IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JAMES FLETCHER JR.,

Plaintiff,

v.

JEROME BOGUCKI, ANTHONY 

NORADIN, RAYMOND SCHALK, 

ANTHONY WOJCIK, UNKNOWN CITY 

OF CHICAGO POLICE OFFICERS, and the 

CITY OF CHICAGO

Defendants.

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Case No. 20−cv−04768

 Judge Andrea Wood

Magistrate Judge Maria Valdez

 

JURY TRIAL DEMANDED

JOINT STATUS REPORT

Plaintiff, James Fletcher, and Defendants City of Chicago, Jerome Bogucki, Anthony 

Noradin, Raymond Schalk, and Anthony Wojcik, by their respective attorneys, and in 

accordance with the Court’s order on September 30, 2021, Dkt. 59, present this joint status 

report. 

I. Status of Discovery

The parties last joint status report was submitted to the court on April 30, 2021, Dkt. 53. 

Since that report was submitted, this court has adjudicated several pending matters before the 

Court, including Defendants’ joint motion to dismiss and strike certain claims, Dkt. 57, and the 

parties competing motions for entry of a confidentiality order, Dkt. 55-56. In response to those 

orders, Defendants have filed supplementary answers to Plaintiff’s complaint, see Dkt. 62-64, 

and have produced several rounds of discovery covered by the confidentiality order. 

However, there is still outstanding discovery in the case. For example, third-party 

subpoenas remain outstanding, or have only recently been answered. Furthermore, attorneys for 

Case: 1:20-cv-04768 Document #: 65 Filed: 12/17/21 Page 1 of 4 PageID #:676
the Plaintiff and the City have scheduled a meet and confer to discuss the status of document 

production in the case. Finally, parties have several depositions to complete, most of which 

depend on documents which have yet to be produced or only recently been received. 

Individual Defendants believe there will be at least two discovery disputes that will 

require the Court’s involvement. The first concerns withheld and/or redacted documents 

produced by the Cook County State’s Attorney’s Office in response to the Individual 

Defendants’ subpoena. The second concerns the production of Plaintiff’s phone calls recorded by 

the Illinois Department of Corrections. The Individual Defendants are attempting to narrow the 

scope of the disputes prior to bringing the appropriate motions before the Court. 

As such, parties believe that a discovery extension is necessary. The parties will meet and 

confer on the length of the extension and file a motion for extension of fact discovery shortly.

II. Settlement Efforts and Referral to Magistrate Judge

In accordance with the Court’s October 1, 2021 order, Plaintiff tendered a settlement 

offer on Defendants on November 1, 2021. Defendants’ responded with a counter-offer on 

December 13, 2021. Parties have not yet conferred on the competing demands. 

III. Matters in Need of a Telephonic Hearing 

None. 

Respectfully Submitted, 

By: /s/ Mariah Garcia 

Arthur Loevy

Jon Loevy

Anand Swaminathan

Mariah Garcia

LOEVY & LOEVY

311 N. Aberdeen, 3rd Floor

Chicago, IL 60607

(312) 243-5900

Jennifer Blagg

1333 W. Devon Ave., Suite 267

Chicago, IL 60660

(773) 859-008

Attorneys for Plaintiff

Case: 1:20-cv-04768 Document #: 65 Filed: 12/17/21 Page 2 of 4 PageID #:677
CELIA MEZA

Corporation Counsel of the City of Chicago

By: /s/ Paul A. Michalik

Special Assistant Corporation Counsel

Terrence M. Burns

Paul A. Michalik

Daniel M. Noland

Reiter Burns LLP

311 S. Wacker Dr., Suite 5200

Chicago, IL 60606

(312) 982-0090

Attorneys for Defendant City of Chicago

By: /s/ Brian Stefanich

Special Assistant Corporation Counsel

Andrew Hale

Barret Boudreaux

Brian Stefanich

Allyson West 

Hale & Monico

53 W. Jackson Blvd., Suite 330

Chicago, IL 60604

(312) 870-6908

Attorneys for the Individual Defendant

Case: 1:20-cv-04768 Document #: 65 Filed: 12/17/21 Page 3 of 4 PageID #:678
CERTIFICATE OF SERVICE

I hereby certify that on December 17, 2021 I caused the foregoing Joint Status Report

with the Clerk of the Court using the ECF system, which sent electronic notification of the filing 

on the same day to all counsel of record via the Court’s CM/ECF system.

/s/ Mariah Garcia

Attorney for Plaintiff

Case: 1:20-cv-04768 Document #: 65 Filed: 12/17/21 Page 4 of 4 PageID #:679