attorney’s Office and/or by 

remote means.

EEOC 30(b)(6) Plaintiff Plaintiff sent a 30(b)(6) 

Notice of Deposition to 

defendant on November 1, 

2021. Defense counsel will 

work with the agency to 

identify its 30(b)(6) witness 

and provide plaintiff’s 

counsel with available dates 

prior to the close of fact 

discovery.

Jose Romo, EEOC 

employee/Union 

representative

Plaintiff Plaintiff’s counsel will 

subpoena this witness for 

deposition on November 30, 

2021.

Kimberley Engram, EEOC 

employee/Union 

representative

Plaintiff Plaintiff’s counsel will 

subpoena this witness for 

deposition on November 30, 

2021.

Omar Guzman, LCSW Defendant Defense counsel will 

subpoena this witness for 

deposition on November 29, 

2021.

Deana Gaston, LCSW, 

Psychotherapist

Defendant Defense counsel will 

subpoena this witness for 

deposition on November 29, 

2021.

Lois Kenyon-Severson

Employee Assistance and 

Work/Life Programs

Defendant Defense counsel will 

subpoena this witness for

deposition on November 29, 

2021.

Individuals who lived with 

plaintiff during the relevant 

time period (Dec 2014 to Nov 

2015) who have not yet been 

identified but will be at 

plaintiff’s deposition

Defendant Defendant will subpoena 

these witnesses for deposition 

after they have been 

identified at plaintiff’s 

deposition.

Plaintiff’s treating physicians 

identified after receiving 

plaintiff’s medical records. 

Plaintiff identified 14 treating 

physicians in her initial 

disclosures. It is highly 

Defendant Defendant will subpoena 

relevant treating physicians 

after defense counsel has 

received the subpoenaed 

medical records. Defense 

counsel has not yet received 

Case: 1:20-cv-02111 Document #: 58 Filed: 11/01/21 Page 3 of 4 PageID #:466
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unlikely that defense counsel 

will need to depose all 14 but 

cannot determine who to 

depose until defense counsel 

can review plaintiff’s medical 

records. Defense counsel has 

not yet received plaintiff’s 

medical records.

any medical records.

Respectfully submitted,

By: /s Matthew E. Lee 

Brian O. Watson

Matthew E. Lee

RILEY SAFER HOLMES & CANCILA 

LLP

70 W. Madison Street, Suite 2900

Chicago, Illinois 60602

(312) 471-8700

bwatson@rshc-law.com

mlee@rshc-law.com

docketdept@rshc-law.com

JOHN R. LAUSCH, Jr.

United States Attorney

By: /s Valerie R. Raedy 

VALERIE R. RAEDY

Assistant United States Attorney

219 South Dearborn Street

Chicago, Illinois 60604

(312) 353-8694

valerie.raedy@usdoj.gov

4867-9015-9105, v. 1

Case: 1:20-cv-02111 Document #: 58 Filed: 11/01/21 Page 4 of 4 PageID #:467