1

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

PETER BONAHOOM,

Plaintiff 

v. 

TZUMI ELECTRONICS, LLC and 

STAPLES, INC., 

 Defendants.

Case No. 1:20-cv-01942

Hon. Mary M. Rowland

STIPULATION STAYING DEADLINES AND DISCOVERY

Plaintiff Peter Bonahoom (“Plaintiff”) and Defendant Staples, Inc. (“Staples”), by and 

through undersigned counsel, hereby stipulate as follows:

WHEREAS, Plaintiff filed his Complaint against Staples on March 23, 2020 (Dkt. No. 1);

WHEREAS, Staples moved to dismiss the Complaint on July 17, 2020 (Dkt. Nos. 17-18);

WHEREAS, the Court granted Staples’ motion in part and denied it in part on March 17, 

2021 (Dkt. No. 30);

WHEREAS, the Court entered a case management schedule on April 5, 2021 (Dkt. No. 

33);

WHEREAS, Plaintiff filed his First Amended Complaint in this matter on September 13, 

2021 pursuant to Fed. R. Civ. P. 15(a)(2) with Staples’ consent, naming Tzumi Electronics, LLC 

(“Tzumi”) as an additional defendant (Dkt. No. 45);

WHEREAS, Plaintiff and Staples are currently in discussions concerning the potential for 

resolution of Plaintiff’s claims against Staples, which would eliminate the need for continued 

litigation cost, burden, and expense, including in respect of discovery;

Case: 1:20-cv-01942 Document #: 46 Filed: 09/14/21 Page 1 of 4 PageID #:270
 2

WHEREAS, Plaintiff and Staples have agreed to proceed to mediation in furtherance of 

their discussions, subject to the Court’s approval of the relief requested herein;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between 

Plaintiff and Staples, and subject to the approval of the Court, that:

1. Staples’ deadline to answer, move, or otherwise respond to Plaintiff’s Amended 

Complaint shall be stayed pending mediation.1

2. The remaining deadlines in the Court’s April 5, 2021 case management schedule 

(Dkt. No. 33) shall be stayed pending mediation.

3. All discovery in this case shall be stayed until Tzumi answers the Amended 

Complaint or is dismissed from the case, and discovery proceeds as to all parties;

4. Plaintiff and Staples shall submit a joint status report following the conclusion of 

mediation, including, if necessary, new dates for the case deadlines stayed pending mediation.

Plaintiff and Staples respectfully request that the Court enter the proposed order submitted 

concurrently herewith.

1

 The parties agree that Staples shall reserve the right to move against the Amended Complaint, whether by a 

motion to dismiss or otherwise, at the appropriate time.

Case: 1:20-cv-01942 Document #: 46 Filed: 09/14/21 Page 2 of 4 PageID #:271
 3

Dated: September 14, 2021 Dated: September 14, 2021

/s/ Eugene Y. Turin

Eugene Y. Turin

Colin Buscarini

Steven Beckham

MCGUIRE LAW, P.C. 

55 W. Wacker Drive, 9th Floor

Chicago, Illinois 60601

Tel: (312) 893-7002

Fax: (312) 275-7895

eturin@mcgpc.com

cbuscarini@mcgpc.com

sbeckham@mcgpc.com

Counsel for Plaintiff

/s/ Robert. B. Ellis

Robert B. Ellis, P.C.

Michael S. Biehl

Kelsey Bleiweiss

KIRKLAND & ELLIS LLP

300 N. LaSalle

Chicago, Illinois 60654

Tel: (312) 862-2000

Fax: (312) 862-2200

robert.ellis@kirkland.com

michael.biehl@kirkland.com

kelsey.bleiweiss@kirkland.com

Counsel for Staples, Inc.

Case: 1:20-cv-01942 Document #: 46 Filed: 09/14/21 Page 3 of 4 PageID #:272
 4

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on this 14th day of September, 2021 a true and 

accurate copy of the foregoing document was electronically filed with the CM/ECF system of the 

United States District Court for the Northern District of Illinois, which sends notice to all counsel 

of record via email.

/s/ Robert B. Ellis

Robert B. Ellis, P.C.

Case: 1:20-cv-01942 Document #: 46 Filed: 09/14/21 Page 4 of 4 PageID #:273