2025-0147 · Court ref 2025-L-004412
Delgado v. Northline Freight Systems, Inc. — motor vehicle collision
OpenPersonal Injury·Mr. Ramon Delgado·Opened Apr 02, 2026
Limitation expires in 44 days — Nov 03, 2026
Issue a protective claim form if settlement is not agreed. Do not rely on the other side agreeing a standstill.
Background
Personal injury action arising from a rear-end collision on I-90 near the Cumberland exit. Plaintiff sustained a cervical strain and aggravation of pre-existing lumbar disc disease. Liability largely conceded in discovery; damages contested.
File note
Note the positional conflict: Northline was a firm client in 2023 on an unrelated vendor dispute. Screened under Rule 1.9, written waiver on file. Defense has raised comparative fault at 20%. Not accepted.
Key dates
4 recorded| Date | Event | Type | Due |
|---|---|---|---|
| Sep 28, 2026 | Deposition of defendant driver | Hearing | in 8 days |
| Oct 16, 2026 | Fact discovery cutoff | Filing deadline | in 4 weeks |
| Nov 03, 2026 | Statute of limitations expires (735 ILCS 5/13-202) Two years from date of occurrence. Complaint is filed, but any amendment adding a party must relate back or be filed before this date. | Limitation | in 6 weeks |
| Nov 06, 2026 | Rule 213(f)(3) expert disclosures due | Filing deadline | in 7 weeks |
Tasks
4 open · 0 completed| Task | Assigned | Due | Priority | Status | |
|---|---|---|---|---|---|
Follow up with Hartley Vance on settlement demand Third follow-up. Escalate to Ms. Sloane directly. | DR | 9 days overdue | High | Not started | |
Calendar protective filing ahead of limitations date Statute runs in under 60 days. Any amendment adding a party must be filed before then. | EW | in 3 days | High | Not started | |
Prepare client for deposition | DR | in 6 days | High | Not started | |
Draft Rule 213(f)(3) expert disclosures | DR | in 3 weeks | High | Not started |
Time recorded
8.9 hrs total · 8.6 hrs billable · $2,773.50| Date | Timekeeper | Narrative | Activity | Units | Value | Billed |
|---|---|---|---|---|---|---|
| Sep 07, 2026 | AK | Drafting Rule 213(f) expert disclosures | Research | 2 · 0.2 hrs | $59.00 | WIP |
| Sep 07, 2026 | TB | Reviewing IME report and preparing cross-examination outline | Research | 3 · 0.3 hrs | $49.50 | WIP |
| Sep 03, 2026 | DR | Drafting Rule 213(f) expert disclosures | Conference | 10 · 1.0 hr | $340.00 | WIP |
| Aug 13, 2026 | DR | Reviewing medical records and billing from treating providers | Telephone | 3 · 0.3 hrs | — | Non-billable |
| Aug 12, 2026 | DR | Drafting Rule 213(f) expert disclosures | Court appearance | 12 · 1.2 hrs | $408.00 | WIP |
| Aug 12, 2026 | DR | Evaluating settlement demand and advising client in writing | Deposition | 6 · 0.6 hrs | $204.00 | WIP |
| Jul 22, 2026 | DR | Telephone conference with client regarding course of treatment | Drafting | 12 · 1.2 hrs | $408.00 | WIP |
| Jul 09, 2026 | DR | Correspondence to defense counsel enclosing medical documentation | Drafting | 12 · 1.2 hrs | $408.00 | WIP |
| Jul 09, 2026 | AK | Drafting Rule 213(f) expert disclosures | Drafting | 10 · 1.0 hr | $295.00 | WIP |
| Jul 06, 2026 | DR | Reviewing IME report and preparing cross-examination outline | Deposition | 15 · 1.5 hrs | $510.00 | WIP |
| Jun 29, 2026 | TB | Reviewing medical records and billing from treating providers | Correspondence out | 2 · 0.2 hrs | $33.00 | WIP |
| Jun 23, 2026 | AK | Preparing plaintiff for deposition | Correspondence in | 2 · 0.2 hrs | $59.00 | WIP |
Advanced costs
Money paid out on the client behalf, billed at cost| Date | Description | Paid out | Amount | Billed |
|---|---|---|---|---|
| Sep 08, 2026 | Circuit court filing fee | Paid | $388.00 | Unbilled |
| Aug 21, 2026 | Deposition transcript — Meridian Court Reporting | Paid | $1,420.00 | Unbilled |
| Jul 27, 2026 | Accident reconstruction — Alvarez Forensic Engineering | Paid | $4,750.00 | Unbilled |
| Jun 22, 2026 | Independent medical examination — Dr. A. Petrosyan | Paid | $3,200.00 | Unbilled |
| May 13, 2026 | Medical records retrieval — Northwestern Memorial | Paid | $185.00 | Unbilled |
Documents
8 on file| Document | Type | Ver. | Filed by | Filed | Size | |
|---|---|---|---|---|---|---|
| Defendant answer and affirmative defenses.pdf | Pleading | v1 | DR | Sep 09, 2026 | 3.8 MB | Download |
| Settlement demand package (draft 3).docx | Correspondence out | v2 | DR | Aug 28, 2026 | 1.8 MB | Download |
| Complaint at law and jury demand.pdf | Pleading | v1 | DR | Aug 13, 2026 | 2.9 MB | Download |
| Rule 213 interrogatories to defendant.docx | Discovery | v1 | DR | Aug 10, 2026 | 4.1 MB | Download |
| Memo to file — client conference.docx | Memo to file | v1 | DR | Aug 03, 2026 | 3.9 MB | Download |
| Engagement letter and contingency fee agreement.pdf | Engagement letter | v1 | DR | Jul 05, 2026 | 556 KB | Download |
| IME report — Dr. A. Petrosyan.pdf | Evidence | v1 | DR | Jun 26, 2026 | 1.6 MB | Download |
| Medical records — Northwestern Memorial.pdf | Evidence | v1 | DR | May 27, 2026 | 368 KB | Download |
Bills
| Bill | Issued | Due | Fees | Disb. | Total | Outstanding | Status |
|---|---|---|---|---|---|---|---|
| INV-2025-0517 | Sep 04, 2026 | Oct 04, 2026 | $4,200.00 | $0.00 | $4,200.00 | $4,200.00 | Sent |