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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

WESTERN DIVISION

Pierre G. Thorsen,

Plaintiff,

v.

Community Unit School District 300,

Defendant.

 Case No. 3:20-cv-50132

 

 Judge Iain D. Johnston

 Magistrate Judge Margaret J. Schneider 

 

 

JOINT STATUS REPORT

Plaintiff Pierre G. Thorsen (“Thorsen”) and Defendant Community Unit School District 

300 (“D300”), hereby submit the following joint status report:

A. Defendant, D300, and Plaintiff, Thorsen, submitted Rule 26(1) disclosures on or 

about August 30, 2021. 

B. Plaintiff submitted his responses to a Request to Admit and Interrogatories on or 

about October 29, 2021.

C. Defendant answered Interrogatories and a Notice to Produce on December 16, 2021, 

with many objections which included objections based on State and Federal 

limitations on the disclosure of student record information. Defendant supplemented 

its production on January 29, 2022. Defendant has produced over 600 pages of 

responsive records in addition to the substantive responses to Plaintiffs Interrogatories 

and Requests to Produce.

D. On December 17, 2021, Plaintiff initially requested a F.R.C.P. 26 (b )(5) privilege log 

regarding documents withheld for privilege. The District provided Plaintiff with a 

privilege log on January 29, 2022.

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E. Plaintiff and Defendant have not resolved their differences over the District's 

discovery responses, despite exchanges over the past months. The District continues 

to maintain that it has provided relevant information in its possession proportionate to 

the needs of the case. Plaintiff continues to seek discovery of additional information. 

This court has received briefs on Plaintiffs Motion to Compel.

F. CUSD 300 took the deposition of Pierre Thorsen on June 7, 2022. Pierre Thorsen 

took the depositions of Mike Williamson, June 8, 2022, Colleen O' Keefe, June 16, 

2022, and Lynn Adler, June 30, 2022. Pierre Thorsen is scheduled to take the 

deposition of Kara McMahon August 10, 2022. CUSD 300 has no other witnesses 

disclosed order F.R.Civ.P.26.

G. On July 22, 2022, Thorsen served CUSD 300 with Supplemental Rule 26(A)(l) 

Disclosures, giving greater details regarding testimony from Thorsen and four other 

previously disclosed witnesses, as well as four new witnesses. District 300 does not 

consider this testimony or these witnesses relevant to any issues in dispute in this 

Title VII employment discrimination case.

H. Pierre Thorsen has been attempting to take the deposition of Aliya Chaudhry, with the 

cooperation of her approved counsel. Counsel for Aliya Chaudhry wants only one 

deposition for all three cases and is working on giving out dates in late August and 

September. Counsel for D300 only learned of this in the past week. D300 objects to 

the necessity and relevance of this deposition in this Title VII employment 

discrimination case. 

I. Thorsen expects to complete deposition fact discovery by October 15, 2022. Thorsen

has not yet seen whether more documents will be produced, as a result of his Motion

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to Compel, and more discovery is needed. Thorsen has not yet had the opportunity to

take Aliya Chaudhry's deposition. If necessary Thorsen will bring a Motion to Extend

the fact discovery deadline.

J. D300 objects to any extension of discovery, including for the limited purpose of 

obtaining the deposition of Aliya Chaudhry. Plaintiff had ample opportunity to 

pursue this deposition prior to this time. As a student, Ms. Chaudhry would not 

possess any relevant knowledge of Plaintiff’s employment relationship or knowledge 

of the circumstances under which he resigned his job. Plaintiff has not pursued other 

avenues to address any issues which he believes Ms. Chaudhry’s testimony would 

address, to include proposed stipulations of fact. Continuing discovery at this point 

only serves the purpose of delay; it will not bring greater clarity to the issues in 

dispute in this Title VII employment discrimination matter. All individuals were 

identified to have relevant knowledge of the circumstances under which Plaintiff 

resigned his job and the District’s disciplinary actions have been deposed (or will be 

before the scheduled close of discovery). This case has been pending for over two 

years. The District is prepared to move forward with a Motion for Summary 

Judgment. D300 requests a status hearing to set a briefing schedule for a Motion for 

Summary Judgment that accounts for resolution of any outstanding discovery issues 

remaining after resolution of Plaintiff’s Motion to Compel.

Dated: August 10, 2022

PIERRE G. THORSEN

By: /s/Timothy J. Lowery

 Timothy J. Lowery

 Hanson Law Group LLP

Dated: August 10, 2022

COMMUNITY UNIT SCHOOL 

DISTRICT 300

By: /s/ Abigail Rogers

 Abigail C. Rogers

 Engler Callaway Baasten & Sraga LLC

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 1000 Hart Road, Suite 300

 Barrington IL 60010

 P: 847-277-9988

 timlowery@hansonlawgrp.com

 keithhanson@hansonlawgrp.com

 nancymondragon@hansonlawgrp.com

 2215 York Road, Suite 400

 Oak Brook IL 60523

 P: 630-313-4750

 arogers@ecbslaw.com

 

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