Jiang v. THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report [66], which reports that the parties have resolved several discovery disputes previously raised in defendants' motion to compel, the parties continue to confer about additional items of written discovery, and defendant anticipates engaging in motion practice relating to a subpoena served on a nonparty outside the Northern District of Illinois. Further joint status report on the same topics as the instant report, as well as confirmation that fact discovery is complete, due on 09/14/2026. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) if they would like the Court's assistance with settlement.

MINUTE entry before the Honorable Heather K. McShain: Pending before the Court are the briefing on defendants' motion to compel [51] and the parties' joint status report [59]. In the exercise of its extremely broad discretion to control discovery, see Chicago Reg'l Council of Carpenters Pension Fund v. Celtic Floor Covering, Inc., 316 F. Supp. 3d 1044, 1046 (N.D. Ill. 2018), the Court denies defendants' motion to compel [51] without prejudice for failure to exhaust their meet-and-confer obligations as required by Local Rule 37.2 and the undersigned's standing order on discovery motions. After conducting an initial review of the briefing, in which plaintiff raised significant questions about defendants' compliance with Local Rule 37.2, and ruling on the parties' joint motion to extend fact discovery, which reported that both sides expected to make supplemental discovery productions in light of recent deposition testimony, the Court ordered the parties to further meet-and-confer in person or by videoconference about the issues raised in defendants' motion and file a joint status report by 05/13/2026 [57]. Plaintiff represents, without contradiction from defendants, that defendants made no effort to meet-and-confer until the afternoon of May 13, at which time plaintiff's counsel was unavailable to confer. The Court views defendants' belated and half-hearted effort to comply with the Court's minute order of 04/29/2026 as compelling evidence underscoring the Court's initial impression that defendants did not exhaust their meet-and-confer obligations before filing the motion to compel. The Court also notes that, according to plaintiff's input into the joint status report, plaintiff made at least four supplemental document productions and served at least two supplements to its responses to defendants' interrogatories after defendant filed the pending motion. While defendants argue in the joint status report that these productions and supplements do not cure the deficiencies that precipitated the motion to compel, defendants had an obligation to raise that contention with plaintiff either after the productions were made or, at a minimum, in the Court-ordered meet-and-confer session. Raising that argument for the first time in a joint status report after failing to participate in a Court-ordered meet-and-confer session was not sufficient to comply with the 04/29/2026 order or to exhaust meet-and-confer obligations. For these reasons, defendants' motion to compel is denied without prejudice to refiling, provided that any renewed motion to compel must be accompanied by a detailed Rule 37.2 certificate (1) explaining that defendants have met in person or by videoconference with plaintiff on or after the date of this order about any discovery issue raised in the motion and (2) establishing that the parties were unable to reach an agreement despite their good-faith efforts. Further joint status report due on 07/13/2026 to update the Court on: (a) the progress of discovery; (b) the status of settlement discussions, if any; and (c) any other issues the parties wish to raise with the Court. The parties may contact chambers at any time (by email to Chambers_McShain@ilnd.uscourts.gov) if they would like the Court's assistance with settlement.

MINUTE entry before the Honorable Heather K. McShain: Defendants' motion for leave to exceed page limit [50] is granted. Defendants' motion to compel [51] is entered and continued. Plaintiff's response, which may not exceed 30 pages and need not include a table of contents or table of authorities, is due by 04/09/2026. Plaintiff's reply is due by 04/20/2026 and may not exceed 15 pages. Once the Court has reviewed the briefs, it will decide whether it can rule on the briefs or whether a motion hearing is warranted. On review of the parties' joint status report [48], the Court orders that all depositions must be completed by 04/30/2026. A joint status report is due on 05/01/2026 to update the Court on: (a) the progress of discovery; (b) the status of settlement discussions, if any; and (c) any other issues the parties wish to raise with the Court.

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed the parties' joint status report on discovery and settlement. The referral to Magistrate Judge McShain is expanded to include discovery supervision and scheduling, including the authority to set, adjust, and extend all discovery deadlines. The 3/23/26 tracking status hearing is stricken and reset to 5/22/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: The parties' joint motion for extension of time to complete discovery [43] is granted. All fact discovery shall be completed by 4/30/26. By 3/10/26, the parties shall file a joint status report setting forth what additional discovery has been completed, what discovery remains, whether any discovery disputes require the Court's attention, and the status of any settlement negotiations. The 2/23/26 tracking status hearing is stricken and re-set to 3/23/26 at 9:00 a.m. (to track the case only, no appearance is required).Mailed notice

MINUTE entry before the Honorable Heather K. McShain: The Court has reviewed the parties' joint status report [44], which was erroneously presented to Magistrate Judge McShain. Because the referral in this case is limited to settlement matters [24], the parties should present all discovery-related matters to the District Judge. Mailed notice.

