4874-4153-5378.v2.34147.78623

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ZHU ZHAI HOLDINGS LIMITED and 

PETER PUI TAK LEE

Plaintiffs,

v. 

STEVEN IVANKOVICH, 

Defendant.

Case No. 1:20-cv-4985 

Hon. Sharon Johnson Coleman 

PARTIES’ AMENDED JOINT STATUS REPORT 

 Consistent with the Court’s October 27, 2023, Order (Dkt. 282), Plaintiffs Peter Lee 

(“Lee”) and Zhu Zhai Holdings Limited (“ZZH”) (collectively, “Plaintiffs”), Defendant Steven 

Ivankovich (“Defendant”), and third parties Pilgrim Warwick LLC, Pilgrim Coulter LLC, Pilgrim 

Windtree LLC, Pilgrim Caribbean Isle LLC, Pilgrim Forest Park LLC (collectively, “Pilgrim 

LLCs”) and other limited liability companies (together with the Pilgrim LLCs, collectively, 

“LLCs”) hereby submit this status report: 

 This Amended Joint Status Report is filed to amend and supersede the Joint Status Report 

filed on November 20, 2023 as Dkt. 283 filed by ZZH. 

Preliminary Statement:

On August 18, 2023, this Court entered a minute order that set forth a revised discovery 

schedule. See Dkt. 277. The dates for discovery included that Plaintiffs were to amend their 

discovery request by September 1, 2023 and objections were required to be filed by October 6, 

2023. The LLCs were required to respond to discovery not later than October 13, 2023. 

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On September 5, 2023, Plaintiffs issued for the first time discovery requests on each of the 

Pilgrim LLCs, consisting of Rule 33 and Rule 34 interrogatories and document requests (the 

Pilgrim LLCs consented to an extension from September 1 to September 5, 2023 to issue the same). 

On or about October 13, 2023, the Pilgrim LLCs answered Plaintiff’s discovery requests,

notwithstanding that the discovery requests were substantively and otherwise styled as Rule 33 

and Rule 34 party requests made on out-of-state, nonparty limited liability companies. See Dkt. 

280 and 281 Certificates of Service. The parties have engaged in good faith settlement discussions 

but through the date of the filing this status report there has been no agreement upon settlement 

terms. 

Steven Ivankovich Statement:

Status of discovery from Mr. Ivankovich. The Plaintiffs issued and served interrogatories 

upon Mr. Ivankovich, to which he responded. There is no pending discovery issue concerning the 

interrogatory answers. 

The Plaintiffs previously served document requests upon Mr. Ivankovich that requested 

information of the LLCs. Mr. Ivankovich produced extensive responsive documents and 

completed written responses to the document request. The Plaintiff objected to the document 

responses and on August 16, 2023, filed a motion to compel after a meet and confer telephone 

conversation. See Dkt. 276. 

On August 18, 2023, this Court addressed the motion to compel and required the Plaintiffs 

to amend their discovery. To complete the record, Mr. Ivankovich’s counsel believes the Court’s 

August 18, 2023 Order mooted the Plaintiff’s Motion to Compel. Defendant filed a response to 

Plaintiff’s Motion to Compel on August 28, 2023. See Dkt. 278. 

Mr. Ivankovich does not believe that there is any outstanding discovery matter, and 

therefore nothing to be argued at the oral argument scheduled for January 9, 2024. 

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LLCs’ Statement:

The LLCs have responded to the discovery propounded by the Plaintiffs. There has been 

no objection filed. Counsel for the Plaintiffs and counsel for the LLCs, have met and conferred to 

produce any additional relevant information or documents requested by the Plaintiffs as have been 

requested by Plaintiffs. Although the LLCs believe all relevant information and documents have 

been produced, including evidence of any intercompany transfers and payments, an inquiry from 

Plaintiffs’ counsel concerning the LLCs’ Chase operating accounts remains an open item

according to the Plaintiff. The LLCs believe the requested Chase operating account statements 

have been produced. 

