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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

K.G., a Minor, by and through ) 

his Parents and Next Friends, CELESTINA ) 

COLEMAN and ANTHONY GILBERT; and ) 

CELESTINA COLEMAN, Individually, and ) 

ANTHONY GILBERT, Individually; ) 

 ) 

 ) 

 Plaintiffs, ) 

 ) Case No.: 1:20-cv-02872 

 v. ) 

 ) Honorable Judge Manish S. Shah 

THE UNITED STATES OF AMERICA; ) 

LAWNDALE CHRISTIAN HEALTH CENTER, ) Magistrate: Honorable Beth W. Jantz

an Illinois Corporation; LINDSAY ) 

MCCRACKEN, PA-C. ) 

 ) 

Defendants. ) 

AGREED MOTION TO AMEND EXPERT DISCOVERY SCHEDULE 

NOW COME the Plaintiffs, K.G., a Minor, by and through CELESTINA COLEMAN and 

ANTHONY GILBERT, as Parents and Next Friends; and CELESTINA COLEMAN, Individually; 

and ANTHONY GILBERT, Individually; by and through their attorneys, SALVI, SCHOSTOK & 

PRITCHARD P.C., upon agreement of all parties, respectfully move this Honorable Court to 

permit amendment of the expert witness discovery schedule; and in support of their Motion, state 

as follows: 

1. This is a medical malpractice action for damages related to injuries suffered by 

minor, K.G., beginning on November 24, 2018. A bench trial is scheduled to begin on January 22, 

2024. 

2. On January 25, 2023, the parties appeared for a status conference and this Court set 

the following deadlines: 

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All expert discovery shall be completed by May 15, 2023;

Parties to file Joint Status Report by June 7, 2023; and

Bench Trial date of January 22, 2024.

A copy of this order (Doc. #111 is attached Exhibit A.)

3. To date, the following defense expert depositions have been completed:

Raymond Mooney (Physician Assistant) – January 12, 2023

Dr. Amy Davis (Pediatric Neuropsychologist) – February 10, 2023

Dr. Gary Simon (Infectious Disease) – March 13, 2023

Lisa Clapp (Economist) – April 5, 2023

4. There is one remaining defense expert deposition to be taken, which is of Dr. Robert 

Shavelle, and is scheduled for May 2, 2023.

5. Upon completion of Defendants’ expert depositions, Plaintiffs intend on filing 

supplemental reports from their experts. In light of Dr. Shavelle’s deposition date of May 2, 2023, 

Plaintiffs believe that a short extension of time within which to obtain the final deposition 

transcript and complete supplemental reports would be beneficial. 

6. Counsel for Plaintiffs have a trial scheduled to begin on May 15, 2023, in the Circuit 

Court of Peoria County, Illinois; this trial is expected to be finished by May 26, 2023. In light of 

the trial timeline, Plaintiffs respectfully request that the expert discovery deadline of May 15, 2023,

be extended to June 15, 2023, with any additional expert depositions completed by July 15, 2023.

7. Upon completion of any supplemental depositions of Plaintiffs’ experts, the parties 

do not anticipate pursuing any additional discovery.

8. Defendants’ counsel has no objection to an extension of these deadlines.

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WHEREFORE, Plaintiffs, K.G., a Minor, by and through CELESTINA COLEMAN and 

ANTHONY GILBERT, as Parents and Next Friends; and CELESTINA COLEMAN, Individually; 

and ANTHONY GILBERT, Individually, by their attorneys, respectfully request this Honorable 

Court to grant Plaintiffs’ Motion to amend the current expert discovery schedule, and for any other 

relief that the Court deems just. 

 Respectfully submitted, 

/s/ Heidi L. Wickstrom ____

 Heidi L. Wickstrom 

Matthew L. Williams (ARDC #6256858) 

Heidi L. Wickstrom (ARDC #6328082) 

Salvi, Schostok & Pritchard, P.C. 

161 North Clark Street, Suite 4700 

Chicago, IL 60601 

312-372-1227 | 312-372-3720 f 

mwilliams@salvilaw.com 

hwickstrom@salvilaw.com

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