UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DEFENDANT’S REPLY IN SUPPORT OF ITS MOTION TO COMPEL

THE PRODUCTION OF PLAINTIFF’S UNREDACTED MEDICAL RECORDS

Introduction

This is a disability discrimination and failure-to-accommodate case where the plaintiff, 

Elizabeth Gonzalez, refuses to produce her unredacted medical records from shortly before, 

during, and after the relevant time period (her employment at the EEOC), even with confidentiality 

provisions in place. The EEOC agrees with Gonzalez that there are highly personal issues 

involved that merit strong confidentiality protections but disagrees that those issues should bar the 

production of unprivileged, relevant medical information in a disability discrimination case. 

Gonzalez has produced only the records that she thinks support her view of her disabilities and not 

the full scope of medical records that are relevant to her medical condition during the relevant time 

period. The EEOC should not be forced to rely on Gonzalez and her attorney to cherry-pick and 

screen which medical records they think are relevant to the EEOC’s defenses. The court should 

compel the production of the unredacted medical records. 

1

 Current EEOC Chair Charlotte Burrows is automatically substituted for former Chair Janet 

Dhillon under 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

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Relevant Background

Elizabeth Gonzalez was employed by the EEOC as a probationary employee from for just 

under a year from December 1, 2014, to November 25, 2015. She was hired as an “information 

intake representative” whose primary responsibility was to answer phones and respond to 

questions from the public about the EEO process and filing EEO claims. Within that year, from 

April to November alone, Gonzalez had used 92 hours of annual leave, 91.45 hours of sick leave, 

and 241 hours of leave without pay (in other words, over 30 days of unpaid leave plus about 23

days of sick and annual leave). She was counseled several times during her employment about 

her excessive absenteeism but did not improve her attendance. When the issue of her attendance

was addressed by her supervisor, Gonzalez stated that her absenteeism was caused by a domestic 

violence situation, and she was directed to the Employee Assistance Program, the ADA 

coordinator, and the City of Chicago’s resources via 311, according to her supervisor’s testimony. 

Gonzalez’s attendance issues did not improve, and at the end of her probationary year, the EEOC 

terminated Gonzalez due to her excessive absences. Gonzalez now claims that the termination 

was due to her depression, anxiety, vertigo, and migraines. 

Given Gonzalez’s allegations of disability, the EEOC sought her medical records through 

a third-party medical records service. Gonzalez objected to the subpoena and withdrew her 

consent. The parties met and conferred and agreed to proceed with Gonzalez retrieving all of her 

medical records and producing them in redacted format to the EEOC so the parties could hopefully 

work through any disputes without court intervention. The undersigned expected small portions 

of the records to be redacted (for example, specific phrases)—unfortunately, large portions were 

redacted as described in the EEOC’s opening motion. Contrary to Gonzalez’s assertions in her 

response brief about the EEOC taking advantage of an agreement, Dkt. 68 at 4-5, the EEOC never 

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agreed that it would not dispute whether the redactions were appropriate; the agreement was for 

Gonzalez to redact the medical records in order for the EEOC to view them and determine whether

it objected to the redactions and to provide the parties the opportunity to work through the 

objections and seek court intervention only if necessary. Dkt. 53 ¶¶ 3-4. Disputes about the 

redactions were contemplated as stated in the parties’ joint motion to serve additional subpoenas. 

Dkt. 53 ¶ 4 (“The parties will meet and confer to work through any disputes that arise from the 

redactions and hopefully come to an agreement without necessitating court intervention”). 

Unfortunately, although the parties attempted to resolve the matter, they were unable to, and now

the EEOC seeks court resolution.

