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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

 

D’ANDRE BRADLEY; DAVID D. MOORE; )

TARA D. MOORE; BRETT O. SHELTON; )

ILLINOIS STATE RIFLE ASSOCIATION; and )

SECOND AMENDMENT FOUNDATION, INC. )

)

Plaintiffs, )

) Case No. 1:20 CV 4270

v. )

)

BRENDAN F. KELLY, in his official capacity as )

Director of the Illinois State Police; and JESSICA )

TRAME, in her official capacity as Bureau Chief of )

the Illinois State Police Firearms Services Bureau, )

)

Defendants. )

JOINT STATUS REPORT 

The Plaintiffs, D’Andre Bradley, David D. Moore, Tara D. Moore, Brett O. 

Shelton, Illinois State Rifle Association, and Second Amendment Foundation, Inc., 

and the Defendants, Brendan F. Kelly, in both his individual and official capacity as 

Director of the Illinois State Police, and Jessica Trame1, in both her individual and 

official capacity as Bureau Chief of the Illinois State Police Firearms Services 

Bureau, by and through their respective undersigned counsel, and pursuant to the 

Court’s Order of September 2, 2020 (Dkt. #12), submit this Joint Status Report: 

I. Nature and Basis of Claims and Defenses 

Plaintiffs allege violations of their Second Amendment and Fourteenth 

Amendment procedural due process rights due to the Defendants’ administration of 

 1 Jarod Ingebritsen has since replaced Jessica Trame as the Bureau Chief of the Illinois State 

Police’s Firearms Services Bureau.

Case: 1:20-cv-04270 Document #: 18 Filed: 09/23/20 Page 1 of 3 PageID #:78
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the application process of the Firearm Owners Identification (“FOID”) Act (430 

ILCS 65/10). Plaintiffs filed a Complaint on July 20, 2020, to which Defendants filed 

a Motion to Dismiss on September 17, 2020, asserting a lack of jurisdiction. A 

briefing schedule is pending (Dkt. # 16).

Plaintiffs seek declaratory and injunctive relief. Plaintiffs also are making a 

42 U.S.C. § 1988 claim.

The major legal and factual issues anticipated in the case are the whether 

the claims of the individual plaintiffs are moot and whether the organizational 

plaintiffs have standing to bring this claim. If this Court has jurisdiction over the 

case, the major legal and factual issues anticipated are administration of the FOID 

card application system by the Defendants and their employees/subordinates, and 

whether the FOID application system, and the administration thereof, violate the 

Plaintiffs’ Second and Fourteenth Amendment rights.

II. Settlement Discussions 

The parties discussed settlement possibilities but, at this time, the parties do 

not foresee a prompt resolution of this matter.

III. Proposed Discovery Plan 

The Defendants will be filing a Motion to stay discovery until the resolution 

of their pending Motion to Dismiss. Plaintiffs object to the Motion. However, given 

the pending Motion, the parties do not have an agreement on a discovery plan or 

schedule at this time, including for Rule 26(a)(1) disclosures.

In addition, in the matter of Thomas, et al v. Kelly, et al, No. 20-CV-734, the 

Case: 1:20-cv-04270 Document #: 18 Filed: 09/23/20 Page 2 of 3 PageID #:79
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Defendants filed a Motion to Reassign the instant case under Local Rule 40.4. A 

copy of this motion was noticed in the instant case at Dkt. 15.

Dated: September 24, 2020 Respectfully submitted,

Attorneys for Plaintiffs Attorneys for Defendants

D’Andre Bradley, David D. Moore Brendan F. Kelly and Jessica Trame

Tara D. Moore, Brett O. Shelton,

Illinois State Rifle Association, and

Second Amendment Foundation, Inc. 

/s/ David G. Sigale /s/ Mary A. Johnston 

David G. Sigale (Atty. ID #6238103) Mary A. Johnston (Atty. ID#6320865)

Law Firm of David G. Sigale, P.C. Office of the Illinois Attorney General

799 Roosevelt Road, Suite 207 100 West Randolph Street, 13th Floor

Glen Ellyn, IL 60137 Chicago, IL 60601

630.452.4547/630.596.4445 (312) 721-8734

dsigale@sigalelaw.com mjohnston@atg.state.il.us 

/s/ Gregory A. Bedell

Gregory A. Bedell (Atty. ID# 6189762)

Knabe & Bedell

33 North Dearborn Street

10th Floor

Chicago, Illinois 60602

312.977.9119

gbedell@kkbchicago.com

/s/ Jacob Heubert

Jacob Huebert (Atty. ID# 6305339)

Martha Astor (appearing pro hac vice)

Scharf-Norton Center for Constitutional Litigation at the

GOLDWATER INSTITUTE

500 E. Coronado Rd.

Phoenix, AZ 85004

Telephone: (602) 462-5000

jheubert@goldwaterinstitute.org

litigation@goldwaterinstitute.org

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