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Illinois Women's Basketball Lawsuit
Illinois Women's Basketball Lawsuit
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E-FILED
No.:
Honorable
Courtroom:
Defendants.
COMPLAINT
NOW COME the Plaintiffs, Amarah Coleman, Alexis Smith, Taylor Tuck,
Nia Oden, Sarah Livingston, Taylor Gleason and Jacqui Grant, by and through
their attorneys, Ekl, Williams & Provenzale LLC, and complaining of the
Defendants, the Board of Trustees of the University of Illinois Urbana-Champaign
(hereinafter "Defendant University"), Mike Thomas (hereinafter "Thomas"), Matt
Bollant (hereinafter "Bollant") and Mike Divilbiss (hereinafter "Divilbiss"), upon
information and belief, state as follows:
Introduction
1.
the Plaintiffs' rights under federal and state laws and the Fourteenth Amendment
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This Court has original jurisdiction over the Plaintiffs' federal claims
brought under Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq., 42
U.S.C. 1983 and 42 U.S.C. 1981 pursuant to 28 U.S.C. 1331 and/or 1343. The
Court has supplemental jurisdiction over the Plaintiffs' pendent state law claims
pursuant to 28 U.S.C. 1367(a) as the facts forming the basis of such claims arise
out of the same nucleus of operative facts that form the basis of the Federal claims.
3.
the facts giving rise to this suit occurred within this district and, upon information
and belief, the Defendant University, Thomas and Bollant reside in this District.
Parties to the Suit
4.
the United States of America of African-American descent who enjoyed all the
/MN
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rights, freedoms and liberties as afforded under the Constitution of the United
States of America, the Laws of the United States and the Laws of the State of
Illinois, and residing in the State of Illinois. Amarah, a world-class athlete, was
enrolled as a student with the Defendant University for the 2014-2015 academic
calendar year, and was under athletic scholarship with the Defendant University
providing her talents to the Defendant University in its Division I Women's
Basketball Program during that time.
5.
Alexis Smith is and was, at all times relevant hereto, a citizen of the
United States of America of African-American descent who enjoyed all the rights,
freedoms and liberties as afforded under the Constitution of the United States of
America, the Laws of the United States and the Laws of the State of Illinois, and
residing in the State of New York. Alexis, a world-class athlete, was enrolled as a
student with the Defendant University for the 2011-2014 academic calendar year,
and was under athletic scholarship with the Defendant University providing her
talents to the Defendant University in its Division I Women's Basketball Program
during that time.
6.
Taylor Tuck is and was, at all times relevant hereto, a citizen of the
United States of America of African-American descent who enjoyed all the rights,
freedoms and liberties as afforded under the Constitution of the United States of
America, the Laws of the United States and the Laws of the State of Illinois, and
residing in the State of Illinois. Taylor, a world-class athlete, was enrolled as a
student with the Defendant University for the 2011-2015 academic calendar year,
/MN
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and was under athletic scholarship with the Defendant University providing her
talents to the Defendant University in its Division I Women's Basketball Program
during that time.
7.
Nia Oden is and was, at all times relevant hereto, a citizen of the
United States of America of African-American descent who enjoyed all the rights,
freedoms and liberties as afforded under the Constitution of the United States of
America, the Laws of the United States and the Laws of the State of Illinois, and
residing in the State of New York. Nia, a world-class athlete, was enrolled as a
student with the Defendant University for the 2011-2015 academic calendar year,
and was under athletic scholarship with the Defendant University providing her
talents to the Defendant University in its Division I Women's Basketball Program
during that time.
8.
the United States of America of African-American descent who enjoyed all the
rights, freedoms and liberties as afforded under the Constitution of the United
States of America, the Laws of the United States and the Laws of the State of
Illinois, and residing in the State of Illinois. Sarah, a world-class athlete, was
enrolled as a student with the Defendant University for the 2013-2014 academic
calendar year, and was under athletic scholarship with the Defendant University
providing her talents to the Defendant University in its Division I Women's
Basketball Program during that time.
/MN
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9.
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Taylor Gleason is and was, at all times relevant hereto, a citizen of the
United States of America of who enjoyed all the rights, freedoms and liberties as
afforded under the Constitution of the United States of America, the Laws of the
United States and the Laws of the State of Illinois, and residing in the State of
Michigan. Taylor, a world-class athlete, was enrolled as a student with the
Defendant University for the 2013-2015 academic calendar year, and was under
athletic scholarship with the Defendant University providing her talents to the
Defendant University in its Division I Women's Basketball Program during that
time.
10.