Argument

Before addressing the merits of the motion, two preliminary matters should be addressed

regarding the scope of the materials sought in the EEOC’s motion to compel and the EEOC’s 

position on the confidentiality of the unredacted medical records. In regards to scope: Gonzalez 

incorrectly summarizes the scope of what defendant is requesting. Contrary to Gonzalez’s 

assertions, the EEOC is not seeking all of Gonzalez’s medical records. As stated in the EEOC’s 

motion to compel, the EEOC seeks unredacted medical records during the relevant time period: 

(1) the three years prior to the beginning of Gonzalez’s employment (from Dec 1, 2011, to Dec 1, 

2014); (2) the year period of Gonzalez’s employment with the EEOC (from Dec 1, 2014, to Nov 

25, 2015); and (3) at least two years after her employment was terminated (from Nov 25, 2015, to 

Nov 25, 2017). Dkt. 64 at 7 (“Thus, the EEOC moves to compel Gonzalez to provide unredacted 

copies of her medical records during the most relevant time period, specifically from December 1, 

2011, to November 25, 2017 (and even longer if she is asserting continued emotional damages).”). 

The EEOC also seeks medical records past 2017 and up until the present if (and only if) Gonzalez 

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4

is seeking continued emotional damages from 2017 up until the present. Thus, Gonzalez’s 

statements and assertions that the EEOC is seeking “all of Plaintiff’s medical records” are

incorrect. Dkt. 68 at 4; cf. Dkt. 68 at 1 (“Defendant is not entitled to Ms. Gonzalez’s entire 

medical and personal history . . .”). The EEOC is seeking only medical records that will show 

Gonzalez’s medical condition shortly before, during, and after her employment with the EEOC.

The court might wonder why the EEOC was not able to specify which Bates-stamped pages 

it was seeking in unredacted form in its motion to compel. The simple fact is that some of the 

medical records are so heavily redacted that the EEOC cannot determine when the medical record 

was created. The EEOC now attaches Exhibit A which lists the redacted records chronologically, 

if the date is apparent, and the undated records as well, to delineate the records it is seeking, to the 

extent it can. Again, the EEOC is seeking only the medical records during the relevant time period

defined above.

In regards to terms of production: The EEOC has no objection to treating Gonzalez’s 

medical records as highly confidential and using standard litigation methods to protect confidential 

material. The EEOC agrees with Gonzalez that information that is highly personal in nature, such 

as a domestic violence situation, should be treated with the highest level of confidentiality. The 

EEOC is not seeking to share Gonzalez’s medical records publicly but only to review the records 

so it can appropriately defend this case. As the EEOC has conveyed to plaintiff’s counsel, the 

EEOC is willing to receive the medical records with attorneys-eyes-only protection or any other 

confidentiality protections the court finds appropriate and to work through a procedural 

mechanism to allow the parties to confer about what information can be publicly disclosed in 

filings or at trial. Thus, the EEOC is not seeking to embarrass Gonzalez in a public forum.2

 This 

2 The EEOC specifically did not mention Gonzalez’s domestic violence situation in its 

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is not a dispute between privacy versus publication but rather a dispute between disclosure versus 

withholding. 

I. Gonzalez’s Medical Records during the Relevant Time Period Meet the Standard Set 

Forth in Rule 26 for Discovery and Should Be Produced.

Rule 26 of the Federal Rules of Civil Procedure outlines the scope of permissible discovery 

and provides that parties to a civil dispute are entitled to discover “any nonprivileged matter that 

is relevant to any party’s claim or defense and proportional to the needs of the case,” regardless 

of admissibility. Fed. R. Civ. P. 26(b)(1) (emphasis added). Proportionality is determined by 

considering “the importance of the issues at stake in the action, the amount in controversy, the 

parties’ relative access to relevant information, the parties’ resources, the importance of the 

discovery in resolving the issues, and whether the burden or expense of the proposed discovery 

outweighs its likely benefit.” Id. The scope of permissible discovery is broad. Oppenheimer 

Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978). Information sought in discovery need not be 

admissible in evidence to be discoverable. Id. Thus, the court should determine: (1) whether a 

privilege applies; (2) whether the sought discovery is relevant; and (3) whether the sought 

discovery is proportional. Here, no privilege applies, Gonzalez’s medical records are relevant, 

and the production of unredacted medical records during the relevant time period is proportional, 

opening motion because of the sensitivity of putting such information in the public domain, 

notwithstanding the fact that Gonzalez herself has asserted such information in her complaints, see

original complaint, Dkt. 1 at 48 (reference to informing supervisor of domestic violence situation); 

