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Mark C.

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  1. Before we go off into Discovery for the 2nd time, Plaintiffs were allowed to submit an Amended Complaint (which they did, on 10/15) and Defendants were given opportunity to respond to the Amended Complaint...which they now have. http://www.archive.org/download/gov.uscourts.ilnd.246475/gov.uscourts.ilnd.246475.132.0.pdf Chicago continues there assertion that the case is now "moot" and they don't hide it in this response. I will need to take a look at all of the original and modified Chicago codes referenced to make sense of it all. Maybe this weekend I'll come up with a list of old/current/voided and see who's telling the truth whether the points of the Complaint are indeed Moot. SAF/Gura have obviously opted to provide Judge Kendall with some additional rope...
  2. Today Chicago filed: On time, at that...their reply in support of their OBJECTIONS to the PI. http://www.archive.org/download/gov.uscourts.ilnd.246475/gov.uscourts.ilnd.246475.129.0.pdf Keep in mind we've been going back & forth for a month over their OBJECTION to the PI. Recall that on 9/28 the Judge in denying Chicago's MTD over the case being Moot, ordered: On 9/30, instead of a plan for the PI, they OBJECTED to the PI. Today's filing is 8 pages of reliving the past....literally. Today's 8 pages (roughly 15 minutes I'll never get back) brings up their MTD points of the case being...are you ready?...Moot due to the updated laws on ranges. They argue that the Plaintiffs are "blowing past procedural" norms, which in a way is arguing against the PI without bringing up "moot", but still fails in the face of the Judge's 9/28 orders. These exact arguments have already failed in their MTD. With the MTD denied, they bring up the same losing points in fulfilling the Judge's order to address the PI. Doesn't that sound like rearguing the now moot "moot" argument? They've blown it. I'm smelling game/set/match on this one.
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