Jacqui Grant is and was, at all times relevant hereto, a citizen of the
United States of America who enjoyed all the rights, freedoms and liberties as
afforded under the Constitution of the United States of America, the Laws of the
United States and the Laws of the State of Illinois, and residing in the State of
Illinois. Jacqui, a world-class athlete, was enrolled as a student with the Defendant
University for the 2013-2015 academic calendar year, and was under athletic
scholarship with the Defendant University providing her talents to the Defendant
University in its Division I Women's Basketball Program during that time.
11.
The Defendant University is and has been at all times relevant herein
a body politic land grant institution incorporated under the Laws of the State of
Illinois, 110 ILCS 305/1, providing, operating, maintaining and controlling facilities
and instructors of higher education at the Urbana-Champaign campus, and was at
all times relevant hereto operating, maintaining and/or controlling an NCAA
/MN
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The Defendant, Thomas, at all times relevant herein is and since his
hire by the Defendant University in 2011 has been the Director of Athletics of the
Defendant University's Division of Intercollegiate Athletics, including therein the
Women's Basketball Program, acting at all times in such capacity under color of law
and within the scope of his employment with the Defendant University. In such
capacity, the Defendant, Thomas, directly oversaw, managed, supervised and
controlled the Defendant University's men's and women's intercollegiate sports
programs' coaches, assistant coaches, the student-athletes, including the Plaintiffs
herein above, and medical / sports injury training staff. In this capacity and role
the Defendant, Thomas, was in a position to address the racially hostile
environment described herein and to take corrective action on the Defendant
University's behalf to end it. Defendant, Thomas, is named in his individual
capacity.
/MN
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13.
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The Defendant, Bollant, at all times relevant herein is and since his
hire by the Defendant University and/or Thomas in 2012 has been the head
women's basketball coach for the Defendant University's Women's Basketball
Program acting under color of law and within the scope of his employment with the
Defendant University. In such capacity, the Defendant, Bollant, directly managed,
supervised and controlled his assistant coaches, including the Defendant, Divilbiss,
the student-athletes, including the Plaintiffs herein above, and medical / sports
injury training staff. In this capacity and role the Defendant, Thomas, was in a
position to address the racially hostile environment described herein and to take
corrective action on the Defendant University's behalf to end it. Defendant,
Bollant, is named in his individual capacity.
14.
The Defendant, Divilbiss, at all times relevant herein was hired by the
University and/or the Defendant, Bollant, in 2012 and acted in the capacity of
associate head basketball coach until his resignation in 2015, acting under color of
law and within the scope of his employment with the Defendant University. In
such capacity and during such time, the Defendant, Divilbiss, directly managed,
supervised and controlled the Women's Basketball Program, its student-athletes,
including the Plaintiffs herein above, and medical / sports injury training staff.
Defendant, Divilbiss, is named in his individual capacity.
/MN
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herein.
16.
Program was under the direction and supervision of former head basketball coach,
Jolette Law, a woman of African-American descent. In such capacity, former coach
Law recruited and received commitments from the Plaintiffs, Alexis Smith, Taylor
Tuck and Nia Oden to the 2011-2012 academic class, to participate as student
athletes in the Women's Basketball Program under an athletic scholarship for the
Defendant University.
17.
In 2012, Jolette Law was fired by the Defendant, Thomas, and the
accepted by the Plaintiffs above were and are written contractual agreements
whereby, in exchange for the student athlete's commitment to and participation in
the Defendant University's Women's Basketball Program, the Defendant University
would and did provide each Plaintiff with financial assistance in form of the costs of
tuition, costs of room and board, and costs of certain education materials, with the
/MN
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At some time around the beginning of, prior to and/or during the
color of law and within the scope of the employment of each with the Defendant,
University, engaged in the following misconduct that created and/or constituted a
racially hostile environment and/or discrimination based upon race:
a.
b.
/MN
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c.
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d.
e.
f.
g.
h.
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j.
k.
l.
m.
21.
of the Defendants, Bollant and/or Divilbiss, acting under color of law and in the
scope of the employment of each with the Defendant University, the Defendants,
Bollant and/or Divilbiss, also engaged in a discriminatory campaign of statements
/MN
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and/or misconduct of treating black players and white players who associated
and/or supported the black players differently than the favored and/or
non-associating white players, where if a non-associating or favored white girl
played poorly or made mistakes, the Defendants, Bollant and/or Divilbis,
encouraged the white girl or coached her for improvement; yet if a black girl or
associating white girl played poorly or made a mistake, the black and/or associating
white player was insulted, denigrated, demeaned, demoralized and/or embarrassed
in front of the rest of the team or other observers in a manner so as to publicly
humiliate and disparage that player, and otherwise in a manner that exhibited an
intent to discriminate against that player based on race or that player's association.
