IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

BROWGLEY RUSSELL and JAMES BURRIS, 

Plaintiffs, 

v. 

CITY OF CHICAGO, 

Defendant. 

)

)

) Case No. 1:20-cv-00420

)

) Judge LaShonda A. Hunt

)

) Magistrate Judge Heather K. McShain

)

)

DEFENDANT’S SECOND UNOPPOSED MOTION TO EXTEND THE BRIEFING 

SCHEDULE ON MOTIONS FOR SUMMARY JUDGMENT

Defendant City of Chicago (hereinafter the “City”), through the undersigned attorneys, 

respectfully submits its second UNOPPOSED Motion to Extend the Briefing Schedule for Motions 

for Summary Judgment, seeking to modify the briefing schedule, as follows:

1. This Court granted the City’s first unopposed motion to modify the briefing schedule 

for Motions for Summary Judgment, moving the filing due dates for the opening briefs from 

September 13 to September 20, 2024. (Dkt. 272) At that time, the City’s request was due to one of the 

City’s attorneys, Samantha Damewood, who was taking the lead in drafting the summary judgment 

submissions, suffering a tragic death in her family. She continues to be on a leave of absence to care 

for her family and herself.

2. The City has been diligently working on its Summary Judgment submissions. 

However, in the rush to file the first motion seeking the initial one-week extension from that Friday, 

September 13, 2024, the City’s attorney did not realize that the main affiant to support the City’s 

summary judgment motion was going to be out of town and unavailable for two weeks starting that 

following Monday, September 16 until September 27, 2024. 

Case: 1:20-cv-00420 Document #: 275 Filed: 09/18/24 Page 1 of 3 PageID #:4312
2

3. Therefore, the City respectfully requests another adjustment to the briefing schedule 

as follows: motions for summary judgment are to be filed by October 4, 2024; responses due 

November 1, 2024; and reply briefs due December 3, 2024 (due to the Thanksgiving holiday).

4. Plaintiffs’ counsel has no objection to this Motion. As indicated in its first motion, 

Plaintiffs also intend to file a motion for summary judgment.

WHEREFORE, for the above stated reasons, Defendant City of Chicago respectfully requests 

this Court grant its Motion and enter an order revising the summary judgment briefing schedule as 

follows: motions for summary judgment are to be filed by October 4, 2024; responses due November 

1, 2024; and reply briefs due December 3, 2024.

Dated: September 18, 2024 Respectfully submitted, 

By: /s/ Jennifer A. Naber____________

Jennifer A. Naber

Counsel for City of Chicago

Laner Muchin, Ltd.

Jennifer A. Naber

Samantha Damewood

515 North State Street, Suite 2400

Chicago, Illinois 60654

(312) 467-9800

jnaber@lanermuchin.com

sdamewood@lanermuchin.com

Case: 1:20-cv-00420 Document #: 275 Filed: 09/18/24 Page 2 of 3 PageID #:4313
CERTIFICATE OF SERVICE

I, Jennifer A. Naber, an attorney, certify that I caused the foregoing Defendant’s Second 

UNOPPOSED Motion to Extend the Summary Judgment Briefing Schedule to be served on 

all parties of record via the Court’s ECF filing system on this 18th day of September, 2024.

/s/ Jennifer A. Naber____________

Case: 1:20-cv-00420 Document #: 275 Filed: 09/18/24 Page 3 of 3 PageID #:4314