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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DEMETRIUS JOHNSON, 

 

Plaintiff, 

v.

REYNALDO GUEVARA, the ESTATE of 

ERNEST HALVERSON, DARRYL DALEY, 

WILLIAM ERICKSON, JOHN HEALY, and 

the CITY OF CHICAGO

Defendants. 

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Case No. 20-cv-4156 

 Judge Sara L. Ellis 

Magistrate Judge Heather K. McShain

JURY TRIAL DEMANDED

 

PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME

Plaintiff, DEMETRIUS JOHNSON, by and through his attorneys, LOEVY & LOEVY, 

hereby moves the Court for an extension of time to make disclosures of expert witnesses 

pursuant to Rule 26(a)(2). Plaintiff has consulted with counsel for the Defendants, who do not 

oppose this motion. 

In support of his motion Plaintiff states:

1. Plaintiff filed this case in November 2020. Dkt 1.

2. The Court’s November 1, 2022 scheduling order provides that Plaintiff’s Rule 

26(a)(2) disclosures are to be served on December 30, 2022. Dkt. 175.

3. Plaintiff’s counsel has been litigating this matter diligently, including the 

completion of fact discovery; filing an affirmative motion for summary judgment; and identifying 

experts in the specialized fields involved in this case.

Case: 1:20-cv-04156 Document #: 185 Filed: 12/19/22 Page 1 of 3 PageID #:2496
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4. In light of other previously-set deadlines in this and other cases as well as the 

holidays, Plaintiff requests an extension to serve his expert disclosures.

5. This is Plaintiff’s first request for an extension of the discovery schedule.

6. Plaintiff’s counsel has contacted the defendants, who do not oppose Plaintiff’s 

request, subject to corresponding extensions of the remaining expert discovery and Defendants’ 

dispositive motion deadlines in this case.

7. In light of the foregoing, Plaintiff respectfully submits there is good cause to extend 

the deadlines set forth in Dkt. 175 as follows:

- Plaintiff’s Rule 26(a)(2) disclosures: January 30, 2023

- Depositions of Plaintiff’s experts: March 30, 2023

- Defendants’ Rule 26(a)(2) disclosures: May 1, 2023

- Depositions of Defendants’ experts: June 26, 2023

- Defendants’ motion for summary judgment: July 31, 2023

- Plaintiff’s response to Defendants’ motion for summary judgment: August 28, 2023

- Defendants’ reply for their motion for summary judgment: September 11, 2023

WHEREFORE, Plaintiff respectfully requests the court enter an order extending 

deadlines in this matter, as set forth in Paragraph 7 of this motion.

Case: 1:20-cv-04156 Document #: 185 Filed: 12/19/22 Page 2 of 3 PageID #:2497
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RESPECTFULLY SUBMITTED,

/s/ Danielle Hamilton 

Counsel for Plaintiff 

Jon Loevy 

Anand Swaminathan 

Steven Art

Danielle Hamilton

Isabella Aguilar

LOEVY & LOEVY

311 N. Aberdeen 

Chicago, Illinois 60607 

(312) 243-5900 

hamilton@loevy.com

CERTIFICATE OF SERVICE

I, Danielle Hamilton, an attorney, certify that on December 19, 2022, I filed the foregoing 

pleading using the Court’s CM/ECF system, which effected service on all counsel of record. 

/s/ Danielle Hamilton 

One of Plaintiff’s Attorneys

Case: 1:20-cv-04156 Document #: 185 Filed: 12/19/22 Page 3 of 3 PageID #:2498