UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JOINT MOTION TO EXTEND FACT DISCOVERY

Plaintiff Elizabeth Gonzalez, by her 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, jointly request 

a 60-day extension of fact discovery from October 8, 2021, to December 8, 2021. In support of 

this joint motion, the parties state as follows:

1. This is an employment discrimination case alleging that plaintiff Elizabeth 

Gonzalez, a former probationary-period employee of the EEOC, was constructively terminated 

due to disability discrimination.

2. Fact discovery is currently set to close on October 8, 2021. Dkt. 31. 

3. Plaintiff has propounded an initial set of discovery to Defendant and has identified 

the key witnesses for deposition. Defendant answered the operative amended complaint on April 

9, 2012. Defendant responded to plaintiff’s request for production and produced over 3,000 pages 

1 The current Chair of the United States EEOC, Charlotte Burrows, is automatically 

substituted for the previous chair, Janet Dhillon, pursuant to Fed. R. Civ. P. 25(d).

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 #: 48 Filed: 08/12/21 Page 1 of 3 PageID #:447
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of documents in its first production, USA-Gonzalez 1–3214, on May 7, 2021. Defendant served 

its own requests for production and interrogatories on May 12, 2021, as well as requests for 

authorizations. Plaintiff is in the process of responding to these requests for production and 

interrogatories. Plaintiff’s personal situation related to domestic violence has delayed her ability 

to respond. Moreover, Plaintiff’s limited resources with transportation and concerns related to 

COVID-19 have also delayed her ability to obtain records necessary to properly respond to 

discovery. As of now, Plaintiff believes she has gathered the voluminous records responsive to 

Defendant’s discovery requests, and her counsel is in the process of reviewing them and assisting 

in providing responses.

4. The parties seek a 60-day extension to complete fact discovery. The plaintiff 

needs additional time to respond to defendant’s first set of requests for production of documents, 

including providing authorizations for third-party medical records, and defendant’s first set of 

interrogatories. Defendant needs additional time to produce relevant ESI, namely emails, from 

the EEOC in its second production. In addition, plaintiff’s answers to defendant’s interrogatories 

will identify plaintiff’s prior medical history; defendant needs those answers in order to subpoena 

and receive and review copies of the relevant third-party medical records and then identify any 

relevant treaters to depose.

5. This is the first motion for extension of fact discovery in this case.

Case: 1:20-cv-02111 Document #: 48 Filed: 08/12/21 Page 2 of 3 PageID #:448
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WHEREFORE, the parties jointly move for a 60-day extension of fact discovery until 

December 8, 2021. 

Respectfully submitted,

s/ Brian O. Watson 

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

Case: 1:20-cv-02111 Document #: 48 Filed: 08/12/21 Page 3 of 3 PageID #:449