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IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

MICHAEL CONWAY,

 Plaintiff, 

 v.

CITY OF CHICAGO, et al.,

 Defendants.

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Case Number: 1:20-cv-04966

Judge Sara L. Ellis

Magistrate Judge Beth W. Jantz

PLAINTIFF MICHAEL CONWAY’S MOTION FOR LEAVE TO FILE A REPLY

TO HIS MOTION TO COMPEL THE PRODUCTION OF CERTAIN DOCUMENTS,

RECORDINGS, AND DATA, AND TO STRIKE FROM THE DOCKET, AS 

INADVERTENTLY FILED, HIS EARLIER REPLY TO THE SAME MOTION 

(TOGETHER WITH EXHIBITS) (DKT. # 166)

Plaintiff Conway respectfully moves for leave to submit his Reply to Plaintiff’s Motion to 

Compel The Production Of Certain Documents, Recordings, And Data, dated November 25, 2022 (Dkt. 

#139) (Motion), attached as Exhibit 1 to this motion, and to strike from the docket, as 

inadvertently filed, his earlier Reply to the same motion (together with exhibits) (Dkt. # 166).

Plaintiff filed a 3-page supplement to his motion on December 9. 2009 (Dkt. # 145), in 

compliance with this Court’s order. (Minute Entry, dated December 5, 2022, Dkt. #144). The 

Defendant City filed its opposition on December 25, 2022 (Dkt. # 146). At that time, the motion 

was fully briefed, as the Court had ordered that no reply was necessary (Minute Entry, December 

5, 2022, Dkt. # 144). The Court has not yet ruled on the motion. Plaintiff therefore seeks leave to 

submit his reply, at this time, to alert the Court to additional information it has become aware of 

in the interim and to clarify his position in light of Defendant City’s opposition.

Case: 1:20-cv-04966 Document #: 167 Filed: 03/12/23 Page 1 of 3 PageID #:2260
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Regretfully, Plaintiff inadvertently filed his Reply (Dkt. # 166) prior to this motion for 

leave, together with an incomplete exhibit earlier today. Plaintiff will consult with the clerk of the 

Court on Monday morning how best to correct this error.

For all these reasons, Plaintiff respectfully requests that the Court grant this motion for 

leave to file his Reply, attached as Exhibit 1 to this motion, and instructs the clerk to strike from 

the docket, as inadvertently filed, his early Reply to the same motion (together with exhibits) (Dkt. 

# 166).

Date: March 12, 2023 Respectfully submitted,

/s/Michael Halberstam

Subodh Chandra (Ohio 0069233)

Donald Screen (Ohio 0044070)

Michael Halberstam (Ohio 0098269)

THE CHANDRA LAW FIRM LLC

The Chandra Law Building

1265 W. 6th St., Suite 400

Cleveland, Ohio 44113

216.578.1700 Phone / 216.578.1800 Fax

Subodh.Chandra@ChandraLaw.com

Donald.Screen@ChandraLaw.com

Michael.Halberstam@ChandraLaw.com

/s/Jamie S. Franklin

Jamie S. Franklin

Assistant Clinical Professor of Law 

ARDC No. 6242916

Employment and Civil Litigation Clinic

Chicago-Kent College of Law

565 West Adams Street, Suite 600

Chicago, IL 60661

312.906.5048 Phone / 312.906.5299 Fax

jfranklin5@kentlaw.iit.edu

Attorneys for Plaintiff Michael Conway

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CERTIFICATE OF SERVICE

I certify that on March 12, 2023, my office serveda copy of this document on all counsel of 

record via ECF and by email.

/s/Michael Halberstam

One of the attorneys for Plaintiff Michael Conway

Case: 1:20-cv-04966 Document #: 167 Filed: 03/12/23 Page 3 of 3 PageID #:2262