Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 1 of 21

IN THE UNITED STATES DISTRICT COURT

·- f'i .'1 • '- i,) '''I'

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

i.i Ii",,, - (', <' , -~,

.,

I

Crystal Wilkes, Sharon Hollister and Tonya Townsend individually and on behalf of a class,
Plaintiffs
vs.
MICHAEL SHEAHAN, SHERIFF OF COOK COUNTY, in his official capacity,
Defendant

)

)
) )

Ole 1592

)

)

No.

)

)

JUDGE

) MAGISTRATE

l )

MAGISTRATE JUDGE ASHMAN

l DOCKETED

MAR 08 2001

COMPLAINT

Now comes the Plaintiffs, by and through their attorney,

Thomas G. Morrissey, Ltd., and Robert H. Farley,Jr.Ltd.,and

complain of the Defendant as follows:

INTRODUCTION

1.

The plaintiffs in this case are currently pretrial

detainees at the Cook County Department of Corrections ("Jail").

Each plaintiff is also a member of the class in Gary v. Sheahan,

No. 96 C 7294, {Coar J.) where the Court found the Sheriff's policy

and practice of strip searching female inmates upon returning to

the Jail from Court after there was a judicial determination that

there was no longer a basis for their detention, other than to be

processed for release was unconstitutional.

2.

As pretrial detainees at the Jail, plaintiffs were

initially strip searched upon admission to the Jail, and have been

and in the future will be strip searched after returning from

1

Case 1:01-cv-01592 Document 1 Filed 03/07/200I 1I Page 2 of 21

court appearances and during random strip searches pursuant to the

policies and practices at the Jail.

3.

Plaintiffs, as representatives of a class seeking

injunctive relief, are not challenging the need to conduct strip

searches at the Jail but rather maintain that the strip searches

are unreasonable because the strip searches are conducted in an

abusive fashion by the Sheriff, are highly intrusive due to the

manner and locations of the searches, and afford no privacy to the

women being searched.

JURSIDICTION

4. This is a Civil Action for injunctive relief to redress

deprivations under color of law of rights, privileges, and

immunities secured under the Fourth, Eighth, and Fourteenth

Amendments to the united States Constitution, and Title 42 U.S.C.

Sections 1983 and 1988.

CLASS ACTION ALLEGATIONS

S.(a) Plaintiffs bring this action as a class action pursuant

to Rule 23(b)(2) of the Federal Rules of Civil Procedure.

(b) The Class consist of all female persons who have been and

in the future will be strip searched upon admission to the Jail,

after returning from court appearances and during random strip

searches pursuant to the policies and practices at the Jail.

C The class is so numerous that joinder of all persons is

impracticable. The practice and policy at the Jail is to strip

search all female inmates when admitted to the Jail, upon their

return to the Jail from Court and during random strip searches.

2

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 3 of 21
Plaintiffs believe that the class probably numbers well over 1,000 female inmates.
(d) Plaintiffs will fairly and adequately protect the interest of all class members as they are members of the class and their claims are typical of the claims of all class members. Each of the plaintiffs is incensed at the treatment accorded the class members and will aggressively pursue the interests of the entire class. Plaintiffs' interest in obtaining injunctive relief for the violations of constitutional rights and privileges are consistent with and not antagonistic to those of any person within the class.
(e) The prosecution of separate actions by individual members of the class would create a risk of inconsistent or varying adjudications with respect to individual members of the class which would establish incompatible standards of conduct for the party opposing the class.
FACTS AND PARTIES 6. Plaintiff Crystal Wilkes is a citizen of the United States and resident of the State of Illinois. Since October 17,2000, Ms. Wilkes has been an inmate at the Cook County Department of Corrections, awaiting trial on a felony charge. Her next court date is set for March 23,2001. 7. Plaintiff Sharon Davis Hollister is a citizen of the United States and a resident of the State of Illinois. Since October 19,2000, Ms. Hollister has been an inmate at the Cook County Department of Corrections, awaiting trial on a felony charge. Her next court date is March 20,2001.
3

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 4 of 21
8. Plaintiff Tonya Townsend is a citizen of the United States and a resident of the State of Illinois. Since February 15,2001, Ms.Townsend has been an inmate at the Cook County Department of Corrections, awaiting trial on a felony charge. Her next court date is March 15,2001.
9. Defendant MICHAEL SHEAHAN (Sheahan) is an elected county official whose duties include implementing and executing policies concerning the operation of the Cook County Jail (Jail) pursuant to 55 ILCS 5/3-15003. At all times relevant hereto, Sheahan was acting under color of law.
10. On February 15,2001, plaintiff Townsend was taken into ·custody of the Sheriff's Office at the Jail and placed in a bullpen in the Receiving Area of the Jail with approximately 38 other women.
11. During the time period the plaintiff was in this bullpen, the canine unit entered the bullpen and the handlers for the dogs informed the women that the dogs would attack and bite the women if they detected any contraband. The dogs were then unleashed by the guards and proceeded to sniff and search each female inmate.
12. Plaintiff and the other women in the bullpen were then escorted by three or four female guards to a gymnasium area where the strip search was conducted. The gym is an open area with a balcony. It is not uncommon for male guards to enter the gym unannounced during strip searches.
13. Upon entering the gym, the plaintiff and the other women were ordered to forms lines and rows with four inmates to a line.
4

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 5 of 21

Pursuant to the standard policy and practice of the Sheriff, the

plaintiff was required to submit to the following strip search:

(A) The plaintiff was ordered to remove all her clothing;

(B) After removing all her clothing, she was required to

open her mouth, lift her breast, and to run her hands through her

hair;

(e) While naked, the plaintiff was required to spread her

buttock and bend and squat three times while coughing. Due to the

fact that some of the women were unable to "properly· perform this

task, the plaintiff was required to repeat the process nine times.

