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Calderwood & Harkness LLP Litigation 12 docs · open →

Document types detected

Analysis / memo4

Correspondence2

Other2

Engagement letter2

Pleading / procedure1

Filing / regulatory1

Parties across the matter

Counsel Metropolitan Transit Development CorpDirector Metropolitan Transit Development CorpHARKNESS LLPHarkness LLPINTRODUCTION Metropolitan Transit Development CorpM. CriticallyM. GroundM. TheM. TheseM. ThisM. ThoseM. WhenMetropolitan Transit Development CorpPemberton Corp

Chronology

2024-06-11 · litigation-readiness-memorandum.docx

… strongly recommend filing the Court of Claims complaint no later than June 11, 2024 — approximately sixty days from the date of this memorandum. II. Procedural History A. So …

2024-04-22 · client-status-update-letter.docx

… RKNESS LLP 311 South Wacker Drive, Suite 4800 Chicago, Illinois 60606 April 22, 2024 VIA EMAIL AND FIRST-CLASS MAIL PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION Dr …

2024-04-14 · status-inquiry-letter-fourth.docx

… (30) calendar days of the date of this letter — that is, on or before April 14, 2024; or (b) Provide MTDC, through undersigned counsel, with a definitive written timeline spe …

2024-04-12 · litigation-readiness-memorandum.docx

… s FROM: Sara Hendricks, Lead Associate, Privacy & Data Security DATE: April 12, 2024 RE: Litigation Readiness Assessment — Escalation of Protest No. IDOT-BPC-2022-0047 to the …

2024-03-18 · litigation-readiness-memorandum.docx

… form receipt confirmation from the IDOT Office of Chief Counsel dated March 18, 2024, with no indication of when or whether a decision would be forthcoming. MTDC has been eff …

2024-03-15 · client-status-update-letter.docx

… t the Board prioritize the issuance of its decision. Fourth Inquiry — March 15, 2024. Approximately fifteen months after the advisement order, we submitted a fourth inquiry t …

2024-03-15 · status-inquiry-letter-fourth.docx

… : (312) 554-7200 Facsimile: (312) 554-7201 www.calderwoodharkness.com March 15, 2024 Ian Blackwood Partner Direct Dial: (312) 554-7238 Direct Fax: (312) 554-7302 Email: iblac …

2024-03-15 · litigation-readiness-memorandum.docx

… ehalf of MTDC (February 17, 2023; June 9, 2023; November 3, 2023; and March 15, 2024), none of which have received a substantive response. The most recent inquiry, dated Marc …

2023-11-03 · client-status-update-letter.docx

… TDC's programmatic objectives and financial position. Third Inquiry — November 3, 2023. Approximately eleven months after the advisement order, we submitted a third, more stron …

2023-11-03 · status-inquiry-letter-fourth.docx

… concern. No substantive response was received. Third Status Inquiry — November 3, 2023. Approximately eleven months after the matter was taken under advisement, and in light of …

2023-11-03 · litigation-readiness-memorandum.docx

… status inquiries on behalf of MTDC (February 17, 2023; June 9, 2023; November 3, 2023; and March 15, 2024), none of which have received a substantive response. The most recent …

2023-06-09 · client-status-update-letter.docx

… preventing the commencement of contract performance. Second Inquiry — June 9, 2023. Approximately six months after the advisement order, we submitted a second inquiry, reit …

2023-06-09 · status-inquiry-letter-fourth.docx

… received from your office or from the Board. Second Status Inquiry — June 9, 2023. Approximately six months after the matter was taken under advisement, and nearly four mo …

2023-06-09 · litigation-readiness-memorandum.docx

… d four written status inquiries on behalf of MTDC (February 17, 2023; June 9, 2023; November 3, 2023; and March 15, 2024), none of which have received a substantive respons …

2023-02-17 · client-status-update-letter.docx

… ryor at the IDOT Office of Chief Counsel, as follows: First Inquiry — February 17, 2023. Approximately two and one-half months after ALJ Odum took the matter under advisement, w …

2023-02-17 · status-inquiry-letter-first.docx

… rkness LLP 311 South Wacker Drive, Suite 4800 Chicago, Illinois 60606 February 17, 2023 Nadine Pryor Chief Counsel, Office of Chief Counsel Illinois Department of Transportation …

2023-02-17 · status-inquiry-letter-fourth.docx

… on. None has generated a substantive response. First Status Inquiry — February 17, 2023. Approximately two and one-half months after ALJ Odum took the matter under advisement, t …

2023-02-17 · litigation-readiness-memorandum.docx

… rkness has submitted four written status inquiries on behalf of MTDC (February 17, 2023; June 9, 2023; November 3, 2023; and March 15, 2024), none of which have received a subst …

2022-12-02 · client-status-update-letter.docx

… erized the matter since ALJ Odum took the protest under advisement on December 2, 2022. Second, we present the options available to MTDC for escalating its challenge beyond the …

