The city of Rock Falls and two fire officials are taking steps that could pave the way for an appeal of a $31.5 million verdict issued against them a little over three weeks ago in connection with Sterling Fire Lt. Garrett Ramos’s 2021 line-of-duty death.

Court documents filed Nov. 24 in Whiteside County Circuit Court indicate that former Rock Falls Fire Chief Chris Bouwens, Rock Falls Fire Chief Ken Wolf, and the city of Rock Falls have retained appellate counsel and are asking to extend the deadline to file a post-trial motion in the wake of the verdict delivered Nov. 14 at the conclusion of a nine-day civil trial.

They are also asking for an entry staying enforcement on the judgment as they request more time to file a post-trial motion.

At the Tuesday, Dec. 2, Rock Falls City Council meeting, the council unanimously approved the hiring of a law firm to represent the city and provide insurance coverage advice relating to the $31.5 million it owes.

Andrew M. Barrios of Reed Smith LLP in Chicago wrote in a letter to the city that he plans to handle the matter personally to ensure “efficiency and predictability.”

Barrios will charge the city $960 an hour for his services and, if appropriate, will also utilize other attorneys at the firm who are billed at a lower rate, typically ranging from $600 to $800 an hour. In addition, the city agrees to pay reimbursable expenses associated with the firm’s representation, like those for obtaining electronic discovery information, according to the letter.

The current deadline to file a post-trial motion is Dec. 15, 2025. The motion filed Nov. 24 states the defendants’ appellate counsel currently is handling a heavy case load and that when combined with the length of the trial, the time required to review transcripts, and to research and prepare a post-trial motion, and the upcoming holidays, they need an additional 30 days to file a post-trial motion.

According to the Nov. 24 court filing, a party intending to move to set aside any judgment may apply to the court for a certificate, which the judge may, in his or her discretion, grant, stating that there is probable cause for staying further proceedings by the order of the court on the motion.

“This provision authorizes the court to stay enforcement of a judgment during the period between the date the judgment was entered on the verdict and the date a post-trial motion is filed to seek to set aside or modify the judgment,” the motion reads. ”Defendants respectfully request that the court stay enforcement of the judgment for this time period. Such a stay is consistent with Supreme Court Rule 305(i), which contemplates that the court can stay a judgment pending an appeal made by a municipal corporation like Rock Falls without requiring a bond or other surety.”

The hearing on the motion is set for 9 a.m. Monday, Dec. 8, in Whiteside County Circuit Court.

The motion filing comes two weeks after Rock Falls officials said they’re reviewing all options to pay the $31.5 million a Whiteside County jury awarded to Ramos’s wife and their two daughters.

At a Rock Falls’ City Council meeting on Tuesday, Nov. 18, Rock Falls City Administrator Robbin D. Blackert addressed the civil lawsuit verdict in an emotional statement. She said the amount owed is “far in excess of the city’s available insurance coverage” and that “the city will review all options in determining the best course of action.”

Blackert also noted the changes the Rock Falls Fire Department has made to upgrade its training standards in the years since Ramos‘s death and expressed sympathy for his family.

She declined to comment further on the issue, saying, “this is the one statement that we [Rock Falls] will make.”

Ramos died Dec. 4, 2021 – four years ago this week.

The fire was reported by the home’s basement resident at 11:04 p.m. Dec. 3, 2021, after the fire started in the one-story home’s attached garage. Ramos arrived at the burning home on Ridge Road in Rock Falls at 11:21 p.m. as part of a Sterling fire crew assisting the Rock Falls Fire Department.

Ramos, who was fighting the fire while inside the home, was leaving the burning structure to replenish his air supply around midnight when he fell through a hole in the floor into the basement. Fire officials did not know the home had a basement at the time he fell.

He was able to issue two mayday calls, but command officers did not know who was issuing them, where the firefighter was located, or what the problem was. They initially identified another firefighter as the one they thought was missing; when he was found, no further work was done to make sure no one else had made the call, according to testimony.

About 30 minutes later, firefighters realized Ramos had not been seen for a while and began searching for him. He was found in the basement in a room adjacent to the room where he fell.

Fire investigators said Ramos was not injured during the fall and had been walking around the basement to find a way out. They believe Ramos survived for about 17 minutes after he fell into the basement and died from asphyxia after running out of air. Firefighters recovered his body at 1:13 a.m. Dec. 4.

Brittney Ramos, Ramos’s wife, filed the lawsuit in December 2022, claiming Bouwens and Wolf, who was a deputy chief at the time of the fire, showed a willful and wanton disregard that caused her husband’s death. The jury found that Bouwens and Wolf were each 50% to blame for Ramos’s death.

The trial ran over the course of two weeks and included testimony from firefighters who were at the scene, Bouwens, Wolf, former Sterling Fire Chief Michael Dettman, expert witnesses, Brittney Ramos and Ramos’ parents.

Ramos’s attorney, Michael Gallagher, had asked the jury to consider a string of failures as it weighed the evidence:

• Bouwens’ failure to ask the residents of the home, who were on-scene, if there was a basement. Firefighters did not learn the home had a basement until after receiving mayday calls from a fallen firefighter at 12:03 a.m. Dec. 4. Not knowing there was a basement put firefighters working the interior of the burning structure at risk because of potential floor collapse and holes developing.

• Bouwens’ failure to appoint a safety officer, as soon as a senior trained official was available, to oversee the scene. Ramos’s attorneys said former Dixon Rural Fire Chief Sid Aurand arrived at the scene at 11:40 p.m., but Bouwens didn’t appoint Aurand as safety officer until three minutes after the two mayday calls were heard at 12:03 a.m.

• Failure to withdraw interior firefighters from the burning home in a timely manner as fire conditions worsened. The fire initially began in the unattached garage. Throughout the next hour, firefighters battled a blaze that had spread into and across the home’s attic, with fire apparent to firefighters as they used tools to pull down ceilings as they worked to save the property. All residents were out of the home safely, yet firefighters were sent back into the burning structure as trusses were falling and holes were developing in the floor.

• Failure to initiate a personnel accountability report in a timely manner so that all firefighters were accounted for.

• Failure to administer PAR properly.

• Failure to properly train for mayday calls and PAR response.

The city of Rock Falls, Bouwens, and Wolf countered that Ramos was partially responsible for missteps that contributed to his own death. Defense attorney Michael Kujawa said Ramos did not maintain crew integrity because he was not with his firefighting partner at the time he fell, and that he should have left the home sooner to get air, as other firefighters had. Kujawa also questioned why Ramos did not provide his name, location or problem when making the mayday call.

The verdict awarded to the Ramos family includes:

• $7 million for the pain and suffering experienced by Garrett Ramos

• $5 million for Brittney Ramos and their two young daughters’ grief, sorrow and mental suffering

• $5 million for loss of society by the two daughters

• $5 million for loss of society, companionship and sexual relationship by Brittney Ramos

• $3 million for the emotional distress suffered by Garrett Ramos

• $3 million for the loss of instruction and moral training that Garrett Ramos was likely to have contributed to his two daughters

• $2.5 million for Garrett Ramos’s loss of future earnings

• $1 million for the loss of money, benefits, goods and services Garrett Ramos was likely to have contributed to Brittney and their two daughters