22.
the intention and/or design to compel and/or coerce the Plaintiffs to quit the team,
surrender their scholarship and/or transfer from the Defendant University, and
which conduct was otherwise negative and adverse in contrast to the treatment of
persons similarly situated otherwise.
23.
under color of law and within the scope of the employment of each with the
Defendant, University, engaged in the following campaign of statements and/or
misconduct that created and/or constituted a racially hostile environment and/or
discrimination based upon race:
a.
/MN
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c.
d.
e.
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24.
the team's black players to the systematic exclusion of the team's non-associating
and/or favored white players, the Defendants also singled out white players who
associated with and/or supported their black teammates who were being verbally
and/or psychologically mistreated and abused on account of their race, through
retaliatory actions such as:
a.
/MN
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25.
environment that existed from approximately 2013 through the end of the academic
year 2015, and otherwise amounted to disparate and divisive treatment of black
players and white players who associated and/or supported the black players,
including the Plaintiffs herein, in contrast to the positive and productive treatment
of those similarly situated but for the race and/or association of the person.
26.
During the time period set forth in 25, above, the Defendant, Bollant,
was actually aware of the racially hostile environment, was in a position to address
the racially hostile environment, was in a position to take measures to end it and
/MN
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acting under color of law and within the scope of the employment of each with the
Defendant University, amounting to a racially hostile environment, the Plaintiff,
Sarah Livingston, surrendered her scholarship and transferred out of the
Defendant University.
30.
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COUNT I
RACIALLY HOSTILE ENVIRONMENT IN EDUCATION
42 U.S.C. 2000d (Title VI of the Civil Rights Act of 1964)
33.
34.
Smith, Taylor Tuck, Nia Oden, Sarah Livingston, Taylor Gleason and Jacqui Grant,
were enrolled as student athletes under athletic scholarships in the Defendant
University and enjoyed at all times those protections and freedoms from racial
discrimination set forth in Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d,
specifically the prohibition against discrimination on ground of race from
participation in and/or benefit of an educational institution's programs and/or
activities.
35.
under color of law and within the scope of employment of each with the Defendant
University, created and maintained a severe, pervasive and objectively offensive
racially hostile environment within the Women's Basketball Program that
constituted racial discrimination in violation of 42 U.S.C. 2000d and operated to
exclude, deny and/or deprive the Plaintiffs, of participation in and/or the benefits of
same.
/MN
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37.
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being in a position to address and take measures to correct the racially hostile
environment, were deliberately indifferent to the racially hostile environment and
its consequences on the Plaintiffs despite actual knowledge of it.
38.
herein.
/MN
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40.
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Smith, Sarah Livingston, Taylor Gleason and Jacqui Grant, were enrolled as
student athletes under athletic scholarships in the Defendant University and
enjoyed at all times those protections and freedoms from racial discrimination in
the making of contracts set forth in 42 U.S.C. 1981. Each had at least one year of
Women's Division I Basketball athletic eligibility remaining.
41.
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herein.
44.
Smith, Taylor Tuck, Nia Oden, Sarah Livingston, Taylor Gleason and Jacqui Grant,
enjoyed all the rights, privileges and freedoms of the Fourteenth Amendment to the
United States Constitution, including specifically the right to Equal Protection of
the Laws and the correlative right thereunder to be free from intentional and
invidious discrimination on the basis of race and association.
45.
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Jacqui Grant, were retaliated against by the Defendants, Bollant and/or Divilbiss,
in a manner and under such circumstances as amounting to intentional and
invidious discrimination on the ground of race for their association with the black
Plaintiffs, and otherwise in such a manner and under such circumstances that
reveal an impermissible discriminatory purpose in violation of the Fourteenth
Amendment's guarantee to Equal Protection of the Laws.
WHEREFORE, the Plaintiffs, Amarah Coleman, Alexis Smith, Taylor Tuck,
Nia Oden, Sarah Livingston, Taylor Gleason and Jacqui Grant, each demand
judgment against the Defendants, Matt Bollant and Mike Divilbiss, jointly and
severally, for compensatory and punitive damages in a total sum in excess of Ten
Million Dollars ($10,000,000.00), plus attorney's fees and costs of this suit on such
judgments pursuant to 42 U.S.C. 1988(b) and Federal Rule of Civil Procedure 54,
and any other legal or equitable relief this Court deems just and appropriate.
COUNT IV
ILLINOIS CIVIL RIGHTS ACT VIOLATIONS
740 ILCS 23/5
47.
herein.
/MN
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48.
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Smith, Taylor Tuck, Nia Oden, Sarah Livingston, Taylor Gleason and Jacqui Grant,
were enrolled as student athletes under athletic scholarships in the Defendant
University and enjoyed at all times those protections and freedoms from racial
discrimination set forth in 740 ILCS 23/5(a)(1), specifically the prohibition against
discrimination on ground of race from participation in and/or benefit of an
educational institution's programs and/or activities.
