Shakman V. Democratic Organization of Cook County
Case: 1:69-cv-02145 Document #: 376 Filed: 01/11/06 Page 1 of 49 PageID #:2139 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION MICHAEL L. SHAKMAN, PAUL M. LURIE, KENNETH § AYERS, ANN M. KING, INDEPENDENT VOTERS OF § ILLINOIS-INDEPENDENT PRECINCT ORGANIZATION, § MICHAEL SULLIVAN, DARRYN JONES, STUART § MAJERCZYK, RICHARD GRAMAROSSA and CONNIE § GRAMAROSSA, et al. § Case No. 69 C 2145 § Plaintiffs, § Judge Andersen § v. § § DEMOCRATIC ORGANIZATION OF COOK COUNTY, § THE CITY OF CHICAGO, RICHARD M. DALEY, § INDIVIDUALLY AND AS MAYOR OF THE CITY OF § CHICAGO, REPUBLICAN STATE CENTRAL § COMMITTEE OF ILLINOIS, REPUBLICAN COUNTY § CENTRAL COMMITTEE OF COOK COUNTY, et al, § § Defendants. § SECOND AMENDED COMPLAINT For their complaint, plaintiffs allege eleven counts set forth below. Counts I through VI are unchanged from the First Amended Complaint. Counts VII and VIII, which added the Republican patronage defendants in 1972, are also unchanged. Final judgments have been entered on Counts I-VIII as to the City and at various times to other defendants in the form of the Consent Orders entered in 1972 and 1983. Count IX, which joined IVI-IPO in 1991 as a plaintiff against the Cook County defendants, is also unchanged since its filing, since it is subject to a final judgment contained in a Consent Order with the County Defendants. Count X, which begins on page 49, is a supplement to Counts I-IX and concerns events occurring after entry of the judgment orders in this case. It consists of allegations concerning the eight Additional Plaintiffs (as defined in that Count), who sought to be joined as plaintiffs in this action in November 2005.
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