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed the parties' joint status report [40]. The parties are proceeding with discovery in advance of the 2/3/26 fact discovery deadline and are reminded to fully exhaust their meet and confer efforts as required by Local Rule 37.2 before filing any discovery motions with the Court. By 1/14/26, the parties shall file a joint status report setting forth what additional discovery has been completed, what discovery remains, whether any discovery disputes require the Court's attention, and the status of any settlement negotiations. The 12/29/25 tracking status hearing is stricken and re-set to 2/23/26 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed the parties' joint status report [38], which indicates that the parties are proceeding with fact discovery. The parties are reminded of their duty to meet and confer under Local Rule 37.2 before filing any discovery motions with the Court. Defendant's unopposed request for an extension of the fact discovery deadline is granted. All fact discovery shall be completed by 2/3/26. By 12/2/25, the parties shall file a joint status report setting forth what additional discovery has been completed, what discovery remains, whether any discovery disputes require the Court's attention, and the status of any settlement negotiations. The 11/10/25 tracking status hearing is stricken and re-set to 12/29/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice

MINUTE entry before the Honorable Heather K. McShain: Off-the-record telephone conference held on 04/29/2025, on settlement. The Court and the parties agree that settlement negotiations have been exhausted and the case has not settled. The Court will leave the settlement referral open and the parties are directed to contact Judge McShain's chambers at any time should they seek additional Court assistance with settlement. Mailed notice.

MINUTE entry before the Honorable Heather K. McShain: Telephone conference held on 04/21/2025, on settlement. The parties are actively engaged in negotiations, and at this time they do not request a settlement conference. An off-the-record telephone conference is set for 04/29/2025 at 10:00 a.m., to further update the Court on the status of the parties' settlement negotiations. Counsel should utilize the same dial-in information [25]. Mailed notice

MINUTE entry before the Honorable Heather K. McShain: This case has been referred to Magistrate Judge McShain for a settlement conference [24]. A telephone conference with the Court is scheduled for 04/17/2025 at 10:00 a.m. to discuss the parties' interest in settlement and, if appropriate, set a schedule for the exchange of settlement proposals and a date for the settlement conference. Counsel primarily responsible for representing the parties must participate in this conference call, and both sides should come prepared to discuss the availability of counsel and decisionmakers in May, June, and July. The Court will also address logistics for the settlement conference itself, which will take place remotely. In advance of the telephone conference, counsel are directed to review Magistrate Judge McShain's Standing Order for Settlement Conferences (available on the Court's website at www.ilnd.uscourts.gov by selecting the link for Magistrate Judge McShain and then the link for "Settlement Conferences"). To participate in the telephonic status hearing, the dial-in number is 650-479-3207, access code 1808 98 4405#. Press # to bypass the Attendee ID number. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice.

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Heather K. McShain for the purpose of holding proceedings related to: settlement conference. Mailed notice.

MINUTE entry before the Honorable Jeffrey I Cummings: The Court has reviewed the parties' joint status report [22] and adopts the parties' proposed schedule in part as follows. Parties shall exchange Rule 26(a)(1) disclosures by 4/18/25 and shall issue initial written discovery requests by 5/2/25. All fact discovery shall be completed by 11/4/25. The Court will set expert discovery deadlines at a later date. Motions for leave to amend pleadings shall be filed, as appropriate, no later than 10/1/25. Any motions to modify this schedule must be supported by good cause and the party seeking a modification is instructed to meet and confer to attempt to reach agreement prior to filing a motion for a modification. By agreement of the parties, this case is referred to the assigned Magistrate Judge for a settlement conference. By 5/29/25, the parties shall file a joint status report setting forth what discovery has been completed, what discovery remains, and whether any discovery disputes require the Court's attention. The 4/18/25 tracking status hearing is stricken and re-set to 6/9/25 at 9:00 a.m. (to track the case only, no appearance is required). Mailed notice