UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

CHRISTINE CRAWFORD, et al., 

Case No.: 1:20-cv-05132

Plaintiffs,

Hon. Judge Steven C. Seeger

v. 

MCDONALD’S USA, LLC, a Delaware

limited liability company, and 

MCDONALD’S CORPORATION, a

Delaware corporation, 

Defendants.

PLAINTIFFS’ JOINT STATEMENT PURSUANT

TO NOVEMBER 15, 2022, MINUTE ENTRY

Plaintiffs’ counsel of record, The Ferraro Law Firm, P.A. (“Ferraro Law”), together with 

proposed substitute counsel for the Crawford Plaintiffs, Loevy & Loevy (the “Loevy Firm”), 

conferred in good faith pursuant to the November 15, 2022, Minute Entry [Dkt. No. 74], and hereby 

respectfully submit a Joint Statement addressing the Court’s questions as follows:

I. Plaintiffs and Plaintiffs’ Counsel

Plaintiffs are a group of seventy-seven (77) Black McDonald’s franchisees who owned and 

operated McDonald’s restaurants in the United States and filed suit for violations of their civil rights 

in denying them equal franchise opportunities. Of these seventy-seven (77) original Plaintiffs, Ferraro 

Law currently represents twenty-nine (29) named Plaintiffs and the Loevy Firm represents forty-eight

(48) named Plaintiffs,1 pursuant to the Client Directives attached as Exhibit “A” hereto. To avoid 

1 In addition to the thirty-nine (39) Plaintiffs named in the Loevy Firm’s November 11, 2022, Motion 

for Substitution of Counsel [Dkt. No. 71], the Loevy Firm sent copies of Client Directives for 

Plaintiffs Eleanor Clark, Mitchell McGuire, Lois McGuire, Ronnie Thornton, and Gordon Thornton

to Ferraro Law on November 17, 2022, and for Plaintiffs Karen and Serge Tancrede, William 

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undue prejudice and/or delay, Ferraro Law authorized the release of the Crawford Plaintiffs’ client 

files to the Loevy Firm, subject to charging liens that Ferraro Law intends to file for each.

While Plaintiffs suffered a similar pattern and practice of racial discrimination and filed a 

single complaint against McDonald’s for purposes of judicial economy and efficiency, Plaintiffs have 

individual injuries and claims against McDonald’s, as well as individual engagement agreements with 

Ferraro Law and the Loevy Firm. As such, Plaintiffs do not seek to represent a putative class of former 

McDonald’s franchisees (as opposed to the proposed class action in Byrd, et al. v. McDonald’s USA, 

LLC, et al., Case No. 1:20-cv-06447 (N.D. Ill), distinguished by the Court in Washington, et al. v. 

McDonald’s USA, LLC, et al., Case No.: 4:21-cv-00367 (N.D. Ohio)), nor is there any issue here 

related to class counsel appointment and/or designation.

II. Joint Proposal

Ferraro Law and the Loevy Firm met and conferred in good faith on November 21, 29, and 

30, 2022, and agree that two, separately represented groups of Plaintiffs should not remain in one 

case with two sets of pleadings and two separate scheduling tracks. As such, Plaintiffs jointly propose 

that the Crawford Plaintiffs’ complaint, once filed, be severed, and assigned a separate case number. 

To avoid duplicative costs and wasted time, Plaintiffs further propose consolidation for purposes of 

discovery.

III. Settlement and Referral to Magistrate for Settlement Conference

Ferraro Law and counsel for McDonald’s engaged in renewed settlement discussions in good 

faith pursuant to the Court’s Minute Entry on September 28, 2022 [Dkt. No. 63], but did not jointly 

agree on a referral to the Magistrate for a Settlement Conference. Plaintiffs are willing to participate 

Washington, and Robert Bonner on the eve of this filing. Those Plaintiffs identified in the attached 

Client Directives are collectively referred to herein as the “Crawford Plaintiffs.” 

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in a Settlement Conference before the Magistrate Judge, subject to McDonald’s response to this Joint 

Statement due to be filed on or before December 2, 2022. 

IV. Other

If the Court determines that a status hearing and/or case management conference would be 

beneficial, Ferraro Law and the Loevy Firm are willing to participate and appear.

Dated: November 30, 2022 Respectfully submitted,

/s/ James L. Ferraro

James L. Ferraro, Esq.

Daryl D. Parks, Esq.

Natalia Salas, Esq.

THE FERRARO LAW FIRM, P.A.

Brickell World Plaza 

600 Brickell Avenue, 38th Floor 

Miami, Florida 33131

Telephone: (305) 375-0111

Facsimile: (305) 379-6222

jferraro@ferrarolaw.com

dparks@ferrarolaw.com

nsalas@ferrarolaw.com

William R. Fahey, Esq.

COONEY & CONWAY, PC

120 N. LaSalle Street, 30th Floor

Chicago, IL 60602

Telephone: (312) 236-6166

bfahey@cooneyconway.com

Counsel for Plaintiffs

s/ Jon Loevy

Jon Loevy 

Roshna Bala Keen 

Dan Twetten 

Steve Art 

Quinn Rallins 

Annie Prossnitz 

Loevy & Loevy 

311 N. Aberdeen, Third Floor 

Chicago, IL 60607 

(312) 243-5900

Counsel for Crawford Plaintiffs

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