UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DEBORAH LAUFER, Individually,

Plaintiff,

v.

233 E ONTARIO HOTEL PROPCO LLC 

d/b/a IVY HOTEL, a Foreign Limited Liability 

Company,

Defendant.

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Case No. 1:20-cv-04593

Honorable Elaine E. Bucklo

REPORT OF PARTIES’ PLANNING MEETING

1. Meeting. Pursuant to FED. R. CIV. P. 26(f), a meeting was held on October 9, 2020 

via phone and was attended by: Kimberly A. Corkill, Esq. (for Plaintiff) and Mary 

A. Smigielski and Kenneth D. Walsh (for Defendant)

2. Pretrial Schedule. The parties jointly propose to the court the following discovery 

plan:

Plaintiff to amend pleadings by October 23, 2020.

Plaintiff to add any additional parties by October 23, 2020.

Defendant to amend pleadings by October 30, 2020.

Defendant to add any additional parties by October 30, 2020.

3. Discovery. Discovery will be needed on the following subjects: 

(a) Disclosures pursuant to Pursuant to FED. R. CIV. 26(a)(1) to be made by 

November 13, 2020. Fact discovery to be commenced in time to be completed by 

February 28, 2021.

Case: 1:20-cv-04593 Document #: 10 Filed: 10/13/20 Page 1 of 3 PageID #:35
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(b) The parties expect they will need approximately 4 depositions.

(c) Reports from retained experts under Rule 26(a)(2) due:

Date for plaintiff to comply with FRCP(26)(a)(2): March 1, 2021

Date for defendant to comply with FRCP(26)(a)(2): March 15, 2021

All expert discovery to be completed by (date). March 31, 2021.

(d) All potentially dispositive motions should be filed by April 30, 2021.

(e) Final pretrial order: Plaintiff to prepare proposed draft by May 15, 2021; parties 

to file joint final pretrial order by May 30, 2021

(f) The case should be ready for trial by June 1, 2021 and at this time is expected to 

take approximately 1 to 2 days.

4. Settlement. At least 14 days prior to the Rule 16(b) scheduling conference, plaintiff 

is directed to make a written settlement demand to the defendant. At least 7 days 

prior to the scheduling conference defendant is to respond in writing to the 

plaintiff’s settlement demand.

5. Consent. Parties do not consent unanimously to proceed before a Magistrate Judge.

Date: October 13, 2020. 

Case: 1:20-cv-04593 Document #: 10 Filed: 10/13/20 Page 2 of 3 PageID #:36
By: /s/ Kimberly A. Corkill, Esq.

Kimberly A. Corkill, Of Counsel

Thomas B. Bacon, P.A.

7 N. Coyle Street

Pensacola, FL 32502

ph. 850-375-3475

fx 877-828-4446

kimberlyatlaw@gmail.com

Florida Bar Id. No. 84942

Thomas B. Bacon, Esq.

Thomas B. Bacon, P.A. 

644 North Mc Donald St.

Mt. Dora, FL 32757

ph. (850)375-3475

kimberlyatlaw@gmail.com

Florida Bar. Id. No. 139262

By: /s/ Mary A. Smigielski

Mary A. Smigielski

Kenneth D. Walsh

LEWIS BRISBOIS BISGAARD & SMITH 

LLP

550 West Adams Street, Suite 300

Chicago, Illinois 60661

312.463.3377

Mary.Smigielski@lewisbrisbois.com

Kenneth.Walsh@lewisbrisbois.com

Stephen E. Abraham, California State Bar # 

172054

LEWIS BRISBOIS BISGAARD & SMITH 

LLP

650 Town Center Drive, Suite 1400

Costa Mesa, CA 92626

Telephone: 714.668.5562

Facsimile: 714.850.1030

E-Mail: 

Stephen.Abraham@lewisbrisbois.com

Pro Hac Application to be Submitted

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