14.

At the time of the strip search, Ms. Townsend was on

her menstrual cycle. Regardless of this fact, she was required to

remove her pad and perform the above stated strip search with no

protection. At least two other women in the group were also on

their menstrual cycle, and as a result the plaintiff saw blood

running down their legs on to the floor of the gym. When the strip

searches were completed, these women were yelled at the by the

guards to clean up their blood.

15. The strip searches were conducted under conditions which

were unhealthy and unsanitary. Two of the women were sick and

vomiting, presumable from withdrawal symptoms. There was a strong,

nauseous odor in the gym during the strip search which was

extremely unpleasant. The guards made frequent derogatory remarks

about the lack of hygiene of the women and called them whores and

bitches.

16. Plaintiff saw one of the guards violently kick and pull

5

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 6 of 21

up one of the women who was sick and lying on the floor of gym.

17.

Since entering the Jail, Plaintiff Townsend has been

subjected to one other strip search in the day area of the tier under circumstances similar to the situations described in

paragraphs 13-16.

18. On October 17,2000, Plaintiff Crystal Wilkes was taken

into custody of the Sheriff's Office at the Jail and placed in a

bullpen in the Receiving Area of the Jail with approximately 40

other women.

19.

Subsequently, Plaintiff Wilkes was moved into another

bullpen room with other female inmates. One of the walls in this

room was made of glass which provided no privacy. This room is

situated in an area with other similar rooms and there are cameras

which are positioned to observe the inmates. The glass wall of the

room looks out onto a hallway. This hallway is frequently traversed

by male guards and male inmates.

20. The bullpen area used to strip search Plaintiff Wilkes

was filthy. The toilet was overflowing, there was urine, human

excrement, food particles and paper on the floor. The smell of the

bullpen was so bad it made the plaintiff nauseous.

21.

During the strip search, the guards called the women

derogatory names such as bitches and whores. Women who were

overweight or had large breast were singled out by the guards and

required to lift the folds of their stomachs and breasts.

22.

While the plaintiff was being strip searched, she

observed a male guard enter the area where the women were being

6

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 7 of 21
searched. 23. One of the women being strip searched was vomiting during
the strip search process. Afterwards she laid on the floor of the bullpen until a guard kicked her and told her to get her "ass" up.
24. During her period of incarceration, Plaintiff Wilkes has been strip searched approximately ten times. These searches have been conducted in a manner similar to what has been described in paragraphs 21 through 23 when she has returned to the Jail after a court appearance or during random strip searches on her tier. The locations of the searches include the gym, clothing room and day area of her tier.
25. On October 19,2000, Plaintiff Sharon Hollister was taken into custody of the Sheriff's Office at the Jail and placed in a bullpen in the Receiving Area of the Jail.
26. Plaintiff Hollister and the other women in the bullpen were then escorted by three or four female guards to a gymnasium area where the strip search was conducted.
27. Ms. Hollister was then strip searched under the same conditions as previously described in paragraphs 13 through 23.
28. During her period of incarceration, Plaintiff Hollister has been strip searched approximately nine times. These searches have been conducted in a manner similar to what has been described in paragraphs 13 through 24 when she returned to the Jail after a court appearance or during random strip searches on her tier. The locations of the searches include the gym, clothing room and day area of her tier.
7

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 8 of 21
COUNT ONE 1-28. Plaintiffs reallge paragraphs 1-28 above as paragraphs 1-28 of Count I. 29. At all times relevant to this complaint, the defendant, as Sheriff of Cook County has the duty to establish procedures and policies and to train deputy sheriffs and C.C.D.O.C. employees to prevent unreasonable body searches of individuals and to prevent strip searches of female inmates from being performed in an abusive fashion, under conditions which are unsanitary and provide no protection of privacy to the women during .the searches. 30. Defendant SHEAHAN knew or should have known that female inmates are subjected to highly intrusive strip searches which afford no privacy to female inmates and which are conduct under unsanitary, filthy conditions, and are carried out by his deputies in an abusive manner. 31. Defendant SHEAHAN instituted, sanctioned, and approved the following policies, practices, customs, and procedures regarding the strip searching of female individuals who are in the custody of the Cook County Department of Corrections;
A. Female inmates are routinely strip searched upon entry to the Jail, after returning from court appearances and during random strip searches in the housing divisions.
B. The canine unit at the Jail makes random inspections of the newly admitted inmates to the Jail prior to and at
8

