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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DEMETRIUS JOHNSON,

Plaintiff,

vs.

REYNALDO GUEVARA, JOANN HALVORSEN, 

as Personal Representative to the 

Estate of Ernest Halvorsen, DARRYL 

DALEY, WILLIAM ERICKSON, JOHN 

HEALY, and the CITY OF CHICAGO, 

Defendants.

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No. 20 C 4156 

Chicago, Illinois

February 29, 2024

1:45 p.m.

TRANSCRIPT OF PROCEEDINGS

BEFORE THE HON. SARA L. ELLIS

APPEARANCES:

For the Plaintiff: MR. ANAND SWAMINATHAN 

MS. MARGARET GOULD 

Loevy & Loevy,

311 North Aberdeen Street, 3rd Floor, 

Chicago, Illinois 60607 

 

For Defendant

Guevara: MS. GABRIELLE R. SANSONETTI 

Leinenweber, Baroni & Daffada, LLC,

120 North Lasalle Street, Suite 2000,

Chicago, Illinois 60602 

For Defendants Daley,

Halvorsen, Erickson,

and Healy: MR. JOSH M. ENGQUIST

MR. DAVID A. BRUEGGEN

The Sotos Law Firm, P.C.,

141 West Jackson Boulevard, Suite 1240A,

Chicago, Illinois 60604

PATRICK J. MULLEN 

Official Court Reporter

United States District Court

219 South Dearborn Street, Room 1412

Chicago, Illinois 60604

 (312) 435-5565

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APPEARANCES: (Continued.)

For Defendant City

of Chicago: MS. EILEEN E. ROSEN

Rock, Fusco & Connelly, LLC, 

321 North Clark Street, Suite 2200,

Chicago, Illinois 60654

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(Telephonic proceedings on the record.) 

THE CLERK: 2020 CV 4156, Johnson versus Guevara. 

MR. SWAMINATHAN: Good afternoon, Your Honor. Anand 

Swaminathan and Meg Gould for plaintiff Demetrius Johnson. 

MR. ENGQUIST: Good morning -- or good afternoon, Your 

Honor. Josh Engquist and David Brueggen on behalf of 

defendants -- oh, geez -- Halverson, Erickson, Daley, and 

Healy. 

MS. ROSEN: Good afternoon, Your Honor. Eileen Rosen 

on behalf of defendant City of Chicago. 

MS. SANSONETTI: Good afternoon, Your Honor. 

Gabrielle Sansonetti on behalf of Mr. Guevara. 

THE COURT: All right. Good afternoon. 

All right. So we'll go through the joint motion to 

resolve facts. The one thing that I'll note, I noticed that 

the plaintiff made general objections to this process, and I'll 

say this one more time to explain the purpose of the process, 

which in reading both of these motions I still think people 

don't understand. 

It is that when I am looking at a joint statement of 

facts, these are the facts that are undisputed. It doesn't 

mean they're good for you. It doesn't mean they're bad for 

you. It just means that they are facts. What I don't want to 

see is argument in the statement of facts. They simply are 

stating that these are the facts. What could be drawn from 

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those facts may be in dispute. 

So in this case, for example, it is clearly in dispute 

as to the validity and legitimacy of the witness identification 

of Mr. Johnson as the shooter, but that comes from competing 

facts that are not in dispute. They compete with each other 

which creates a dispute, but they themselves are not in 

dispute, and that is what this statement should be. 

So if, for example, you have, you know, a witness that 

testifies that the light was green and somebody else testifies 

that the light was red, you cannot put in the statement of 

facts that the light was green or that it was red because that 

fact is actually in dispute. How do we know it's in dispute? 

From the undisputed fact that this one said it was green and 

the undisputed fact that that one said it was red. That is the 

purpose of this exercise. So I'm overruling the plaintiff's 

general objection, and we will go forward. 

MR. SWAMINATHAN: And, Judge, let me just add this. 

Just for clarification, I appreciate your statement and I 

understand it. I mean, I understood a lot that you said, and 

this is for purposes of our briefing that's now going to be 

coming after this is over. If in the statement of facts you 

have the light is green from one witness and the light is red 

says the other witness, in the brief -- 

THE COURT: In the brief, then you argue it and you 

say: Judge, clearly you cannot find summary judgment here, 

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right, because that is a question of fact that you cannot 

decide on summary judgment. 

MR. SWAMINATHAN: That's right. 

