[Spats McGee]

I think you are missing something. Yes, Chicago has an extensive permitting process. So? According to the 2nd Amended Complaint, none of the eleven ranges in Chicago are open to the public. The City admits the ranges that it runs, admits the ranges that Brinks Security runs, and denies the rest. If the Plaintiff is correct, there are no public or private ranges at which she could have signed in. Even if there were some privately-owned ranged where she could have signed in, I'd be troubled by the prospect of the city rummaging through the records of every privately-owned range to see if she had ever signed in.

On top of the A4 implications of such a move, which are large, there's the problem of cost. That's the expensive way to find out if she's a resident. The cheap way is to just take her deposition and ask her where she lives. At that point, there's sworn testimony on the record about her residency and we can all move on.

The mere fact that something is "likely," as seems to be the case with Ezell's residence and citizenship, is not sufficient to admit something on your client's behalf. To do so could be malpractice, especially if it later turns out that the particular fact which you admitted could have, if denied, gotten the whole case against your client dismissed.