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 9 of 21
the time while women are in the process of being strip searched. The guard dogs enter the bullpens where the female inmates are held without restraints and proceed to sniff and search female inmates for contraband, after the Sheriff deputies inform the women that the dogs will attack and bite the women if drugs are detected.
c. The strip searches are conducted in groups of between 15
and 40 inmates which affords no privacy to the women. D. The areas in which the strip searches are administered by
the Sheriff are dirty, foul smelling and subject to viewing by male guards and male inmates. At times the strip searches are conducted in bullpens located in the Receiving area of the Jail. The walls of these bullpens are made of glass and provide no privacy. The glass wall of the room looks out onto a hallway. The hallway is frequently traversed by male and female C.C.D.O.C. employees. (Exhibit A, p.1S) E. The foul smell and odor in the areas where the women are strip searched is so retched and putrid that even the guards conducting the searches admit that it makes them nauseous and has caused one to almost vomit. (Exhibit A. p. 15; Exhibit B. p.17) F. The physical conditions under which the women are strip searched are unclean and unsanitary. In the bullpen areas, the toilets are frequently overflowing, there is urine, human excrement, blood, food and paper on the
9

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 10 of 21
floors. G. Pursuant to the standard policy and practice of the
Sheriff, the plaintiff was required to submit to the following strip search under the above conditions: (1) The women are order to get in lines containing three or four inmates arms length apart; (2) The women are then ordered to remove all of their clothing; (3) After removing all their clothing, the women are required to open their mouths, lift their breasts, and to run their hands through their hair. H. Regardless of whether women are on their menstrual cycle, they are required to remove their sanitary napkin and perform the strip search without any protection. Frequently women on their menstrual cycle are exposed to the embarrassment of having blood running down their legs and onto the floor. (Exhibit A.p.16). In addition, the other women in the group are subjected to potential infection from these bodily fluids. I. During the strip searches of the female inmates, the guards frequently call the women derogatory names and single out women that are overweight or who have large breasts to lift the folds of their stomachs and breasts. 32. The Sheriff failed to establish appropriate procedures and practices to ensure that female inmates are not subjected to unreasonable body searches.
10

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 11 of 21

33. The Sheriff failed to properly train and supervise the

deputy sheriffs and C.C.D.O.C. employees responsible for conducting

body searches of inmates to prevent unreasonable body searches.

34. The strip search of plaintiffs under the above describe

abusive conditions constitutes deliberate indifference to the

rights of the plaintiffs in violation of the Fourth, Eighth and

Fourteenth Amendments to the u.S. Constitution.

36.

As a direct and proximate result of the Sheriff's

policies, practices and procedures, in his official capacity, the

defendant subjected the Plaintiffs and members of the class to

unreasonable body searches which were demeaning, dehumanizing,

undignified, humiliating, terrifying, unpleasant, embarrassing,

repulsive, signifying degradation and submission.

37.

Unless immediately, preliminarily and permanently

enjoined from continuing to subject females inmates from abusive

strip searches defendant will continue to engage in the willful,

wanton and deliberate violation of the constitutional rights of

females, and plaintiffs and members of the class will continue to

suffer gross violations of their constitutional rights and gross

indignities, each of which constitutes irreparable injury for which

plaintiffs have no adequate remedy at law.

WHEREFORE, plaintiffs PRAY that this Court enter an order:

1.

Finding that this action should proceed as a class

action pursuant to Rule 23(b) (2) ,of the Federal Rules of Civil

Procedure~

2. Preliminarily and permanently restraining, enjoining and

11

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 12 of 21
prohibiting defendant from undertaking, enforcing, maintaining or adopting any policies, procedures, practices or acts by which any
female inmate is subjected to an abusive strip search without
consideration for the privacy interest of the female and the
conditions under which the strip search is conducted.
3. Awarding plaintiffs and the class their costs and attorney's fees under Title 42 U.S.C. Sect. 1988.
('/'~) jI/V\/....-//7
. Plaintiffs' Attorneys
Thomas G. Morrissey, Ltd. Robert H. Farley, Jr., Ltd. 10249 S. Western Ave.
Chicago, n. 60643
(773)-233-7900
12

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 13 of 21

1

1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

2

EASTERN DIVISION

3

4

KENYA GARY and TANIA HAYES,

Individually and on behalf

5

of a class,

6

Plaintiffs,

7

vs.

8

MICHAEL SHEAHAN, Sheriff

of Cook County, in his

9

individual official

capacity,

10

Defendant.

11

) ) ) ) ) )
)No. 96 C 7294
) ) ) ) ) ) )

12

The Discovery Deposition of PATSY

13

MOODY, taken before SHERLENE BRANSCOMB, a Certified

14

Shorthand Reporter and Notary Public, pursuant to the

15

Federal Rules of Civil Procedure for the United

16

States District Courts, pertaining to the taking of

17

discovery depositions, at 2700 South California,

18

Division 4, Chicago, Illinois, at the hour of 9:00

19

a.m., on the 10th day of April, A.D., 1998.

20

21

22

23

24

TOOMEY REPORTING (312) 853-0648

. - '/ ,-ll /:;! f A

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 14 of 21

15

did you hear any female court return make sexual,

suggestive comments in the nature of you're pretty or

I want you to be my girlfriend or one inmate to

another?

