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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DEMETRIUS JOHNSON, 

 

Plaintiff, 

v.

REYNALDO GUEVARA, et al., 

Defendants. 

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Case No. 20-cv-4156 

 Judge Sara L. Ellis

Magistrate Judge Heather K. McShain

JURY TRIAL DEMANDED

 

PLAINTIFF’S OPPOSED MOTION FOR LEAVE TO FILE EXCESS PAGES

Plaintiff DEMETRIUS JOHNSON, by and through his attorneys, hereby moves this Court 

to grant him leave to file his Consolidated Response in Opposition to Defendants’ Motions 

Regarding Summary Judgment in excess of fifteen (15) pages. In support, Plaintiff states: 

1. On January 22, 2024, Defendants Darryl Daley and Geri Lynn Yanow, as Special 

Representative for Ernest Halverson, William Erickson, and John Healy, filed an Opposed Motion 

for Additional Time to File Their Motion on Disputes in the Joint Statement of Facts and Summary 

Judgment, Dkt. 290, and accompanying exhibits. 

2. On January 23, 2024, Defendant City of Chicago filed its Opposed Motion for 

Leave to File Excess Pages, Dkt. 292, along with an eighteen-page Motion to Deem Facts Set 

Forth in the City’s Proposed Joint Statement of Facts as Admitted, Dkt. 292-1, and accompanying 

exhibits. 

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3. In the City’s Motion, it stated that “significant issues arose while the parties where 

[sic] working on the Joint Statement of Material Facts,” and that, given the “importance” of the 

various issues that needed to be addressed “and the limited time the City was left to draft the 

Motion,” it could not comply with the fifteen-page limit. Dkt. 292 at 1. 

4. Although Plaintiff vehemently disagrees with Defendants’ motions, they do not 

oppose Defendants’ motion for leave to exceed fifteen pages. 

5. In response to both Motions filed yesterday, Plaintiff seeks to file a consolidated 

Response to the Defendants’ motions. And to address the many issues raised in Defendants’ 

motions, Plaintiff’s Consolidated Response also requires more than fifteen pages. The Response 

is attached here as Exhibit 1. 

6. In an effort to get this issue briefed with as much time as possible for the Court to 

consider the parties’ dispute, Plaintiff has worked hard to get his response on file today, one day 

after Defendants filed their motions. Thus, Plaintiff too has not had time to confer with the 

Defendants on this Motion for leave to exceed fifteen pages, and is filing the motion as opposed. 

WHEREFORE, for the foregoing reasons, Plaintiff respectfully requests this Court grant 

his motion for leave to file his Consolidated Response in Opposition to Defendants’ Motions 

Regarding Summary Judgment in excess of 15 pages, and grant such further relief as this Court

deems just and equitable. 

RESPECTFULLY SUBMITTED,

/s/ Alyssa Martinez 

One of Plaintiff’s Attorneys 

Anand Swaminathan 

Steven Art

Rachel Brady

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Sean Starr

Alyssa Martinez

LOEVY + LOEVY

311 N. Aberdeen 

Chicago, Illinois 60607 

(312) 243-5900 

alyssa@loevy.com

CERTIFICATE OF SERVICE

I, Alyssa Martinez, an attorney, certify that on January 23, 2024, I filed the foregoing 

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

/s/ Alyssa Martinez 

One of Plaintiff’s Attorneys

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