Operative second amended complaint, Dkt. 40 ¶ 30 (references to the same). However, in her 

response brief, Gonzalez raises her domestic violence situation as a reason to withhold her medical 

records from the EEOC. Her domestic violence situation is not a sword to withhold medical 

records that plaintiffs in disability discrimination cases typically turn over as part of standard 

discovery process. This is not to say that there should not be additional protections due to the 

sensitive personal nature of such concerns, but those additional privacy interest can be addressed 

through the standard litigation mechanisms for dealing with highly confidential material such as a 

confidentiality order (the EEOC has offered to enter into one) or an attorneys-eyes-only 

production. 

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especially when considering the EEOC’s willingness to abide by the highest level of 

confidentiality protection.

A. Gonzalez Does Not Claim Any Privilege.

No applicable privilege applies here. Gonzalez makes no claim that a privilege applies to 

bar the production of her medical records, and thus any privilege argument is waived. Thus, if 

the records are relevant and the discovery proportional, they should be produced with appropriate 

confidentiality protections.

B. The Requested Unredacted Medical Records Are Relevant.

Gonzalez’s medical records from the time period from Dec 1, 2011, to at least Nov 25, 

2017 are relevant (at least in the discovery phase). “Evidence is relevant if: (a) it has any tendency 

to make a fact more or less probable than it would be without the evidence; and (b) the fact is of 

consequence in determining the action.” Fed. R. of Evid. 401. To the state the obvious, 

Gonzalez’s medical records will make a fact—her disabilities, the severity of those disabilities, 

and the extent of her injury or damages—more or less probable.

In its motion to compel, the EEOC described six specific examples of improperly 

redacted medical records. Gonzalez does not address any of those examples in her response. 

Most notably, Gonzalez does not even attempt to explain why she has refused to turn over 

records related to a medical incident on February 4, 2015, that is included in her complaint. See

Ex. A to Opening Motion, Dkt. 64 at 22-24 (filed under seal); 2d Am. Compl., Dkt. 40 ¶ 25

(“Plaintiff had a medical event at work and went to the emergency room at Holy Cross Hospital 

because of her medical condition on February 3, 2015.”). Surely, Gonzalez herself found it 

relevant to the litigation given that she alleged the facts of the medical incident in her complaint. 

And yet, Gonzalez has refused to provide these unredacted records to the EEOC, regardless of 

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their relevance or any offered confidentiality provision. And rather than at least address the 

issue in her response brief, Gonzalez just ignores that argument and all of the other specific 

illustrations offered by the EEOC.

More generally, Gonzalez as a plaintiff does not get to pick and choose what medical 

information she deems relevant. Gonzalez’s medical information during the relevant time period 

is relevant because her medical condition is at issue generally. Not just her diagnosis, but what 

she was and was not capable of doing and why. The EEOC is entitled to medical information that 

both supports and undermines her alleged claims—that both shows her medical condition is more 

severe or less severe. The specific things that could be seen in the redacted medical records 

include: depression screening results that conflict with Gonzalez’s allegations, causal relationships 

that undermine Gonzalez’s allegations, the absence of statements about her medical condition that

would support her testimony, indications of less or more severe symptoms, reasons that could have 

caused her absenteeism other than her alleged disabilities (for example, alcoholism, which there is 

evidence in the record of), and statements contrary to her current description of her medical 

condition at the time, among others.

Plaintiff repeatedly states that Gonzalez’s disabilities are undisputed. The EEOC will not 

be contesting Gonzalez’s various diagnoses supported by the medical records but the severity of 

Gonzalez’s disabilities is disputed and directly relates to whether she could perform her job with 

or without an accommodation, a central issue in this action, and whether she was a qualified 

individual with a disability. Further, the EEOC intends to consult with experts to review 

Gonzalez’s medical records to opine on the severity of her alleged disabilities—depression, 

anxiety, vertigo, and migraines—and her ability to work during the relevant time period based on 

her medical condition. As even lay people intuitively know, there is a huge range in regards to 