5

MR. BEIRNE: Objection to the form of the

6

question as compound, vague, and ambiguous.

7

THE WITNESS: No.

8

BY MR. FARLEY:

9

Q Have you been given the job or

10

responsibility for cleaning the bull pen area in the

11

female receiving room?

12

A No.

13

Q When you go over to pick up the female

14

court returns, how does the female receiving bull pen

15

area smell?

16

MR. BEIRNE: Objection. Vague.

17

MR. FARLEY: You can answer.

18

THE WITNESS: Smelly.

19

BY MR. FARLEY:

20

Q Does the smell ever reach a point of making

21

you nauseous?

22

A

Yes.

23

Q And during those times when the smell made

24

you nauseous, what was the physical condition or

TOOMEY REPORTING (312) 853-0648

I I
Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 15 of 21

16

1

appearance of the bull pen?

2

MR. BEIRNE: Objection to the question as

3

vague and ambiguous. You can answer.

4

THE WITNESS: Dirty.

5

BY MR. FARLEY:

6

Q

As to dirty, what do you mean by dirty?

7

A

Toilet paper being on the floor.

8

Q And with respect to toilet paper on the

9

floor, did you observe what appeared to be blood on

10

the toilet paper or human waste?

11

A

No.

12

Q

When a woman is on her menstrual cycle and

13

she is required to bend and squat three times, were

14

there occasions where you observed blood running down

15

her legs?

16

A

Yes.

17

Q

And did you also observe blood on the tile

18

floor?

19

A

Yes.

20

Q

And do you know what happens to that blood

21

on the tile floor after the strip search procedure?

22

A

We give them toilet paper so that they can

23

clean it up.

24

Q

Is the female given anything else besides

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 16 of 21

17

toilet paper to clean up the blood off the floor?

2

A No.

3

Q During the strip search procedures, has a

4

female court return -- have you heard a female court

5

return voice concerns about other inmates being HIV

6

positive or having AIDS?

7

A

Yes.

8

Q And when you observed the blood on the

9

floor running down the inmate's legs, they were --

10

the inmate was completely naked, correct?

11

A Yes.

12

Q And with respect to the female court return

13

voicing concerns about other females being HIV

14

positive or AIDS, was that during a strip search

15

procedure?

16

A

Yes.

17

Q I apologize if I asked this question, but

18

things flow together.

19

Are there -- do you have any knowledge

20

as to whether there is cameras or monitors in the

21

female receiving area, the bull pen area, where the

22

strip search procedures take place?

23

A

No.

24

Q

So no as to you have no knowledge?

TOOMEY REPORTING (312) 853-064R

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 17 of 21

18

1

A

Right. I have no knowledge.

2

Q Now, in the female receiving area there is

3

a -- is it correct to say that there is a door that

4

separates four bull pens from another four bull pens

5

in the female receiving area?

6

A

Yes.

7

Q And on occasions when you have been present

8

during the strip searching of the female court

9

returns, have there been occasions when some male or

10

males inadvertently walked ahrough that door during a

11

strip search procedure?

12

A

Yes.

13

Q

And how often would that occur?

14

MR. BEIRNE: Objection to the form of the

15

question as vague. You can answer if you know.

16

BY MR. FARLEY:

17

Q How often would that occur with respect to

18

men inadvertently walking through that door during a

19

strip search?

20

MR. BEIRNE: Same objection.

21

MR. FARLEY: You can answer.

22

THE WITNESS: Not that often.

23

BY MR. FARLEY:

24

Q

In the bull pen where the women are strip

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 18 of 21

1

.

1

,

2

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF Illinois
EASTERN DIVISION

3

4

KENYA GARY and TANIA HAYES,

Individually and on behalf

5

of a class,

6

Plaintiffs,

7

vs.

8

MICHAEL SHEAHAN, Sheriff

of Cook County, in his

9

individual official

capacity,

10

Defendant.

11

) ) ) ) ) )
)No.
) ) ) ) ) ) )

96 C 7294

12

The Discovery Deposition of WANDA

13

SPARKS, taken before SHERLENE BRANSCOMB, a Certified

14

Shorthand Reporter and Notary Public, pursuant to the

15

Federal Rules of Civil Procedure for the United

,

16

States District Courts, pertaining to the taking of

17

discovery depositions, at 2700 South CaliIorllia,

18

Division 4, Chicago, Illinois, at the hour of 9:00

19

a.m., on the 10th day of April, A.D., 1998.

20

21

22

23

24

TOOMEY REPORTING (312) 853-0648

Case 1:01-cv-01592 Document 1 Filed 03/07/200I1I Page 19 of 21

17

A

It's awful.

Q

And by awful, what type of smell?

3

A

I'm sure it would be the odor that's left

4

there from the strip search normally. Once we get

5

there, it's not -- where the women are in the one

6

bull pen you have the stench coming from. We usually

7

move them to an empty bull pen maybe 20 at a time,

8

depending on how many we have to do the search.

9

Once we are done with that 20, the stench is there

10

now. So it's a really awful odor at time. So bad I

11

have almost vomited.

12

Q

Have there been occasions when you have

13

gone to the female receiving area in RCDC where the

14

floors appear to have dry blood on it?