49.
under color of law and within the scope of the employment of each with the
Defendant University, created and maintained a racially hostile environment
within said program and team that constituted racial discrimination in violation of
740 ILCS 23/5 and operated to exclude, deny and/or deprive the Plaintiffs, of
participation in and/or the benefits of same.
51.
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Page 1 of 2
CIVIL COVER
SHEET
JS 44 (Rev. 12/12)
E-FILED
Wednesday,
2015
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service
of pleadings or01
otherJuly,
papers as
required11:00:43
by law, exceptAM
as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required
for
the
use
of
the
Clerk
of
Court for the
Clerk,
U.S.
District
Court,
ILCD
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS
DEFENDANTS
Will
NOTE:
unknown
U.S. Government
Plaintiff
Federal Question
(U.S. Government Not a Party)
U.S. Government
Defendant
Diversity
(Indicate Citizenship of Parties in Item III)
DEF
1
Citizen or Subject of a
Foreign Country
Foreign Nation
TORTS
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education
FORFEITURE/PENALTY
PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
463 Alien Detainee
510 Motions to Vacate
Sentence
530 General
535 Death Penalty
Other:
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement
BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act
SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
OTHER STATUTES
IMMIGRATION
462 Naturalization Application
465 Other Immigration
Actions
2 Removed from
State Court
Remanded from
Appellate Court
4 Reinstated or
Reopened
5 Transferred from
Another District
(specify)
6 Multidistrict
Litigation
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
42 U.S.C. 2000d (Title VI), 42 U.S.C. 1981(a), 42 U.S.C. 1983, 740 ILCS 23/5, and 14th Amendment
Violations against Plaintiffs for racial discrimination, retaliation & invidious discrimination by Defendants
DEMAND $
10,000,000.00
s/ Terry A. Ekl
FOR OFFICE USE ONLY
RECEIPT #
AMOUNT
APPLYING IFP
Save As...
JUDGE
MAG. JUDGE
Reset
2:15-cv-02146-CSB-EIL # 1-1
Page 2 of 2
(b)
(c)
Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II.
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III.
Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV.
Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.
V.
VI.
Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII.
Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
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Page 1 of 2
E-FILED
CentralDistrict
Districtof
of__________
Illinois
__________
Amarah Coleman, Alexis Smith, Taylor Tuck, Nia
Oden, Sarah Livingston, Taylor Gleason and Jacqui
Grant,
Plaintiff(s)
v.
The Board of Trustees of the University of Illinois
Urbana-Champaign, a Body Politic and Corporate,
Mike Thomas, Matt Bollant and Mike Divilbiss,
Defendant(s)
)
)
)
)
)
)
)
)
)
)
)
)
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
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Page 2 of 2
; or
I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)
, who is
; or
; or
Other (specify):
.
My fees are $
0.00
Date:
Servers signature
Servers address
Save As...
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2:15-cv-02146-CSB-EIL # 1-3
Page 1 of 2
E-FILED
CentralDistrict
Districtof
of__________
Illinois
__________
Amarah Coleman, Alexis Smith, Taylor Tuck, Nia
Oden, Sarah Livingston, Taylor Gleason and Jacqui
Grant,
Plaintiff(s)
v.
The Board of Trustees of the University of Illinois
Urbana-Champaign, a Body Politic and Corporate,
Mike Thomas, Matt Bollant and Mike Divilbiss,
Defendant(s)
)
)
)
)
)
)
)
)
)
)
)
)
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
2:15-cv-02146-CSB-EIL # 1-3
Page 2 of 2
; or
I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)
, who is
; or
; or
Other (specify):
.
My fees are $
0.00
Date:
Servers signature
Servers address
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2:15-cv-02146-CSB-EIL # 1-4
Page 1 of 2
E-FILED
CentralDistrict
Districtof
of__________
Illinois
__________
Amarah Coleman, Alexis Smith, Taylor Tuck, Nia
Oden, Sarah Livingston, Taylor Gleason and Jacqui
Grant,
Plaintiff(s)
v.
The Board of Trustees of the University of Illinois
Urbana-Champaign, a Body Politic and Corporate,
Mike Thomas, Matt Bollant and Mike Divilbiss,
Defendant(s)
)
)
)
)
)
)
)
)
)
)
)
)
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
2:15-cv-02146-CSB-EIL # 1-4
Page 2 of 2
; or
I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)
, who is
; or
; or
Other (specify):
.
My fees are $
0.00
Date:
Servers signature
Servers address
Save As...
Reset