THE COURT: Therefore, it goes to the jury. 

MR. SWAMINATHAN: Right. 

THE COURT: And that's where the argument belongs, in 

the brief, not in the statement of facts. You use the 

statement of facts to set yourself up to make these arguments 

in the brief. 

So let me go through the objections. So I'm looking 

first at the ones regarding the defendant officers' motion. 

MS. SANSONETTI: Judge, is that document 302? 

THE COURT: Yes. All right. So paragraph 28 -- 

paragraphs 28, 30, 31, 32, 33, 35, 37, 38, 39, 42, 43, 44, 59, 

60, 71, 87, and 88 all go in. 

Then do the plaintiffs want their proposed -- it looks 

like they're proposing an additional fact at the bottom of 

their objection to paragraph 88. 

MR. SWAMINATHAN: That's correct, Your Honor. Our 

position is if, as I think you just said, you're admitting 

paragraph 88, what we're saying is we agree to that so long as 

our -- 

THE COURT: All right. Did you propose it? 

MR. SWAMINATHAN: We did. We did propose it. In 

fact, actually at the end of their statement -- 

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THE COURT: Okay. I just want to make sure that this 

is the same as what was -- 

MR. SWAMINATHAN: Yes. So these were presented to 

defendants. We conferred about them and, in fact, I think I 

just spoke with counsel before we walked in. Paragraph 88 

reads as though there was still some dispute, so what we had 

said was -- 

THE COURT: Okay. So yours is 134. Yours is your 

proposal to 134. 

MR. SWAMINATHAN: That's exactly right, Your Honor. 

THE COURT: Okay. 

MR. SWAMINATHAN: What they're saying is they don't 

dispute it if we include -- 

THE COURT: Okay. 

MS. SWAMINATHAN: You know, we just respelled 

"Hispanic." So it sounds like we don't have a dispute about 88 

because we're including 134. 

THE COURT: All right. Then 89 -- 

MR. SWAMINATHAN: That goes in. 

THE COURT: -- goes in. 

MR. SWAMINATHAN: Yeah. 

THE COURT: Then I'll say 134 also goes in. 

90 needs to be modified to read: 

"Mr. Burgos testified he then saw this man fire the 

gun."

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All right. 91 and 97 go in. 

102, however, needs to be edited to read: 

"Elba Burgos was on her front porch on the east side 

of the street, and the shooter was running down the sidewalk on 

the west side of the street. She only had a few seconds to see 

the shooter as he was running by, and any identification came 

only weeks later."

Then remove "she only saw the shooter from the side" 

because that doesn't come from anybody's testimony. That's an 

inference, right, that you want me to make, but that doesn't 

come from anyone's testimony. 

Then I would remove the sentence starting "in 

addition" because, again, that's another inference that you 

want me to make. Then you can say: 

"Elba's trial identification came" -- remove the word 

"only" -- "after she was shown plaintiff's picture multiple 

times, including in a single photo containing plaintiff and two 

dissimilar individuals in a lineup in which he was the only 

person from prior photos."

You can then later argue that that was, you know, an 

invalid or a suspect identification, but it needs to be those 

facts. 

All right. 103 goes in. 106 goes in. 

108 is a bit of a mess, so you need to clean this up. 

So the section where it says "she told police everything 

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happened so fast and she wasn't sure who the shooter was," that 

doesn't come from any police reports. That is coming from the 

testimony of the public defender. 

So, you know, there's a paragraph later -- and we'll 

get to that -- about what he testified to that could go in, but 

it can't go in here about her statements because it's not 

appropriate to go in here. So you can remove that section, and 

the last two sentences should come out. The first one is just 

duplicative, as is the second. 

MR. ENGQUIST: So, Your Honor, I'm just trying to be 

clear. So it would be -- 

THE COURT: It's a bit of a mess of a paragraph, so 

you know what shouldn't be in there, right? 

MR. ENGQUIST: I think -- I believe so, Your Honor. 

THE COURT: All right. So I want the plaintiff to go 

back and rework paragraph 108. If I understand you correctly 

in what you want, you know, you want to include things that 

bring the validity of her identification into question, right? 

So you can do that. It just shouldn't be in the mishmash that 

you've got here, right? 

MR. SWAMINATHAN: Okay. 