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an individual’s ability to function depending on the severity of the four alleged disabilities at issue 

here, from those with migraines that are severe and frequent leading to almost complete

impairment, to those that live and work with migraines and are able to do so. The same can be 

said about depression and anxiety. More importantly, it is not just whether Gonzalez is disabled 

but whether she was a qualified individual with a disability. Gonzalez must show that she had “a 

physical or mental impairment which substantially limits one or more of such person’s major life 

activities,” 29 U.S.C. § 705(20)(B)(i)—in other words, she must show not only that she had some 

medical diagnosis but that her disabilities were severe enough to substantially limit her life 

activities. The severity of Gonzalez’s disabilities is disputed, as well as whether any 

accommodation could have been effective, and thus the facts of her medical condition directly 

impact specific elements of her disability discrimination and failure-to-accommodate case. Thus, 

the second prong is met—“the fact” (here, her medical condition and the severity of her alleged 

disabilities) is “of consequence in determining the action.” Fed. R. Evid. 401. 

Case law supports the EEOC’s position. Gonzalez cites to Wier v. United Airlines, Inc., 

No. 19 CV 7000, 2020 WL 12432053, at *1-2 (N.D. Ill. Dec. 16, 2020), but Weir supports the 

EEOC’s position. In Weir, the plaintiff had already “produced to Defendant unredacted versions 

of her records from her two mental healthcare providers, including unredacted therapy session 

notes, and Plaintiff [did] not raise an objection in her response to Defendant subpoenaing her 

records directly from any of her healthcare providers, including her mental health providers.” 

Wier 2020 WL 12432053, at *2 (emphasis added). In contrast, here, Gonzalez did not produce 

unredacted copies of records from her mental healthcare providers or unredacted therapy session 

notes; and Gonzalez did object to defendant subpoenaing medical records directly from her 

providers. Furthermore, the order granted in Weir provided eight years of medical records to 

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defendant, which is more than the about five years of records that the EEOC is requesting here. 

The other cases cited by Gonzalez (Ashley v. Schneider Nat’l Carriers, Inc., No. 12-cv-08309, 

2014 WL 972154 (N.D. Ill. Mar. 11, 2014), and Warner v. Velardi, No. 16-cv-1924, 2017 WL 

3387723 (S.D. Cal. Aug. 7, 2017)) are not disability discrimination cases and thus are not helpful. 

Similarly, Anderson v. Abercrombie & Fitch Stores, Inc., No. 06-cv-991, 2007 WL 1994059, at 

*4 (S.D. Cal. July 2, 2007), is not helpful because the discrimination case was not based on 

disability or failure-to-accommodate claims but race and retaliation, and further, the court’s 

reasoning relies on California privilege law not involved here. Id. at *4.

Gonzalez argues that the medical records produced should be limited to records related her 

claimed disabilities. As discussed above, that application of relevancy is far too narrow. But 

even if the court accepted Gonzalez’s argument (it should not), the EEOC is still owed additional, 

unredacted records. Gonzalez has redacted records that are related to Gonzalez’s alleged 

disabilities of depression, anxiety, migraines, and vertigo. For example, medical records from 

Gonzalez’s hospital visit on February 4, 2015, referenced in her complaint, directly relate to 

depression, and yet were still redacted. See Gonzalez-HolyCross 800-02, attached as Exhibit A 

to Dkt. 64 (filed under seal). Another example: medical records from a Holy Cross visit 

(Gonzalez-HolyCross 854) list depression, suicidal ideation, and vertigo, as well as alcohol use,

and yet large portions of the record from that visit are redacted. See Ex. B (filed under seal). 

Other medical records have the same problem (Gonzalez-UCMC 634 and GonzalezFriendFamilyHealth 11) in that they are relevant to Gonzalez’s alleged disabilities (both records 

reference her alleged disabilities) and yet they are still redacted. Id. In addition, although some 

references to Gonzalez’s alcohol use disorder have been produced in unredacted form, see, e.g., 

Gonzalez-RiverEdge 2, alcohol use is not one of Gonzalez’s alleged disabilities and thus, 

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according to Gonzalez’s argument, should not have to be produced. Id. However, this is 

obviously relevant because it relates to a possible defense, namely evidence of an alternative cause 

of Gonzalez’s severe absenteeism. The EEOC does not know what other relevant information in 

the medical records have been redacted, and the EEOC should not have to rely on plaintiff’s 

determination of what is relevant to the EEOC’s defense in discovery.

