UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

JACOB DANESHRAD; JOSEPH 

DANESHRAD; HASSAN 

BLURFRUSHAN, 

Plaintiffs, 

v. 

TREAN GROUP, LLC; NANCY 

STUBENRAUCH; MARK FRANTZ; and 

DOES 1 to 100, inclusive, 

Defendants. 

CASE NO. 1:20-CV-03887 

Hon. Jorge L. Alonso 

Magistrate Judge Sunil R. Harjani 

JOINT STATUS REPORT 

Pursuant to the Court’s Order dated December 8, 2020 (Dkt. No. 35), Plaintiffs Jacob 

Daneshrad, Joseph Daneshrad, and Hassan Blurfrushan (collectively, “Plaintiffs”) and Defendants 

Trean Group, LLC (“Trean”), Nancy Stubenrauch, and Mark Frantz (collectively with Trean and 

Stubenrauch, “Defendants”) jointly submit the following Status Report to Magistrate Judge 

Harjani regarding the status of discovery in this case. 

I. Discovery Status

A. Discovery Requests Issued by Defendants 

As of the date of filing, Defendants have served the following discovery requests on 

Plaintiffs: 

 First Sets of Interrogatories to Plaintiffs Joseph Daneshrad, Jacob Daneshrad, and 

Hassan Blurfrushan, served May 1, 2020; Responses served June 25, 2020; 

 Second Set of Interrogatories to Plaintiff Joseph Daneshrad, served July 16, 2020; 

Response served September 21, 2020; 

 First Sets of Requests for Production of Documents to Plaintiffs Joseph Daneshrad, 

Jacob Daneshrad, and Hassan Blurfrushan, served May 1, 2020; Response served 

June 25, 2020; 

 Second Sets of Requests for Production of Documents to Plaintiffs Joseph 

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Daneshrad and Jacob Daneshrad, served May 4, 2020.1 

Pursuant to this Court’s December 8, 2020 Order, Plaintiffs were required to provide a 

supplemental document production of attachments missing from e-mails they produced by 

December 14, 2020. (Dkt. No. 35). On February 22, 2021, the date of the filing of this Status 

Report, Plaintiffs produced documents to Defendants, which Plaintiffs assert contain the 

attachments from the e-mails previously produced by Plaintiffs. Counsel for Defendants have not 

yet had an opportunity to review the completeness of this production, but will update the Court 

regarding the completeness of Plaintiffs’ supplemental production at the status hearing on 

February 25th. 

B. Discovery Requests Issued by Plaintiffs 

Plaintiff Joseph Daneshrad issued his First Requests for Production of Documents to 

Defendants on February 22, 2021. Plaintiffs also intend to serve Interrogatories and Request for 

Admissions. 

The Court’s December 8, 2020 Order (Dkt. No. 35) required all written discovery to be 

issued by December 28, 2021. Because the December 28, 2021 date is eight months after the factdiscovery close deadline in the Order, Defendants understand that Plaintiffs’ deadline to issue 

written discovery was December 28, 2020, understood that the reference in the Court’s Order to 

2021 was a clerical error, and take the position that Plaintiffs waived their right to issue written 

discovery, including the Requests for Production Plaintiff issued on the date of this filing and any 

future written discovery not yet issued. 

Plaintiffs take the position that they have until December 28, 2021, as ordered by this Court, 

1

 Plaintiffs did not serve separate written responses to Defendants’ Second Sets of Requests for Production 

of Documents, but represent that their June 25, 2020 responses to Defendants’ First Sets of Requests for 

Production of Documents and corresponding document production contained Plaintiffs’ responses to the 

Second Set of Requests for Production. 

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to issue written discovery. Plaintiffs had previously requested an extension of 3 months and this 

Court granted Plaintiffs’ request. Prior to the said extension, there was no separate deadline for 

written discovery, and it did not occur to Plaintiffs’ counsel that the Court would grant a 3-month 

extension of all discovery and then, from Plaintiffs’ perspective, take away the extension for 

written discovery. In addition, Defense counsel did not bring to the attention of Plaintiffs’ counsel 

this contention that the December 28, 2021 deadline is a Court’s clerical error prior to what 

Defendants assert is the correct December 28, 2020 deadline and only brought it up just recently 

during discussion for drafting this joint report. Plaintiffs take the position the Court extended the 

discovery cut-off to April 15, 2021 and set the written discovery deadline for December 28, 2021. 

Plaintiff takes the position that Defendants cannot lie in wait for a deadline that they believe was 

made in error to pass and then argue waiver. Plaintiffs further take the position that if the Court 

did indeed make a clerical error, it would be unfair to punish Plaintiffs for a Court clerical error. 

However, Defendants’ counsel was unaware that Plaintiffs assert the position that they may 

issue written discovery eight months after the fact-discovery close deadline until this recent call 

between counsel and thus had no reason to believe they needed to raise this issue with Plaintiffs 

given that the date appeared to be a clear clerical error. 

Accordingly, the Parties request clarification from the Court regarding whether Plaintiffs 

properly issued Plaintiff Joseph Daneshrad’s First Requests for Production of Documents to 

Defendant on February 22, 2021, whether Plaintiffs may issue any further written discovery, and, 

if so, their deadline to issue. 

II. Completed Fact Witness Depositions

Defendants have taken the following depositions: 

December 3, 2020: Plaintiff Joseph Daneshrad 

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December 7, 2020: Plaintiffs Jacob Daneshrad and Hassan Blurfrushan 

Plaintiffs have not taken any fact witness depositions to date, but on February 22, 2021, 

Plaintiffs issued notices of depositions and demands for production of documents to Nancy 

Stubenrauch, Mark Frantz, the Person Most Knowledgeable for Trean, if different. 

III. Remaining Fact Witness Depositions to be Completed

Defendants will take the deposition of William Josephson on March 4, 2021. Defendants 

will also depose a corporate representative of non-party FCStone, and will do so by March 26, 

2021. 

Plaintiffs will take the deposition of Nancy Stubenrauch on March 11, 2021 and Mark 

Frantz on March 12, 2021 and the Person Most Knowledgeable for Trean, if different, before 

March 26, 2021. 

IV. Status of Settlement Discussions

The Parties have not engaged in settlement discussions to date. The Parties believe that 

informal settlement discussion would be the most productive at this point in the case and do not 

request a formal settlement conference at this time. 

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DATED: February 22, 2021 DANESHRAD LAW FIRM, APC 

By: /s/ Joseph Daneshrad

Joseph Daneshrad 

Daneshrad Law Firm APC 

12400 Wilshire Boulevard Suite 400 

Los Angeles, CA 90025-1030 

310-447-3544 

daneshrad@yahoo.com 

Attorneys for Plaintiffs JACOB DANESHRAD, 

JOSEPH DANESHRAD and HASSAN 

BLURFRUSHAN

DATED: February 22, 2021 THOMPSON COBURN LLP 

By: /s/ Lukas Sosnicki

Lukas Sosnicki 

Thompson Coburn LLP 

2029 Century Park East 

19th Floor 

Los Angeles, CA 90067 

310-282-2500 

lsosnicki@thompsoncoburn.com 

Holly H. Campbell 

Thompson Coburn LLP 

55 E. Monroe St. 

37th Floor 

Chicago, IL 60603 

312-346-7500 

hcampbell@thompsoncoburn.com 

Attorneys for Defendants TREAN GROUP, LLC, 

NANCY STUBENRAUCH, and MARK 

FRANTZ

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