THE COURT: It should be that here's the -- and you 

can do -- you can split it up into other paragraphs. You don't 

have to jam it all into one. It can be here's the 

circumstances of what happened during the shooting. She was 

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coming down the stairs behind Mr. Ortiz. Someone shot 

Mr. Ortiz. She turned around and ran back upstairs. 

That's one paragraph, right? Then you can argue from 

that that she would not have had time nor -- well, because she 

wouldn't be expecting this and had been surprised, she wouldn't 

have been paying attention to the identity of the person and 

didn't have a long enough time, even if she was looking, to 

make a valid identification. 

You know, that she also had trouble distinguishing 

among people and that she didn't make a positive 

identification, I mean, those are all be separate sentences. 

They don't all need to go in one where you're making an 

argument in the paragraph about why it's not a valid 

identification. You can argue that later in your brief, so 

you'll just need to fix that. 

Paragraphs 117 and 118 can go in. 

119 should just be edited to read: 

"At her deposition in this case, Rosa Burgos testified 

that she currently suffers from hereditary memory issues but 

stated" -- rather than "confirmed" -- that she would not have 

lied to the police if asked questions about a shooting and 

would have told the truth when under oath in giving testimony 

in a courtroom."

129 can go in. 

130 should be edited to remove "and so could only have 

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seen the side of the shooter's face." That's an inference. 

It's not a fact. Then the last sentence should read: 

"She had only four to five seconds to see the 

shooter's face."

131, you need to remove the portion that says: 

"She told police everything happened so fast and she 

wasn't sure who the shooter was."

132 can go in as well as 133, 134, 135. 

136, the distance from the porch to the sidewalk being 

greater than 50 feet away, I don't know where that comes from. 

I don't see any support for that. 

MR. SWAMINATHAN: You're looking at paragraph 136 

right now, Judge? 

THE COURT: Yes. 

MR. SWAMINATHAN: That is from -- if we go back to 

paragraph 97, paragraph 97 is where I think you said in your 

ruling that 97 comes in. Then in our -- if you look at page 

20 -- 

THE COURT: Yes, I see your map but --

MR. SWAMINATHAN: The response, that's where we put in 

the evidence room. 

THE COURT: I see your map; however, I don't know 

where this map comes from. 

MR. SWAMINATHAN: So it's a Google map, and what we 

would say is we would ask the Court to take judicial notice of 

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the Google map and the distances contained on the map as a 

basis to support our fact. 

THE COURT: Well, then you need -- so this isn't the 

appropriate way to do that, right? You're not going to just 

throw a Google map at me and ask me to take judicial notice, 

right? First of all, the other side would need to know that 

you would be using this map to establish what the distance is 

from where she was sitting to the other side of the street, 

right? 

So if you can fix it, then you can put in the 

distance. If you can support it with something, then go ahead. 

But as it stands right now, it's not supported by anything in 

the record. 

137 can go in. 

All right. Then at docket 305, paragraphs 23 and 31 

can go in, and it looks like the city wants to add 

additional -- an additional fact. Did you propose that fact? 

MS. ROSEN: Are you looking at page 4? 

THE COURT: 4, yes, at the top. 

MS. ROSEN: So the city proposed that fact if the 

objection -- we said "overruled," but I think we meant 

"sustained." Yes. Sorry. I'm saying it backwards. Yes, if 

the Court overrules the objection, which is what the Court just 

did on paragraph 31, we want to add when he -- the language 

that begins "the city proposes the inclusion of the following 

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language as its own fact: When Hickey was asked" -- 

THE COURT: Right. 

MS. ROSEN: Through the cite of Hickey.

THE COURT: Okay. So, yes. So, again, the process 

again is don't imbed what you want in your objection. You 

know, just say: Here's some additional proposed facts that we 

want. 

But I assume that plaintiff doesn't object. 

MS. GOULD: No, Your Honor, we do not object. We say 

if they want to add that, that's fine as an additional fact. 

THE COURT: All right. So you can add that as an 

additional fact. 

So for 35, when I look at Exhibit 13 at Bates number 

55, there's this, and I think it's 1983 training material. 

What I'm not -- what I'm confused about is how are the parties 

using these at all. So are you trying to say that there were 

no training materials that the detectives received prior to 

this incident? Are you trying to say that here are the 

training materials that were in effect at the time of the 

incident? I couldn't follow. 