Finally, Gonzalez’s objection based on privacy concerns does not change the relevancy 

analysis. Gonzalez’s medical records are relevant because she put her medical condition at issue 

in this case by asserting that she suffered emotional distress and challenging the EEOC’s legitimate 

reason for her employment termination with the allegation that it was instead based on her medical 

condition and domestic violence situation. See Santelli v. Electro-Motive, 188 F.R.D. 306, 309 

(N.D. Ill. 1999) (noting that plaintiff “cannot inject his or her psychological treatment, conditions, 

or symptoms into a case and expect to be able to prevent discovery of information relevant to those 

claims.”); Patterson v. Chicago Assoc. for Retarded Children, 1997 WL 323575, *3 (N.D. Ill. 

1997) (“ADA plaintiffs . . . waive all privileges and privacy interests related to their claim by virtue 

of filing the complaint.”). Accordingly, Gonzalez’s medical records during the specified time 

period are relevant.

C. The Requested Medical Records Are Proportional.

The medical records are time bound based on Gonzalez’s employment history with the 

EEOC and any alleged issues of privacy and embarrassment can be resolved by a confidentiality 

order and/or an agreed limitation such as attorneys-eyes-only. Again, the EEOC is not seeking to 

make Gonzalez’s medical information public and would agree to a procedural mechanism for the 

parties to confer before any information from the medical records was used in a public filing or at 

trial. However, the EEOC should be able to collect evidence and evaluate for itself Gonzalez’s 

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medical condition in this disability discrimination and failure-to-accommodate case, and should 

be able to provide a complete set of medical records during the relevant time period to its experts.3

D. The Legitimate Privacy Concerns Gonzalez Raises Should Be Addressed 

through Confidentiality Provisions, Not Bar Production Entirely.

Gonzalez’s legitimate privacy concerns can be adequately addressed through a 

confidentiality order and/or an attorneys-eyes-only limitation on the production of the unredacted 

medical records. See Ill. League of Advocs. for the Developmentally, Disabled v. Ill. Dep’t of Hum. 

Servs., No. 13 C 1300, 2013 WL 3287145, at *4 (N.D. Ill. June 28, 2013) (finding that 

confidentiality order was sufficient to protect confidential nature of medical records and ordering 

them to be produced in unredacted form). Gonzalez argues that because her medical records 

contain highly personal information (Gonzalez implies that there are references to her domestic 

violence situation in her medical records although the EEOC obviously cannot confirm that 

assertion given the redactions), she should not have to produce the unredacted records at all. 

However, this argument goes to support higher confidentiality protections, not to bar production. 

Although the EEOC is happy to abide by a stringent confidentiality order, the EEOC should not 

be placed at a disadvantage in defending this suit because one of the intertwined issues is of a 

personal nature to plaintiff. The issue is unfortunately intertwined because when Gonzalez’s 

direct supervisor addressed Gonzalez’s serious attendance issues midway through her probationary 

year, according to her supervisor’s testimony, Gonzalez explained that she was absent due to her

domestic violence situation. See also Complaint, Dkt. 1 at 48 (noting that she informed supervisor 

3 The EEOC will be seeking expert discovery if its motion for summary judgment is not 

granted by the court. Gonzalez’s assertions on this front about what discovery defendant needs 

to defend the case is improper. The EEOC requested a summary briefing schedule instead of an 

expert discovery schedule because if the court grants summary judgment in the EEOC’s favor, 

expert discovery will be unnecessary. If the court would like the EEOC to file an amended status 

report to indicate its intention to seek expert discovery in this case, the EEOC will do so.

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of domestic violence situation when addressing absences); 2d Am. Complaint, Dkt. 40 ¶ 30 (same). 