15

A

I haven't seen any.

16

Q When you would arrive down to RCDC to pick

17

up the female court returns, would they generally be

18

ln one bull pen?

19

A

Sometimes.

20

Q

You indicated that some of the inmates are

21

brought out of a single bull pen to another bull pen

22

to be strip searched?

23

A

Yes, over in receiving.

24

Q

How many would be brought out at one time?

TOOMEY REPORTING (312) 853-0648

Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 20 of 21

JS 44 (Rev. 12/96)

CIVIL COVER SHEET

The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as requirec: by law. except as provided by looal rules of court. This form., approved by the Judicial Conference of the Unfted States in September 1974, is required for the US4 of the Cieri< of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

I. (a) PLAINTIFFS (f<ySlU

0/t.../ielj

~1,):H:'iV /-Ioit..iSTe

DEFENDANTS

/!hA.d rtJ)v)l~ ral..vJV.5<"Jv'41

( oult (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
(EXCEPT IN U.S. PLAINTIFF CASES)

(c) ATTORNEYS(FIRMNAME.AOORESS.ANDTELEPHONENUMBER) _

MAR 0 8

TA"W1J4~ 6. /viuic"!2t',>:;-e'l "c..Tdf:

(0,).'19 !:. W~S{.-Ckiv 14u.e

· JU

LA Ie Al, (>. J:t' 6 o{;L/

~-

IS JOHN W DARRAHKlAOrSTRATE JUDGE ASHMA

II. BASIS OF JURISDICTION

(PLACE AN "X' IN ONE BOX ONLY)

0' U.S. Government Plaintiff

~ral Question (U.S. Govemment Not a Party)

III. CITIZENSHIP OF PRINCIPAL PARTIESIPLACEAN'X'INONEeoxFORPlAlN11f

(For Diversity Cases Only)

AND ONE BOX FOR DEFENDANT)

PTF DEF

PTF lIEF

Citizen of This State

01 01 Incorporated or Principal Place 04 0< of Business In This State

o 2 U.S. Govemment
Defendant

04 Diversfty (Indicate Citizenship of Parties in Item III)

Citizen of Another State 0 2 02
Citizen or Subject of a 0 :3 0 :3 Foreign Country

Incorporated and Principal Place 0 5 0 5 of Business In Another S_

Foreign Nation

06 05

IV. ORIGIN
J&(6riginal Prcoeeding

0 2 Removed from State Court

(pLACE AN "X" IN ONE BOX ONLy)

0 3 Remanded from o 4 Reinstated or

Appellate Court

Reopened

Transferred from o 5 another district
(specfty)

o 6 Multidistrict
Utigation

Appeal 10 DisIric JUdQetrom
o 7 Magistrate
Judgment

V. NATURE OF SUIT (PLACE AN ")(" IN ONE BOX ONLy)

CONTRACT
0110 Insurance
o0120 MarIne 130 Miller Act
o 140 Negotiable Instrument o 150 Recovery of OI/erpayment
& EnfOrcement of Judgment
o lS1 Medicare Act o 152 Re~oI Defaulted
Student ans (Excl. Veterans)
o 153 Recovery of Overpayment of Veteran·s Benefits
o 160 Stockhoiders'Suits o 190 Other Contract o 195 Contract Product LiabUlly
REAL PROPERTY
o 210 Land Condemnation o 220 Foreclosure o 230 Rent Lease & Ejectment o 240 Torts to Land o 245 Ton Product UabUIty o 290 All Other Real Property

TORTS

FORFEITURE/PENALTY

PERSONAL INJURY
o 310 Airplane o 315 Airplane Product
liability
o 320 Assault. Libel & Slander
o 330 Federal Employers' Liability
o 340 Marine o 345 Marine Product
Uability
o 350 Motor Vehicle o 355 Motor Vehicle
Product liability
o 360 Other Personal Injury

PERSONAL INJURY
o 362 Personal Injury Meci. Malpractice
o 365 Personal Injury Product Liability
o 368 Asbestos Personal Injury Product Liability
PERSONALPROPERTV
o 370 Other Fraud o 371 Truth In Lending o 380 Other Personal
Property Damage
o 385 Property Damage Product Liablllty

CIVIL RIGHTS
0441 VOting
o 442 Employment o 443 Houslng/
Accommodations
~elfare
o Other CMI Rights

PRISONER PETITIONS
o 510 Motions to Vacate Sentence
o HABEAS CORPUS: 530 General
o S35 Death Penalty o S40 Mandamus & Other o S50 Civil Rights o S55 Prison COndition

o 610 Agriculture o 820 Other Food & Drug o 625 Drug Related Seizure
of Property 21 USC 881
o 630 uquor LaWS o0' 640 R.R. & Truck
650 Airline Regs.
o 660 Occupational·
Safety/Health 0690 Other
LABOR
o 710 Fair Labor Standards Act
o 720 Labor/Mgml. Relations
o 730 LabOT/Mgmt Reporting & Disclosure Act
o 740 Railway Labor Act
o 790 Other Labor Lltlgatlon
o 791 Empl. Ret. Inc. security Act