MS. GOULD: Right. This is -- I think it's because 

the fact preceding this one was not included, and that fact 

referred to pages, I believe, 40 and 41. So what this 

additional fact was responding to was that the material on 

pages 40 and 41 was from the 1996 training manual. Then the 

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reference on 55 to previous materials in the 1980s, that's not 

a -- you know, that's not evidence of a separate training 

manual. That's just a reference to something in 1980. 

So the manual itself was from 1996 with a reference to 

earlier special orders. So our position was that as an 

additional fact, we wanted to point out that this was a 1996 

training manual without reference to another training manual 

before that. 

THE COURT: All right. So then that puts it into 

context, and that makes sense. I'm not sure then what the 

city's objection is if they're only pointing out that this 

training manual was in effect in 1996 and the incident occurred 

prior to that date. 

MS. ROSEN: Sure. The reference in the training 

manual to the previous special orders indicates as best as we 

can tell, right, that this isn't the first time this was 

trained, which is I think what plaintiff is intending to argue. 

THE COURT: Right, but I guess you can -- you know, 

either there is training materials that pre-date this, right, 

that somebody can testify to -- and I presume somebody did -- 

that this was the training in effect at the time of the 

incident and this is what they went through. Then, you know, 

if the city wants to point to what was in a training manual in 

1996, if that occurred prior to the incident, that's not 

helpful. 

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MS. ROSEN: No, I understand the point. 

THE COURT: Okay. So I'll overrule the objection. 

Then 42 is a little hard to follow in that when you 

read everything around that citation, during his deposition he 

says this wasn't directed to supplemental reports; it was for 

general progress reports. 

So what I'm concerned about is leaving it the way it 

is currently I don't think tracks what was said in the 

deposition in the context in which the questions were asked and 

answered, in that he was talking about training on newly 

introduced general progress reports and telling people: We're 

introducing a way for you to keep track of what happened during 

your investigation. So rather than everybody keeping random 

notes that you kept in your pocket or threw away or they went 

through the wash, we're going to memorialize your notes and do 

it in a uniform fashion. That's why we've created a general 

progress report, and we expect the people to use it, and this 

is what the report looks like. 

In reading his deposition, that's my understanding of 

what this particular training was for. It didn't involve 

supplemental reports because it was all about the GPR. So if 

you want, I think what you're trying to get at is that the city 

has not identified anything in the police department that 

trained detectives on what it is that they are supposed to 

include in their reports when they are making reports of 

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investigation. You can say that, and you can certainly argue 

that in the brief but just not this way because I don't think 

that this tracks. Having read his deposition, I don't think it 

tracks what the deposition is saying. 

MS. GOULD: Okay. Thank you. I think when we were -- 

so these are all kind of direct citations, and from what I 

understand, your position is that it's just not providing the 

context that this was about a GPR training. So one proposed 

modification is that we could say the training, you know, on 

general progress reports that detectives received did not 

include training on what was supposed to be in supplemental 

reports. Because the citation does say or supports -- 

THE COURT: But I think it's different in that it 

would instead be two sentences that you could then ask me to 

draw the inference from in your brief, which is, the police 

department provided training to detectives on general progress 

reports, on the use of general progress reports, and the city 

or the police department did not have training on what was to 

be included in supplemental reports. 

If that question, you know, was ever asked, I don't 

know. But, you know, if it was ever proved, if there was 

anything that was ever proffered by the city, I don't know. 

You could say that the record doesn't include what was provided 

as training on supplemental reports, but to say that they 

didn't do it based on questions about training for a GPR isn't 

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an accurate way to reflect what was asked, because GPRs are 

different than supplemental reports and in some ways serve a 

different purpose and this training really was: We're going to 

create a general progress report that contains the information 

that the detectives learn in an investigation. It's all in one 

place and it's maintained in the file, and anybody could go 

back and look at it at any time if they need to, and it is 

required to be part of the case file. 

There are then supplemental reports, and as the 

investigation progresses, detectives then are required to fill 

out a supplemental report that adds to what would be in the 

GPR. There may or may not have been training on supplemental 

reports, right? It might be that once they rolled it out they 

realized: If you write a GPR and you keep investigating, where 

does that information go? We need to create something called a 

supplemental report. 

There might have been training on that. There might 

not have been. I don't know. I didn't litigate this case. I 

have no idea what questions were asked other than what's in all 

of this. So you can go back -- 

MS. GOULD: We can go back to the drawing board on 

this one. 