The Plaintiffs have requested the deposition of a representative of the LLCs in addition to 

the written discovery. The LLCs designated either Mark Brown, asset manager, and/or Shanna 

Willis, Atlas Homes’ vice president to be deposed. On November 16, 2023, Plaintiffs requested 

that Mark Brown appear for a deposition. The LLCs and Plaintiffs expect to agree on a new 

deposition date for a representative of the LLCs to be deposed, prior to the January 9, 2004 

continued hearing date. Of note, Mr. Brown planned to attend the hearing scheduled for October 

30, 2023 in person and indeed flew to Chicago to attend the same, which was subsequently reset 

on the Court’s minute entry. See Dkt. 282. Mr. Brown, the LLCs’ counsel, and counsel for the 

Plaintiffs had an in-person meeting in Chicago to informally discuss matters related to the case

and the possibility of settlement. 

Mark Brown, with authority to settle although not obligated to engage in settlement 

negotiations, further met in person with Plaintiff Peter Pui Tak Lee in Chicago. They conducted in

person settlement negotiations. 

The LLCs do not believe there is any outstanding discovery issue to be argued in the oral 

argument scheduled for January 9, 2024. It is respectfully suggested that in the event Plaintiffs

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allege that a discovery dispute exists, that the LLCs be permitted to call witnesses to show that all 

outstanding discovery has been produced. 

Further, the Pilgrim LLCs request that the continued freeze of their funds held at Walker 

Dunlop be lifted and Walker Dunlop ordered to release the funds to the Pilgrim LLCs in light of 

the good faith responses to Plaintiffs’ discovery requests, lack of showing that the Pilgrim LLCs 

hold assets of the judgment debtor, and continued (now over a yearlong) freeze and resulting losses 

incurred by the Pilgrim LLCs as a result of the continued freeze as addressed in various filings the 

Pilgrim LLCs to date (e.g., Dkts. 205, 233, 244, 266, and 271). The Pilgrim LLCs further request 

that to the extent the Court does not lift the freeze prior to the January 9, 2024 hearing date, that 

the Pilgrim LLCs be allowed to produce a witness(es) to testify regarding the ownership of their 

funds held at Walker Dunlop. 

Statement of Plaintiffs:

Plaintiffs disagree there are no outstanding discovery issues. Ivankovich testified that he 

transferred over 50M to entities that are currently subject to citations. He stated that he transferred 

the money to the LLCs. But neither Ivankovich or the LLCs have provided statements that 

evidence such transfers. Plaintiffs have noticed depositions of the corporate representatives of 

these entities. They are expected to be schedule to go in January. Plaintiffs request this discovery 

be completed and the hearing on the pending motion to compel be continued to February. Plaintiffs 

request the hold on the Pilgrim LLCs accounts at Walker Dunlop remain in place until further 

order of Court. 

Respectfully submitted,

/s/ Amir Tahmassebi

Amir Tahmassebi, Bar #6287787 

Konicek & Dillon, P.C. 

70 W. Madison, Suite 2060 

Chicago, IL 60602 

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(312) 328-9166 (Direct) 

(630) 262-9659 (Fax) 

amir@konicekdillonlaw.com 

Steven Lammers, Bar #6294413 

Mandel Rauch & Lammers, P.C. 

704 Adams Street, Suite F 

Carmel, IN 46032 

(317) 581-7440 (Direct) 

(317) 848-6197 (Fax) 

slammers@mhmrlaw.com

Respectfully Submitted:

 By: /s Jason Wandner__________________ 

 Jason Wandner, Fla Bar # 0114960

 100 N. Biscayne Boulevard 

 Suite 1607 

 Miami, Florida 33132 

 Email: jason@wandnerlaw.com

 Admitted Pro Hac Vice Counsel for Defendant 

 Telephone (305) 868-1655. Fax (305) 503-7480 

 ______________________________________ 

 Stuart Office:

Treasure Coast-Stuart Office

 412 SW Camden Avenue 

 Stuart, Florida 34994 

 Telephone (772) 324- 9255 

Third Party LLCs

 /s/ C. Cy Porras 

 By: One of Its Attorneys 

Michael Debre (IL Bar No. 6296197) 

C. Cy Porras (IL Bar No. 6324512) 

CHUHAK & TECSON, P.C.

120 S. Riverside Plaza, Suite 1700 

Chicago, IL 60606 

(312) 844-4313 

mdebre@chuhak.com

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