This is not a case where there is an ancillary issue of domestic violence and defendant seeks further 

discovery on that issue even though it is unrelated; this is a case where Gonzalez was terminated 

for excessive absenteeism and when asked about why she was absent, according to her supervisor,

plaintiff pointed to her domestic violence situation. Further, although the EEOC is in agreement 

that this topic deserves the highest level of confidentiality—and as such has offered attorneys-eyeonly protection for her medical records—such an allegation cannot be used as a sword to shield all 

medical records relevant to Gonzalez’s overall medical condition from production because they 

discuss her personal situation, especially where the alleged disabilities, depression and anxiety, are 

intertwined with her domestic violence situation based on what Gonzalez said to her supervisor

during her employment. This is a difficult discovery issue because the EEOC will be the first to 

admit that information related to domestic abuse is highly personal, but it is also central to the 

litigation because plaintiff provided it as a reason for her excessive absences from work. Thus, 

the EEOC seeks guidance from the court on balancing these interests.

II. The Court Should Disregard Gonzalez’s Red Herring Arguments about Unrelated 

Discovery Issues.

Gonzalez raises other, unrelated discovery issues that are not relevant to the issue at hand. 

Gonzalez cannot get around providing relevant, documentary material by arguing about 

depositions. For example, Gonzalez criticizes the EEOC for withdrawing Dr. Mirkin’s subpoena 

for deposition after the undersigned scheduled the deposition and for subpoenaing family 

members. These red herrings should be ignored. Ironically though, even if the court considers 

these ancillary issues, this criticism merely emphasizes the EEOC’s need for these records. The 

undersigned withdrew Dr. Mirkin’s subpoena for deposition because in the week prior to the 

deposition when the undersigned attempted to prepare for the deposition, the undersigned could 

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13

not find Dr. Mirkin’s name anywhere in the unredacted medical records because—assumedly—

all of Dr. Mirkin’s records in the Sinai records were redacted. Gonzalez has, in her response, now 

admitted that Dr. Mirkin is a relevant treater and yet, none of Dr. Mirkin’s treatment records were 

provided in unredacted form. In preparing for the deposition, the undersigned was unable to 

provide Dr. Mirkin’s treatment records to the doctor as requested. Given that many years have

passed since such treatment, the undersigned decided the medical records would more accurately

define Gonzalez’s condition than the doctor’s memory—unassisted by records—of Gonzalez’s 

condition over six years ago and chose to withdraw the subpoena. The lack of medical records 

produced here thus affected the undersigned’s ability to prepare for Dr. Mirkin’s deposition. If 

anything, this issue highlights that these records should have been provided to defendant in 

unredacted format months ago.

Similarly, Gonzalez attempts to criticize the EEOC for serving family member subpoenas, 

stating that the EEOC sent a subpoena to Gonzalez’s abuser. First, the EEOC does not know the 

identity of the abuser because Gonzalez refused to answer any questions related to this topic at her 

deposition and thus the EEOC was unable to identify and exclude the abuser and still subpoena 

other available family members. The parties have met and conferred on this issue and since 

agreed to stipulate that Gonzalez will not introduce any evidence at trial that the EEOC was not 

allowed to discover during discovery related to these sensitive issues, which allows Gonzalez to 

maintain privacy while still allowing the EEOC to avoid any unfair surprise at trial. Second, when 

sending the family member subpoenas, the undersigned reached out to plaintiff’s counsel and 

specifically stated that she would agree to limit the depositions to focus on personal observations 

of Gonzalez’s disabilities. Suggesting now that the EEOC intended to delve into Gonzalez’s 

domestic violence situation when counsel specifically noted that she would agree to a limitation 

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14

ahead of time to exclude certain issues is not a fair representation. Further, Gonzalez’s counsel 

at any time could have moved for a protective order or requested certain agreed limitations from 

the EEOC and yet never did so. Again, these other, unrelated discovery issues are not relevant to 

this motion.

Conclusion

For the above stated reasons, the EEOC requests that the court grant its motion to compel 

the production of Gonzalez’s unredacted medical records during the relevant time period with 

confidentiality provisions.

