1:20-Cv-02093 Document #: 1 Filed: 04/02/20 Page 1 of 48 Pageid #:1
Case: 1:20-cv-02093 Document #: 1 Filed: 04/02/20 Page 1 of 48 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JAMES MONEY, WILLIAM RICHARD, ) GERALD REED, AMBER WATTERS, ) TEWKUNZI GREEN, DANNY LABOSETTE, ) CARL REED, CARL “TAY TAY” TATE, ) PATRICE DANIELS, and ANTHONY ) RODESKY, on behalf of themselves and all ) similarly situated individuals, ) ) Plaintiffs, ) Case No. ) (Class Action) ) v. ) ) J.B. PRITZKER, in his official capacity as ) GOVERNOR OF THE STATE OF ILLINOIS, ) and ROB JEFFREYS, in his official capacities as ) DIRECTOR OF THE DEPARTMENT OF ) CORRECTIONS, ) ) Defendants. ) CLASS ACTION COMPLAINT Plaintiffs James Money, William Richard, Gerald Reed, Amber Watters, Tewkunzi Green, Danny Labosette, Carl Reed, Carl “Tay Tay” Tate, Patrice Daniels, and Anthony Rodesky, individually and on behalf of a class of similarly situated individuals, by their undersigned attorneys, file this Complaint for declaratory and injunctive relief against the Defendants, Governor of the State of Illinois J.B Pritzker and Illinois Department of Corrections Director Rob Jeffreys, and allege as follows: INTRODUCTION 1. Without urgent action by the Governor and the Illinois Department of Corrections (“IDOC”) to drastically reduce Illinois’s prison population, the novel coronavirus is likely to 1 Case: 1:20-cv-02093 Document #: 1 Filed: 04/02/20 Page 2 of 48 PageID #:2 spread not just inside the walls of Illinois’s 28 prisons, but throughout prison communities as well. Nearly 37,000 people are incarcerated in Illinois, living in close quarters where all aspects of daily life, including healthcare and food service, take place.
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