BANKRUPTCY
o 422 Appeal 28 USC 158 o 423 Withdrawal
28 USC 157
PROPERTY RIGHTS
o 820 Copyrights o 830 Patent o 840 Trademark
SOCIAL SECURITY
o 861 H1A (1:395ff) o 862 Black Lung (923) o 863 DIWC/DIWW (405(g}) o 864 SSID Tille XVI o 865 RSI (405(g))
FEDERAL TAX SUITS
o 870 Taxes (U.S. Plaintiff or Defendant)
o 871 IRS - Third Party 26 USC76D9

VI. CAUSE OF ACTION (CITE THE U.S. CMl STATUTE UNDER WHICH YOU ARE FlUNG AND WRITE BRIEF STATEMENT OF CAUSE.

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Case 1:01-cv-01592 Document 1 Filed 03/07/2001 Page 21 of 21

UNITED STATESDISTRICTCOUnT
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 Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 2 of 10

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

Crystal Wilkes, Sharon Hollister

Tonya Townsend, Sherrille Maynie,

Marvella Everett, and Kristine Ricks

)

)

Plaintiffs

)

)

vs.

)

)

MICHAEL SHEAHAN,

)

SHERIFF OF COOK COUNTY,

)

in his official capacity,

)

)

Defendant

)

I~K1CE'D

No.

01

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iv1ICI-iAEL
ti51Jr2,U. S.

DWI''_-;roDl,\,,(,:-Y,~,~j")"IC':N_uSunr

/ JUDGE

~

MAGISTRATE

AMENDED COMPLAINT Now comes the Plaintiffs, by and through their attorneys, Thomas G. Morrissey, Ltd., and Robert H. Farley,Jr.Ltd.,and complain of the Defendant as follows:
1. The plaintiffs in this case are former pretrial detainees
at the Cook County Department of Corrections ("Jail"). As pretrial detainees at the Jail, plaintiffs were initially strip searched upon admission to the Jail, and after returning from court appearances and during random strip searches pursuant to the policies and practices at the Jail.
2. This is a Civil Action to redress deprivations under color
of law of rights, privileges, and immunities secured under the Fourth, Eighth, and Fourteenth Amendments to the united States Constitution, and Title 42 U.S.C. Sections 1983 and 1988.

1

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 3 of 10
3. Plaintiff Crystal Wilkes is a citizen of the United States and resident of the State of Illinois. Ms. Wilkes was an inmate at the Cook County Department of Corrections.
4. Plaintiff Sharon Davis Hollister is a citizen of the United States and a resident of the State of Illinois. Ms. Hollister was an inmate at the Cook County Department of Corrections.
5. Plaintiff Tonya Townsend is a citizen of the United States and a resident of the State of Illinois. MS.Townsend was an inmate at the Cook County Department of Corrections.
6. Plaintiff Sherille Maynie is a citizen of the United States and resident of the State of Illinois. She was admitted to the Jail on March 19,2001 and released on May 2,2001.
7. Plaintiff Kristine Ricks is a citizen of the United States and a resident of the State of Illinois. She was admitted to the Jail on May 21,2000 and released on May 22,2000
8. Plaintiff Marvella Evertt is a citizen of the United States and a resident of the State of Illinois. She was an inmate at the Cook County Department of Corrections.
9. Defendant MICHAEL SHEAHAN (Sheahan) is an elected county official whose duties include implementing and executing policies concerning the operation of the Cook County Jail (Jail) pursuant to 55 ILCS 5/3-15003. At all times relevant hereto, Sheahan was acting under color of law.
10. On February 15,2001, plaintiff Townsend was taken into custody of the Sheriff's Office at the Jail and placed in a bullpen in the Receiving Area of the Jail with approximately 38 other
2

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 4 of 10 ".

women.

11. During the time period the plaintiff was in this bullpen,

the canine unit entered the bullpen and the handlers for the dogs

informed the women that the dogs would attack and bite the women if

they detected any contraband. The dogs were then unleashed by the

guards and proceeded to sniff and search each female inmate.

12. Plaintiff and the other women in the bullpen were then

escorted by three or four female guards to a gymnasium area where

the strip search was conducted. The gym is an open area with a

balcony. It is not uncommon for male guards to enter the gym

unannounced during strip searches.

13. Upon entering the gym, the plaintiff and the other women

were ordered to forms lines and rows with four inmates to a line.

Pursuant to the standard policy and practice of the Sheriff, the

plaintiff was required to submit to the following strip search:

(A)

The plaintiff was ordered to remove all her clothing;

(B) After removing all her clothing, she was required to

open her mouth, lift her breast, and to run her hands through her

hair;

(e) While naked, the plaintiff was required to spread her

buttock and bend and squat three times while coughing. Due to the

fact that some of the women were unable to "properly" perform this

task, the plaintiff was required to repeat the process nine times.

14.

At the time of the strip search, Ms. Townsend was on

her menstrual cycle. Regardless of this fact, she was required to

remove her pad and perform the above stated strip search with no

3

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 5 of 10

protection. At least two other women in the group were also on

their menstrual cycle, and as a result the plaintiff saw blood

running down their legs on to the floor of the gym. When the strip

searches were completed, these women were yelled at the by the

guards to clean up their blood.