Respectfully submitted,

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 #: 71 Filed: 03/16/22 Page 14 of 20 PageID #:1294
Exhibit A

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

REDACTED BATES-STAMPED DOCUMENTS PRODUCED BY PLAINTIFF

All redacted medical records are listed by Bates-stamp. Bold indicate the records fall 

within the relevant time period. Italics means the time period is undetermined. Unaltered, 

regular text indicates medical records that fall outside the EEOC’s motion to compel Asterisks

(**) indicate that the records are only sought if Gonzalez is seeking emotional damages for that 

period of time.

REDACTED BATES RANGE DATE OF SERVICE 

GONZALEZ – UCMC

671 – 674

774 – 776

633 – 773

630 – 771

628

676 – 769

622 – 624

620

675 – 765 

618 – 619

621

625

626 – 627

629

637

644

660

02.15.08

07.29.08

09.09.08

09.11.08

09.17.08

09.23.08

01.06.09

03.13.09

05.12.16

Undetermined*

Undetermined*

Undetermined*

Undetermined*

Undetermined*

Undetermined*

Undetermined*

Undetermined*

ELIZABETH GONZALEZ,

Plaintiff,

v.

CHARLOTTE A. BURROWS, Chair of the 

U.S. Equal Employment Opportunity 

Commission,

Defendant.

)

)

)

)

)

)

)

)

)

)

)

No. 20 C 2111

Judge Kennelly

Case: 1:20-cv-02111 Document #: 71 Filed: 03/16/22 Page 16 of 20 PageID #:1296
665 – 670 Undetermined*

GONZALEZ-HOLYCROSS

782 – 785

786

894

787

788 – 790

791 – 792

793 

794 – 795

796 – 797

798 

799

800 – 803

804 - 839

840 

841 – 867

895

868 – 870**

871 

872 – 875**

876 – 878

879 – 887**

891 – 892**

888 – 890**

02.04.15

02.04.15

02.03.15

02.03.15

02.03.15

02.04.15

02.03.15

Undetermined*

02.04.15

02.04.15

Undetermined*

02.04.15

05.13.16

06.01.16

07.29.16

07.29.16

08.13.20

Undetermined*

08.13.20

Undetermined*

08.13.20

08.13.20

08.14.20

GONZALEZ – RUSH

587 – 617

549 – 586

528 – 545

492 – 527

444 – 491

358 – 443**

246 - 357**

07.05.13

08.14.13

09.30.14

11.05.15

05.13.16

07.28.19

10.01.21

GONZALEZFRIENDFAMILYHEALTH

008 - 009

177 - 180

010 - 013 

018

12.05.11

Undetermined*

02.18.13

02.21.13

Case: 1:20-cv-02111 Document #: 71 Filed: 03/16/22 Page 17 of 20 PageID #:1297
019 - 021

022 - 025

026 - 028

029 - 032

055 - 059

060 - 062

063 - 067

068 - 071

072 - 076

077 – 082

207 – 213

083 – 087

088 – 093

214 – 216

094 – 097

098 – 118

119 – 123

124 – 129

130 – 134

135 – 141

226 – 228

142 – 146

147 – 155**

234 – 237**

156 – 162**

163 – 169**

170 – 174**

175 – 176 

181 – 206

217 – 225

229 – 233

238 – 241

242 - 245

07.03.13

01.09.14

01.28.14

02.21.14

07.28.14

08.01.14

08.08.14

10.07.14

11.26.14

03.20.15

03.26.15

06.09.15

09.04.15

09.09.15

11.12.15

02.22.16

11.23.16

11.29.16

03.01.17

07.12.17

07.18.17

10.04.17

10.15.18

10.17.18

10.29.18

04.16.19

06.13.19

Undetermined*

Undetermined*

Undetermined*

Undetermined*

Undetermined*

Undetermined*

Case: 1:20-cv-02111 Document #: 71 Filed: 03/16/22 Page 18 of 20 PageID #:1298
Exhibit B

Case: 1:20-cv-02111 Document #: 71 Filed: 03/16/22 Page 19 of 20 PageID #:1299
Redacted

Case: 1:20-cv-02111 Document #: 71 Filed: 03/16/22 Page 20 of 20 PageID #:1300