Crump v. State of Illinois et al

Page 1 of 4
THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
STEVEN CRUMP,
Plaintiff,
vs.
STATE OF ILLINOIS, ET AL.,
Defendants.
)
)
)
)
)
)
)
)
)
)
Case No. 3:23-cv-01922-GCS
MEMORANDUM & ORDER
SISON, Magistrate Judge:
Pending before the Court is Plaintiff’s Consolidated Motion requesting various
forms of relief (“Motion”). In the Motion, Plaintiff asks for six things: i) an order
compelling Defendants to provide “complete, accurate, and non-evasive” responses to
discovery requests; ii) the imposition of sanctions for alleged discovery violations; iii) an
explanation as to why the Court initially provided for the parties to serve fifteen
interrogatories on each other; iv) an order allowing Plaintiff to serve twenty-five
interrogatories on each Defendant; 1 v) leave to serve forty interrogatories on each
Defendant; and vi) judicial notice of a thirty-one day period when Plaintiff was allegedly
unlawfully detained. For the reasons given below, the Court DENIES each of Plaintiff’s
requests.
1 	Plaintiff has already served either thirty-five or forty interrogatories on each
Defendant in violation of the Court’s Scheduling and Discovery Order. (Doc. 150, p. 1;
Doc. 162, p. 1-2).
Case 3:23-cv-01922-GCS Document 168 Filed 02/10/26 Page 1 of 4 Page ID
#<pageID>

Page 2 of 4
A. 	Request to Compel Defendants, Request for Sanctions
The Court denies these requests. Motions to compel “must include a certification
that the movant has in good faith conferred or attempted to confer with the person or
party failing to make disclosure or discovery in an effort to obtain it without court action.”
FED. R. C IV. P ROC. 37(a)(1). This Court’s Local Rules also require parties to make good
faith efforts to timely meet and confer on any discovery dispute before filing a motion
with the Court.” SDIL-LR 26.1(c)(2). The Local Rules require that any motion filed
pursuant to Rules 26 through 37 of the Federal Rules of Civil Procedure include either a
copy of the discovery documents that are the subject of the motion or a “verbatim
recitation of each interrogatory, request, answer, response, and/or objection that is the
subject of the motion.” SDIL-LR 26.1(c)(4). Plaintiff has not complied with these
requirements. Accordingly, the Court denies Plaintiff’s motion to compel and to impose
sanctions on Defendants.
B. 	Clarification of the Limit on the Number of Interrogatories
Plaintiff also requests an explanation as to why the Court limited interrogatories
in this case to fifteen per party. (Doc. 163, p.7; Doc. 150, p. 1). As Plaintiff acknowledges,
this limitation is typical in prisoner civil rights cases. (Doc. 163, p. 6). The Court found
that this case did not, on its face, require more than fifteen interrogatories per party. At
the same time, it recognized that more interrogatories might be necessary, which is why
it allowed the parties to move to increase the limit for good cause shown. Id. Prior to the
instant Motion, Plaintiff had not moved for leave to serve additional interrogatories or
explained why there is good cause to increase the limit set out in the court’s Scheduling
Case 3:23-cv-01922-GCS Document 168 Filed 02/10/26 Page 2 of 4 Page ID
#<pageID>

Page 3 of 4
Order. (Doc. 150).
C. 	Requests for Leave to Serve Additional Interrogatories
Plaintiff has moved for leave to serve twenty-five interrogatories on each
Defendant and to serve up to forty interrogatories on each Defendant. The Court denies
these motions. As noted above, Plaintiff has not complied with Local Rule 26.1(c)(4),
which, on its own, warrants denial of Plaintiff’s requests. Furthermore, Plaintiff has not
shown good cause for the Court to grant him leave to serve additional interrogatories.
Plaintiff recites the complexity of his case, issues related to prison policies, and the
number of Defendants in this case as justifications for serving more interrogatories. (Doc.
163, p. 8). However, these factors are common in many prisoner rights cases. Without
more specific explanations as to why more interrogatories are necessary, without
providing the Court with the additional interrogatories that Plaintiff seeks to serve, and
without explanations as to why those additional interrogatories will serve to address the
needs of the case, the Court finds that there is no good cause to grant Plaintiff leave to
serve additional interrogatories. Accordingly, the Court DENIES Plaintiff’s requests.
D. 	Request for Judicial Notice
Finally, Plaintiff asks the Court to take judicial notice of the fact that “Plaintiff was
unlawfully detained for 31 days.” (Doc. 163, p. 3). The Court cannot do so. “A court may
take judicial notice of an adjudicative fact that is both ‘not subject to reasonable dispute’
and either (1) ‘generally known within the territorial jurisdiction of the trial court’ or (2)
‘capable of accurate and ready determination by resort to sources whose accuracy cannot
reasonably be questioned.’” General Elec. Capital Corp. v. Lease Resolution Corp., 128 F.3d
Case 3:23-cv-01922-GCS Document 168 Filed 02/10/26 Page 3 of 4 Page ID
#<pageID>

Page 4 of 4
1074, 1081 (7th Cir. 1997) (quoting FED. R. EVID. 201(b) (1975)). Judicial notice is proper
only when the matter is beyond reasonable controversy. See, e.g., Hennessy v. Penril
Datacomm Networks, Inc., 69 F.3d 1344, 1354 (7th Cir. 1995) (stating that “[i]n order for a
fact to be judicially noticed, indisputability is a prerequisite.”). Courts have traditionally
taken judicial notice of facts of universal truths that cannot reasonably be controverted,
such as geography or matters of political history. See 520 South Michigan Ave. Associates,
Ltd. v. Shannon, 549 F.3d 1119, 1137 n.14 (7th Cir. 2008). In other words, courts take judicial
notice of matters of common knowledge that cannot be disputed.
Plaintiff’s alleged over-detention is not a matter of common knowledge, nor has
he provided any evidence to demonstrate that it is indisputable. Plaintiff asserts that two
documents 	demonstrate 	the 	existence 	of 	this 	fact. 	(Doc. 	3). 	Plaintiff, 	however,
acknowledges that the Defendants dispute this fact. (Doc. 163, p. 3) The proper manner
to determine the facts of Plaintiff’s detention is to develop and test the evidence through
the adversarial process. Accordingly, the Court DENIES Plaintiff’s request for judicial
notice.
CONCLUSION
For the reasons explained above, the Court DENIES Plaintiff’s Motion.
IT IS SO ORDERED.
DATED: February 10, 2026.
______________________________
GILBERT C. SISON
United States Magistrate Judge
Digitally signed by
Judge Sison
Date: 2026.02.10
15:53:27 -06'00'
Case 3:23-cv-01922-GCS Document 168 Filed 02/10/26 Page 4 of 4 Page ID
#<pageID>