MADISON - ST. CLAIR RECORD

Plaintiffs seeking to discredit Illinois Supreme Court Justice Lloyd Karmeier for the sake of a $7 billion suit against State Farm intend to bring Chief Justice Rita Garman into the proceedings too.

“Produce all documents related to Rita B. Garman, including but not limited to documents related to contributions provided by you or on your behalf,” David Eisenberg of Chicago wrote to State Farm on March 28, in one of 65 production requests.

Garman won a seat on the Court in 2002, two years before the Karmeier campaign that lead plaintiff Mark Hale previously identified as the origin of the Court’s alleged corruption. Garman was retained by voters to another 10-year term in November 2012.

Hale’s production requests all reach back to Jan. 1, 2001, except for three that reach back to 1992.

He seeks State Farm’s personnel files on employee William Shepherd, who he sues as an individual, plus chief executive Ed Rust and employee Kim Brunner.

The production request also seeks all documents relating to communication between Shepherd and another defendant, Ed Murnane, president of Illinois Civil Justice League.

Rather than produce, State Farm asked Chief U.S. District Judge David Herndon for a confidentiality order on May 2.

State Farm attached to its motion Eisenberg’s requests and interrogatories.

The production request began, “Produce all documents related to Justice Lloyd Karmeier, including but not limited to documents related to contributions provided by you or on your behalf to Justice Karmeier or his campaign for election to the Illinois Supreme Court.”

Eisenberg further asked for documents relating to:

- Citizens for Karmeier, a group Hale originally named as a defendant but quickly dismissed;

- Gordon Maag, who Karmeier defeated;

- Mary Karmeier, wife of Justice Karmeier; and

- Any Supreme Court campaign.

He asked for minutes of meetings, including State Farm’s board of directors, relating to the Supreme Court or the “selection, election and support of Justice Karmeier.”

He asked for all documents pertaining to efforts to raise money for Karmeier, bank accounts from which contributions were made to Karmeier and documents relating to Avery v. State Farm, a class action that underlies the action now pending before Herndon.

Lawyers in the current case obtained a billion dollar judgment for the Avery class in WilliamsonCounty in 1999, and the Supreme Court overturned it in 2005.

Hale and two others sued for the same class in 2012, claiming State Farm led a racketeering conspiracy to plant Karmeier on the Supreme Court.

They seek triple damages, plus interest, for a $7 billion total.

The production request that started with Karmeier spread in many directions.

Plaintiffs also asked for documents relating to:

- Illinois Civil Justice League and Murnane;

- Justpac and Shepherd’s involvement in it;

- Illinois Republican Party;

- State Sen. David Luechtefeld and State Rep. Dwight Kay;

- Former appellate judge Sue Myerscough;

- Illinois Manufacturers Association and Illinois Coalition for Jobs, Growth and Prosperity;

- Illinois Business Roundtable task forces on class actions and civil justice reform task forces;

- National Business Roundtable and Financial Services Roundtable;

- Illinois Lawsuit Abuse Watch, Civil Justice Reform Group, NationalLitigationCenter, and American Tort Reform Association;

- U.S. Chamber of Commerce, which owns this newspaper, National Chamber Foundation and Illinois Chamber of Commerce;

- U.S. Chamber’s Institute for Legal Reform, including Rust’s membership on it, the subject of judicial elections, and the campaigns of 2002 and 2004;

- Karen Melchert, Cristin Connerty, Todd Maisch, Kim Maisch, Allen Adomite, Mark Denzler, Cliff Pintak, Thomas Donohue, Rob Engstrom, Curt Mercadante, Sherman Joyce, Scott Reed and Steve Tomaszewski; and

- MPGH Agency, John Pastuovic Communications, and Mid-America Advertising.

Plaintiffs also asked State Farm for “all joint defense agreements you have with any of the defendants or any other person or entity regarding this case,” as well as:

- Documents relating to communication with Sandberg Phoenix law firm about Karmeier’s campaign, from 2003 to 2005;

- Documents relating to State Farm’s provision of contributions to political candidates in Illinois since 1992; and

- Documents “sufficient to identify any person to whom or entity to which you have made political contributions for the period from 1992 to the present.”

They asked for State Farm’s budget for political contributions since 1992.

Separately Eisenerg served 21 interrogatories.

Plaintiffs asked about meetings, calls, emails, or other contact by State Farm or on its behalf with Karmeier including deliveries to his office.

They asked about State Farm’s donations or contributions to his campaign and about State Farm’s involvement in the Illinois Civil Justice League’s decision to support Karmeier, and whether State Farm contributed to the league.

They asked the same about Justpac, the U.S. Chamber, the state Chamber, the state party, the jobs and growth coalition, Citizens for a Sound Economy, the tort reform group, and the civil justice reform group.