15. The strip searches were conducted under conditions which

were unhealthy and unsanitary. Two of the women were sick and

vomiting, presumable from withdrawal symptoms. There was a strong,

nauseous odor in the gym during the strip search which was

extremely unpleasant. The guards made frequent derogatory remarks

about the lack of hygiene of the women and called them whores and

bitches.

16. Plaintiff saw one of the guards violently kick and pull

up one of the women who was sick and lying on the floor of gym.

17.

Since entering the Jail, Plaintiff Townsend has been

subjected to one other strip search in the day area of the tier

under circumstances similar to the situations described in

paragraphs 13-16.

18. On October 17,2000, Plaintiff Crystal Wilkes was taken

into custody of the Sheriff's Office at the Jail and placed in a

bullpen in the Receiving Area of the Jail with approximately 40

other women.

19.

plaintiff Wilkes was strip searched under conditions

which provided no privacy.

20. On October 19,2000, Plaintiff Sharon Hollister was taken

into custody of the Sheriff's Office at the Jail and placed in a

4

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 6 of 10
bullpen in the Receiving Area of the Jail. 21. Plaintiff Hollister was subsequently strip searched under
conditions which provided no privacy. 22. Plaintiffs Sherrile Maynie, Kristine Ricks, and Marvella
Everett were also strip searched while incarcerated at the Jail under conditions which provided no privacy.
COUNT ONE
1-22. Plaintiffs reallge paragraphs 1-22 above as paragraphs 1-22 of Count I.
23. At all times relevant to this complaint, the defendant, as Sheriff of Cook County has the duty to establish procedures and policies and to train deputy sheriffs and C.C.D.O.C. employees to prevent unreasonable body searches of individuals and to prevent strip searches of female inmates from being performed in an abusive fashion, under conditions which are unsanitary and provide no protection of privacy to the women during the searches.
24. Defendant SHEAHAN knew or should have known that female inmates are subjected to highly intrusive strip searches which afford no privacy to female inmates and which are conduct under unsanitary, filthy conditions, and are carried out by his deputies in an abusive manner.
25. Defendant SHEAHAN instituted, sanctioned, and approved the following policies, practices, customs, and procedures regarding the strip searching of female individuals who are in the custody of the Cook County Department of Corrections1
5

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 7 of 10
A. Female inmates are routinely strip searched upon entry to the Jail, after returning from court appearances and during random strip searches in the housing divisions.
B. The canine unit at the Jail makes random inspections of the newly admitted inmates to the Jail prior to and at the time while women are in the process of being strip searched. The guard dogs enter the bullpens where the female inmates are held without restraints and proceed to sniff and search female inmates for contraband, after the Sheriff deputies inform the women that the dogs will attack and bite the women if drugs are detected.
c. The strip searches are conducted in groups of between 15
and 40 inmates which affords no privacy to the women. D. The areas in which the strip searches are administered by
the Sheriff are dirty, foul smelling and subject to viewing by male guards and male inmates. E. The foul smell and odor in the areas where the women are strip searched is so retched and putrid that even the guards conducting the searches admit that it makes them nauseous and has caused one to almost vomit. F. The physical conditions under which the women are strip searched are unclean and unsanitary. In the bullpen areas, the toilets are frequently overflowing, there is urine, human excrement, blood, food and paper on the floors. G. Pursuant to the standard policy and practice of the
6

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 8 of 10
· -.
Sheriff, the plaintiff was required to submit to the following strip search under the above conditions: (1) The women are order to get in lines containing three or four inmates arms length apart; (2) The women are then ordered to remove all of their clothing; (3) After removing all their clothing, the women are required to open their mouths, lift their breasts, and to run their hands through their hair. H. Regardless of whether women are on their menstrual cycle, they are required to remove their sanitary napkin and perform the strip search without any protection. Frequently women on their menstrual cycle are exposed to the embarrassment of having blood running down their legs and onto the floor. In addition, the other women in the group are subjected to potential infection from these bodily fluids. I. During the strip searches of the female inmates, the guards frequently call the women derogatory names and single out women that are overweight or who have large breasts to lift the folds of their stomachs and breasts. 26. The Sheriff failed to establish appropriate procedures and practices to ensure that female inmates are not subjected to unreasonable body searches. 27. The Sheriff failed to properly train and supervise the deputy sheriffs and C.C.D.O.C. employees responsible for conducting body searches of inmates to prevent unreasonable body searches.
7

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 9 of 10 , -.

28. The strip search of plaintiffs under the above describe

abusive conditions constitutes deliberate indifference to the

rights Qf the plaintiffs in violation of the Fourth, Eighth and
Fourteenth Amendments to the u.s. Constitution.

29.

As a direct and proximate result of the Sheriff's

policies, practices and procedures, in his official capacity, the

defendant subjected the Plaintiffs and members of the class to

unreasonable body searches which were demeaning, dehumanizing,

undignified, humiliating, terrifying, unpleasant, embarrassing,

repulsive, signifying degradation and submission. The plaintiffs

suffered great emotional pain, humiliation and embarrassment.