2022-12-02 · status-inquiry-letter-first.docx

… Protest No. IDOT-BPC-2022-0047, which has been under advisement since December 2, 2022. We write in a spirit of cooperation and with the shared objective of facilitating a time …

2022-12-02 · status-inquiry-letter-fourth.docx

… had fully briefed the issues and the matter was ripe for decision. On December 2, 2022, ALJ Odum issued an order stating that he was taking the matter "under advisement" and th …

2022-12-02 · litigation-readiness-memorandum.docx

… istrative Law Judge Terrence Odum took the matter under advisement on December 2, 2022 — over sixteen months ago — and has issued no substantive ruling in the intervening perio …

2022-11-15 · client-status-update-letter.docx

… al argument was held before Administrative Law Judge Terrence Odum on November 15, 2022. All parties participated through counsel, and ALJ Odum posed detailed questions to each …

2022-11-15 · status-inquiry-letter-first.docx

… al argument was held before Administrative Law Judge Terrence Odum on November 15, 2022, at which all parties had a full and fair opportunity to present their respective positio …

2022-11-15 · status-inquiry-letter-fourth.docx

… rough Brannick, Hartley & Voss LLP, filed its Intervenor Response. On November 15, 2022, Administrative Law Judge Terrence Odum conducted oral argument on the protest. At the co …

2022-11-15 · litigation-readiness-memorandum.docx

… EP members' MTTC membership did not constitute disqualifying bias. On November 15, 2022, oral argument was held before ALJ Terrence Odum. All three parties — MTDC, IDOT, and Pin …

2022-10-28 · client-status-update-letter.docx

… sal. Brannick, Hartley & Voss filed Pinnacle's Intervenor Response on October 28, 2022, opposing the protest on all grounds. Oral argument was held before Administrative Law Ju …

2022-10-28 · status-inquiry-letter-first.docx

… the basis of the protest. Pinnacle's Intervenor Response was filed on October 28, 2022. Oral argument was held before Administrative Law Judge Terrence Odum on November 15, 202 …

2022-10-28 · status-inquiry-letter-fourth.docx

… itrary, capricious, and contrary to the terms of the solicitation. On October 28, 2022, Pinnacle, through Brannick, Hartley & Voss LLP, filed its Intervenor Response. On Novemb …

2022-10-28 · litigation-readiness-memorandum.docx

… ied additional concerns raised by the Agency Report documentation. On October 28, 2022, Brannick, Hartley & Voss filed Pinnacle's Intervenor Response, opposing the protest on a …

2022-10-28 · mtdc-comments-on-agency-report.docx

… rvention on September 12, 2022. Pinnacle's Intervenor Response is due October 28, 2022. To the extent that Pinnacle's Notice of Intervention foreshadows certain arguments, MTDC …

2022-10-14 · client-status-update-letter.docx

… . Calderwood & Harkness filed MTDC's Comments on the Agency Report on October 14, 2022. The Comments comprehensively addressed each of MTDC's five grounds for protest, supporte …

2022-10-14 · status-inquiry-letter-first.docx

… mber 30, 2022. MTDC timely filed its Comments on the Agency Report on October 14, 2022, addressing the substantive deficiencies in the evaluation process that form the basis of …

2022-10-14 · status-inquiry-letter-fourth.docx

… l and cost evaluation narratives, and related procurement records. On October 14, 2022, MTDC, through this firm, filed its Comments on the Agency Report, identifying specific f …

2022-10-14 · litigation-readiness-memorandum.docx

… ontracts Division, appeared as counsel for IDOT in the proceeding. On October 14, 2022, Calderwood & Harkness filed MTDC's Comments on the Agency Report, which provided a detai …

2022-10-14 · mtdc-comments-on-agency-report.docx

… LOPMENT CORP.'S COMMENTS ON THE AGENCY REPORT AND PROTEST FILE Filed: October 14, 2022 Right-click to update Table of Contents I. INTRODUCTION Protestant Metropolitan Transit D …

2022-10-05 · expert-report-summary-memo.docx

… ristopher Aiken, Associate FROM: Sara Hendricks, Lead Associate DATE: October 5, 2022 RE: Summary of Expert Findings — Dr. Alicia Fernwood, Linden Analytics Group, LLC — Procu …

2022-10-01 · client-status-update-letter.docx

… that contract performance has not commenced. The RFP contemplated an October 1, 2022 start date for the IITMP contract, but that date was not met due to the automatic stay of …

2022-10-01 · status-inquiry-letter-first.docx

… Moreover, the IITMP contract's anticipated performance start date of October 1, 2022, has already passed without the commencement of work, and continued delay in resolving th …

2022-10-01 · status-inquiry-letter-fourth.docx

… e-year option periods. The anticipated contract commencement date was October 1, 2022, which has now been delayed by approximately eighteen months as a direct consequence of t …