IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ILLINOIS REPUBLICAN PARTY, WILL 

COUNTY REPUBLICAN CENTRAL 

COMMITTEE, SCHAUMBURG TOWNSHIP 

REPUBLICAN ORGANIZATION, and 

NORTHWEST SIDE GOP CLUB, 

 Plaintiffs,

 v.

GOVERNOR JB PRITZKER, 

 Defendant. 

No. 20-C-03489

Honorable Steven C. Seeger

Honorable Sara L. Ellis

THE GOVERNOR’S AMENDED UNOPPOSED MOTION 

TO STAY PROCEEDINGS PENDING APPEAL

Pursuant to Federal Rule of Civil Procedure 6(b), Defendant JB Pritzker, Governor of 

Illinois, by his attorney, Illinois Attorney General Kwame Raoul, respectfully requests that the 

Court stay the proceedings in this case in the district court until 30 days after the Supreme Court 

rules on the Plaintiffs’ upcoming petition for certiorari, or, if the petition is granted, 30 days after 

the Supreme Court issues a decision on the merits. In support of this motion, the Governor states 

as follows:

1. On August 13, 2020, the Governor filed an unopposed motion to stay the 

proceedings in this Court until the later of September 17, 2020 or 30 days after Plaintiffs’ 

interlocutory appeal is resolved and the mandate is issued. ECF 26. The Court has not yet acted on 

the Governor’s motion.

2. The Seventh Circuit affirmed this Court’s denial of Plaintiffs’ motion for temporary 

restraining order and preliminary injunction on September 3, 2020. Ill. Republican Party v. 

Case: 1:20-cv-03489 Document #: 31 Filed: 10/19/20 Page 1 of 3 PageID #:239
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Pritzker, 973 F.3d 760 (7th Cir. 2020). The Seventh Circuit issued a mandate in the case on 

September 25, 2020. Ill. Republican Party v. Pritzker, No. 20-2175 (7th Cir.), ECF 37.

3. Counsel for Plaintiffs has informed counsel for the Governor that Plaintiffs intend 

to file a petition for certiorari before the United States Supreme Court. 

4. Because the outcome of Plaintiffs’ petition for certiorari is likely to be relevant to 

the Governor’s responsive pleading, including a possible motion to dismiss, the Governor believes 

this Court’s resources would be preserved if the parties are not required to simultaneously litigate 

in this Court as well as in the Supreme Court. The Governor therefore requests that the Court stay 

his deadline to answer or otherwise respond to the complaint, and stay all other district court 

proceedings, until 30 days after the Supreme Court rules on the petition for certiorari, or, if the 

petition is granted, 30 days after the Supreme Court issues a decision on the merits.

5. Counsel for the Governor has conferred with counsel for Plaintiffs concerning this 

motion, and counsel for Plaintiffs has authorized the Governor to represent that they do not oppose 

the motion.

For these reasons, the Governor requests that the Court stay the deadline to respond to 

Plaintiffs’ complaint and stay all other proceedings pertaining to this case in this Court until 30 

days after the Supreme Court rules on the petition for certiorari, or, if the petition is granted, 30 

days after the Supreme Court issues a decision on the merits.

Date: October 19, 2020 Respectfully submitted,

KWAME RAOUL 

Illinois Attorney General 

Case: 1:20-cv-03489 Document #: 31 Filed: 10/19/20 Page 2 of 3 PageID #:240
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By: /s/ Jeffrey J. VanDam

R. Douglas Rees

Deputy Attorney General

Christopher G. Wells

Chief, Public Interest Division

Hal Dworkin

Assistant Attorney General

Office of the Illinois Attorney General

100 W. Randolph St.

Chicago, IL 60601

(312) 814-3000

Jeffrey J. VanDam

Public Interest Counsel

jvandam@atg.state.il.us

(718) 702-3337

rrees@atg.state.il.us

cwells@atg.state.il.us

hdworkin@atg.state.il.us

Case: 1:20-cv-03489 Document #: 31 Filed: 10/19/20 Page 3 of 3 PageID #:241