THE COURT: -- and figure this out, but that's where 

I'm coming from on that one. So I know that the city had 

proposed additional language on that one. Go back and just 

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work that issue out. 

For paragraph 245, I'm going to edit it to read: 

"Foster was unaware of any policy or any training 

about how tentative identifications were to be documented and 

confirmed that detectives were not trained to ask witnesses if 

they were 100 percent confident of their identifications," 

period. 

"Tentative identifications would" -- I'd take out the 

word "only" -- "would occur if the witnesses themselves 

volunteered that they were not 100 percent certain."

Then the city can add the additional fact on that one, 

and I think that's it. 

Okay. So I now need to set a briefing schedule. 

Okay. So when do folks want to file motions for summary 

judgment? 

MR. SWAMINATHAN: So, Your Honor, we're not filing a 

motion for summary judgment. We filed previously as to, you 

know, a discrete issue involving Mr. Johnson. So I think it's 

the defendants who will be filing. I just want to state for 

the record -- and I think I did this last time -- my client was 

actually supposed to be here. He has an emergency with his 

son, so he wasn't able to be here. But, you know, he continues 

to insist that this process since fact discovery closed more 

than a year and a half ago, expert discovery was something like 

six, nine months ago, whatever it was, you know, he feels, you 

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know, we've got to move. 

And from our perspective, there's no reason the 

summary judgment motions shouldn't have been -- they should 

have been working on those for the last year. They, you know, 

sent us a statement in fact in November, which was later than 

we thought it should have happened. But there's no reason that 

we shouldn't be filing summary judgment motions in a week, you 

know, or whatever it is. You may not grant that amount of 

time, but in our view, you know, it's time to move. 

THE COURT: All right. Well, you don't even know what 

they're going to say, right? 

MS. ROSEN: Judge, we would like until April 12th to 

file the summary judgment. We need to get the transcript and 

revise these particular facts, and then we also have three 

different summary judgments that hit on actually March 25th, 

April 8th, and I'm looking for the other one which is somewhere 

in between there. So based on all of that, we would like until 

April 12th to file summary judgment. 

THE COURT: All right. And any Daubert motions? 

MS. ROSEN: Correct. 

THE COURT: So everything is on the same date? 

MS. ROSEN: Correct. 

THE COURT: But know this. I'm not moving these dates 

at all. So an act of God, whatever, figure it out. I'm not 

moving the dates -- 

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MS. ROSEN: Understood. 

THE COURT: -- for anything and for anyone. 

All right. When do the -- when does the plaintiff 

want to file a response? So keep in mind you're responding to 

all the summary judgment motions and then any Daubert. 

MR. SWAMINATHAN: Yes, we've seen the Daubert motions 

now in two companion cases. I assume they'll be very similar, 

same experts. So we'll be prepared to file our response 

within, say, 30 days. 

THE COURT: Okay. That's fine. 

Ms. Johnson? 

THE CLERK: May the 13th. 

MR. SWAMINATHAN: Thank you. 

THE COURT: All right. And then the replies? 

(Discussion off the record.) 

MS. ROSEN: So plaintiff is filing their responses on 

May 13th, we said, right? 

THE COURT: Yes. 

MR. SWAMINATHAN: Could we get till June 10th? 

THE COURT: All right. But again, know that I'm not 

moving the dates, so that's it. 

All right. So then I'll strike the July 10th ruling 

date and set it for September 17th. So it's not that far off 

from the prior July ruling date. 

All right. So I'll see everybody then on September 

Case: 1:20-cv-04156 Document #: 308 Filed: 04/12/24 Page 19 of 20 PageID #:14947
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17th. 

MS. ROSEN: Thank you, Judge. 

MR. ENGQUIST: Thank you, Judge. 

MR. SWAMINATHAN: Thanks. 

MS. SANSONETTI: Thanks, Judge.

(Proceedings concluded.) 

C E R T I F I C A T E

I, Patrick J. Mullen, do hereby certify that the 

foregoing is a complete, true, and accurate transcript of the 

proceedings had in the above-entitled case before the Honorable 

SARA L. ELLIS, one of the judges of said Court, at Chicago, 

Illinois, on February 29, 2024.

/s/ Patrick J. Mullen

Official Court Reporter

United States District Court

Northern District of Illinois

Eastern Division 

Case: 1:20-cv-04156 Document #: 308 Filed: 04/12/24 Page 20 of 20 PageID #:14948