IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF

ILLINOIS EASTERN DIVISION

DEMETRIUS JOHNSON )

) Case No. 20 CV 4156

Plaintiff, )

) Judge Sara L. Ellis

v. )

) Magistrate Judge Heather K. McShain

REYNALDO GUEVARA, et al. )

)

Defendants. ) JURY TRIAL DEMANDED

)

DEFENDANTS’ UNOPPOSED MOTION TO EXTEND EXPERT DISCOVERY AND 

SUMMARY JUDGMENT BRIEFING SCHEDULE

Defendants, Reynaldo Guevara, Darryl Daley, Geri Lynn Yanow, as special representative 

for William Erickson (deceased), Ernest Halvorsen (deceased), John Healy (deceased), and The 

City of Chicago, together through their undersigned counsel, respectfully move this Court for an 

extension of time to complete expert discovery. In support of this motion, Defendants state as 

follows: 

1. On January 16, 2023, this Court set a schedule for expert discovery as well as a 

briefing schedule on Defendants’ anticipated motion for summary judgment. (Dkt. 204). 

2. Subsequently, on February 27, 2023, Plaintiff sought additional time to provide his 

expert reports. (Dkt. 217). 

3. Accordingly. on March 8, 2023, Plaintiff disclosed three expert witnesses; (1) 

Thomas Tiderington, a police procedures expert and Monell expert opining on evidence 

suppression; (2) Dr. Jennifer Dysart, an eyewitness identification expert opining on the 

identification procedures used in the criminal investigation; and (3) Dr. Nancy Steblay, a Monell 

Case: 1:20-cv-04156 Document #: 244 Filed: 05/01/23 Page 1 of 3 PageID #:5798
expert opining on the rate at which eyewitnesses made suspect identifications. 

4. Pursuant to the current schedule set in Dkt. 204, Defendants are to depose these 

experts by May 1, 2023. 

5. Although Plaintiff provided Defendants with dates of availability for the deposition 

of these expert witnesses, due to scheduling conflicts, including a myriad of expert depositions 

already scheduled and deadlines in other Guevara related cases, Defendants were simply unable 

to accommodate the dates proposed. 

6. The first available date for all Parties for Defendants to depose Mr. Tiderington is 

May 9, 2023, which has been confirmed. The Parties are working to finalize dates for Dr. Dysart 

and Dr. Steblay as well. 

7. Thus, Defendants request that the expert schedule for the remaining deadlines be 

extended as set forth below:

a. 6/5/2023 – Defendants to depose Plaintiff’s experts.

b. 7/12/2023 – Defendants’ expert disclosures due.

c. 8/21/2023 – Plaintiff’s to complete Defendants’ expert depositions. 

8. Furthermore, this shift in the expert schedule requires the summary judgment 

schedule to be shifted as well. Accordingly, Defendants’ request the remaining summary judgment 

schedule as set forth below: 

a. 9/20/2023 – Defendants’ motion for summary judgment

b. 10/20/2023 – Plaintiff’s response to Defendants motion for summary judgment. 

c. 11/10/2023 – Defendants’ reply in further support of their motion for summary 

judgment. 

9. Defendants have conferred with Plaintiff’s counsel and they do not oppose this 

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motion or the adjustment to the schedule. 

WHEREFORE, Defendants respectfully request that this Court grant this Motion and 

extend the expert discovery schedule and summary judgment schedule, as set forth above, and for 

any other relief as this Court deems just and reasonable. 

DATE: May 1, 2023 Respectfully Submitted,

/s/ Eileen E. Rosen 

Special Assistant Corporation Counsel for 

Defendant City of Chicago 

Eileen E. Rosen 

Austin G. Rahe 

Catherine M. Barber 

Theresa B. Carney 

ROCK FUSCO & CONNELLY, LLC 

333 West Wacker Drive, 19th Fl.

Chicago, IL 60606 

(312) 494-1000 

erosen@rfclaw.com 

/s/ Josh M. Engquist 

Special Assistant Corporation Counsel for 

Defendant Individual Officers 

James G. Sotos 

Josh M. Engquist 

Jeffrey Kivetz 

David A. Brueggen 

Carson W. Canonie 

The Sotos Law Firm, P.C. 

141 W. Jackson Blvd, Suite 1240A 

Chicago, IL 60604 

(630)735-3300 

JEngquist@jsotoslaw.com 

/s/ Thomas M. Leinenweber 

Special Assistant Corporation Counsel for 

Defendant Reynaldo Guevara 

Thomas M. Leinenweber 

James V. Daffada 

Megan McGrath 

LEINENWEBER BARONI & DAFFADA, 

LLC 

120 North LaSalle Street 

Suite 2000 

Chicago, IL 60602 

(312) 663-3003 

thomas@ilesq.com

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