UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ZHU ZHAI HOLDINGS LIMITED and ) 

PETER PUI TAK LEE, ) 

 ) Case No. 20-cv-04985 

Plaintiffs/Judgement Creditors, ) 

 ) Judge Sharon Johnson Coleman 

v. ) 

 ) Hon Sidney I. Schenkier (Ret.), 

STEVEN IVANKOVICH, ) Special Master

 ) 

 Defendant/Judgement Debtor ) 

SPECIAL MASTER’S ORDER NO. 10

On August 17, 2021, the presiding district judge entered a default judgment in favor of 

plaintiffs Zhu Zhai Holdings Limited and Peter Pui Tak Lee (“plaintiffs”) and against Steven 

Ivankovich (“defendant”) in the amount of $4,503,842 (doc. # 92). Post judgement proceedings 

to collect on the judgment ensued and remain ongoing. 

By an order dated January 19, 2014, the presiding district judge appointed the undersigned 

to serve as Special Master “for the purpose of hearing and resolving issues and disputes related to 

the parties’ post-judgment discovery proceedings, as identified in Plaintiffs’ pending postjudgment motions, Dkts 276, 285” (doc. # 290: Order Appointing Special Master (“Appointment 

Order”) at ¶ 1). Pursuant to that mandate, the district judge directed the Special Master to address 

“issues related to but not limited to the parties’ post-judgment discovery proceedings, the discovery 

produced thus far, and the location and amount of Judgment Debtor Ivankovich’s assets” (Id.). 

On August 28, 2024, the Special Master convened a status hearing by Zoom in the matter. 

Counsel for plaintiffs and defendant attended the hearing, as well as counsel for Pilgrim Warwick 

LLC, Pilgrim Coulter LLC, Pilgrim Windtree LLC, Pilgrim Caribbean Isle LLC, and Pilgrim 

Forest Park LLC (collectively, the “Third Party LLCs”) and counsel for Third Party Intervenor 

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Jeanette Ivankovich (“Ms. Ivankovich”), who was given leave to intervene pursuant to the district 

judge’s March 19, 2019, order (doc. # 307). Also in attendance were Ms. Ivankovich attended

and Andrea Hendrix, who observed the proceeding on behalf of various governmental entities in 

Reagan County, Texas. Pursuant to the Appointment Order, the May 1, 2024, hearing was court 

reported and a transcript of the hearing (along with this Order) will be docketed. 

In preparation for the hearing, on August 26 and 27, 2024, the parties filed on JAMS Access 

separate status reports. Based on the discussion with the parties at the hearing, the Special Master 

issues the following order: 

1. Motion to Release Funds. Pursuant to the district judge’s order dated February 8, 

(doc. # 296), the sum of $1,494,619.10 is on deposit in the Court Registry. In their status report 

and during the hearing, defendant and the Third-Party LLCs moved for an order releasing those 

funds (in whole or in part) to the Third-Party LLCs. In the alternative, the defendant and the ThirdParty LLCs asked for a schedule to file for summary judgment on the issue of the release of the 

funds. Those motions were denied.

2. Evidentiary Hearing. The Special Master set an evidentiary hearing to commence on

November 7, 2024, at 9:00 a.m. CT at the JAMS Resolution Center in Chicago, Illinois. The sole 

subject of that hearing will be whether the funds on deposit with the Court (a) are an asset of the 

defendant, which should be held for distribution to plaintiffs or to Intervenor Ivankovich as would 

be determined in a later, separate proceeding, or (b) instead should be released to the Third-Party 

LLCs. The schedule for preparation of pre-hearing materials is as follows:

A. By October 11, 2024, the parties shall exchange proposed stipulations, witness lists, 

and exhibit lists, and the designations of any deposition testimony they plan to offer into evidence.

B. By October 15, 2024, they shall meet and confer in a good faith effort to reach

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stipulations and to resolve any objections over exhibits and witnesses. In addition, by that date the 

parties shall provide any objections they have to deposition designations and any counterdesignations. 

C. By October 18, 2024, the parties shall file on the Court docket and on JAMS Access 

(in pdf format) their stipulation; their witness lists (identifying the subject of the witnesses 

testimony and its expected length, along with any objections); their exhibit lists (identifying any 

objections to exhibits and responses to objections, using a format the parties may obtain from the 

case manager); and their deposition designations (identifying the party designating the testimony 

and aby objections). 

D. By October 30, 2024, the parties shall file on the Court docket and on JAMS Access 

(in pdf format) pre-hearing memoranda. Plaintiffs and Intervenor Ivankovich shall file one 

consolidated memorandum, and defendant and the Third-Party LLCs shall file one consolidated 

memorandum. Each memorandum shall not exceed 15 pages double spaced. 

3. Witness Testimony. Without objection, third-party witnesses may testify by Zoom. 

Over the objection of plaintiffs and Intervenor Ivankovich, the defendant may testify by Zoom. 

4. Subpoenas. No additional subpoenas shall issue prior to the hearing. With respect to

subpoenas that have been served, by September 6, 2024, plaintiffs shall provide all parties and 

intervenors with copies and any responses (including a response that indicated there are no 

documents to produce). With respect to any subpoena responses received after September 6, 2024, 

plaintiffs shall provide copies to all parties and intervenors within two business days after receipt. 

 

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Next Hearing. The matter is set for a pre-hearing conference by Zoom on November 1, 

2024, at 9:00 a.m. CT. 

Entered:

___________________________________ 

HON. SIDNEY I. SCHENKIER (RET.)

Special Master

August 28, 2024 

 

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