A bit of an update.
Back on Mar. 2nd, the defendant, City of Chicago, motioned to submit their Statement of Facts and exhibits (doc #159). Then on Mar. 7th, the Clerk enters the following:
MINUTE entry before Honorable Edmond E. Chang: The Clerk's Office informed the Court that Defendant filed only a paper version of its summary judgment filings, including the exhibits, and did not file electronically. Although the Court understands the potential time and expense of electronically scanning the box-full of exhibits, Defendant (like every other litigant) must electronically file all of its filings (even sealed or partially-sealed documents are filed electronically). And feeding the pages into a scanner can be accomplished without extraordinary effort. The electronic filing shall be completed on or before 03/14/12. Mailed notice (slb, ) (Entered: 03/07/2012)
Did you get that? The city dumped an entire box of documents off to the court! the Judge said, No, you must file electronically, like everyone else. and sent it all back!!
Then on Mar. 12th, the city sent in the data: Doc #164, their Statement of Material Facts; doc #165, 7 attachments with 25 exhibits; doc #166, 9 attachments with exhibits 26 thru 38; doc #167, 1 attachment with exhibits 39 and 40; doc #168, thru doc #170 with a total of 90 exhibits.
If you can't beat the opposition on the merits, smother them (and the court) with paperwork!!