WHEREFORE, plaintiffs pray that this Court enter an order

awarding monetary damages to plaintiffs in an amount in excess of

fifty thousand dollars. In addition, award the plaintiffs and

members of the class their costs and attorney's fees under Title 42

U.S.C. Sect. 1988.

Thomas G. Morrissey, Ltd. Robert H. Farley, Jr., Ltd. 10249 S. Western Ave. Chicago, II. 60643 (773)-233-7900
8

Case 1:01-cv-01592 Document 23 Filed 07/05/2001 Page 10 of 10
· '.

CERTIFICATE OF SERVICE

I, Thomas G, Morrissey" an attorney, deposes and states that he served a copy the

\;WO foregoing Amended Complaint on July

1 before 5:00 p,m,

Patrick Driscoll, Jr. Thomas Lyons Thomas Burnham Michael Jacobs Assistant State's Attorneys 500 Richard J. Daley Center Chicago, II. 60602 312-603-3600

Thomas G. Morrissey

Thomas G, Morrissey Ltd. Robert H. Farley,Jr. 10249 S. Western Ave. Chicago, II 60643; (773) 233-7900

 
 CM/ECF LIVE, Ver 2.5 - U.S. District Court, Northern Illinois - Docket Report

Page 1 of 5

ASHMAN, TERMED
United States District Court Northern District of Illinois - CM/ECF LIVE, Ver 2.5 (Chicago)
CIVIL DOCKET FOR CASE #: 1:01-cv-01592

Wilkes, et al v. Sheahan Assigned to: Hon. John W. Darrah Demand: $0 Cause: 42:1983 Civil Rights Act Plaintiff Crystal Wilkes
Plaintiff Sharon Hollister
Plaintiff Tonya Townsend

Date Filed: 03/07/2001 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
represented by Thomas Gerard Morrissey Thomas G. Morrissey 10249 South Western Avenue Chicago, IL 60643 (312) 233-7900 Email: tgmlaw@ameritech.net LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert Hugh Farley, Jr. Robert H. Farley, Jr., Ltd. 1155 South Washington Naperville, IL 60540 (630) 369-0103 Fax: (630) 369-0195 Email: farleylaw@aol.com ATTORNEY TO BE NOTICED
represented by Thomas Gerard Morrissey (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert Hugh Farley, Jr. (See above for address) ATTORNEY TO BE NOTICED
represented by Thomas Gerard Morrissey (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Robert Hugh Farley, Jr. (See above for address)

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CM/ECF LIVE, Ver 2.5 - U.S. District Court, Northern Illinois - Docket Report

Page 2 of 5

Plaintiff Sherrille Maynie
Plaintiff Marvella Everette
Plaintiff Kristine Ricks
V. Defendant Michael Sheahan Sheriff of Cook County, in his official capacity as head of Sheriff of Cook County

ATTORNEY TO BE NOTICED
represented by Thomas Gerard Morrissey (See above for address) ATTORNEY TO BE NOTICED
represented by Thomas Gerard Morrissey (See above for address) ATTORNEY TO BE NOTICED
represented by Thomas Gerard Morrissey (See above for address) ATTORNEY TO BE NOTICED
represented by Michael David Jacobs Cook County State Attorney's Office 301 Richard J. Daley Center Chicago, IL 60602 (312) 603-3401 Email: mjacobs@cookcountygov.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Patrick T. Driscoll, Jr. Cook County State's Attorney 500 Richard J. Daley Center Chicago, IL 60602 (312) 603-6461 Email: pdrisco@cookcountygov.com ATTORNEY TO BE NOTICED
Paul Anthony Castiglione Cook County State's Attorney 300 Richard J. Daley Center Chicago, IL 60602 (312) 603-3362 Email: pcastig@cookcountygov.com ATTORNEY TO BE NOTICED
Thomas M. Burnham Cook County State's Attorney's Office 500 Richard J. Daley Center Chicago, IL 60602

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CM/ECF LIVE, Ver 2.5 - U.S. District Court, Northern Illinois - Docket Report

Page 3 of 5

Date Filed 03/07/2001
03/07/2001 03/07/2001 03/09/2001 03/09/2001 03/12/2001 03/12/2001 03/12/2001 03/13/2001 03/13/2001 03/14/2001 03/14/2001 03/14/2001 03/15/2001

(312) 603-5440

#

Docket Text

1 COMPLAINT (Exhibit) - Civil cover sheet - Appearance(s) of Thomas Gerard Morrissey and Robert Hugh Farley Jr. as attorney(s) for plaintiffs Crystal Wilkes, Sharon Hollister and Tonya Townsend (One Original and one copy summons(es) issued.) ( Documents: 1-1 through 1-3) (hp) (Entered: 03/08/2001)

RECEIPT regarding payment of filing fee paid; on 3/7/01 in the amount of $ 150.00, receipt # 1023380. (hp) (Entered: 03/08/2001)

7 MOTION by plaintiffs for temporary restraining order ; Notice (las) (Entered: 03/16/2001)

2 ATTORNEY APPEARANCE for defendant by Michael David Jacobs, Patrick T. Driscoll Jr., Paul Anthony Castiglione, Thomas M. Burnham. (mw) (Entered: 03/12/2001)

9 MOTION by plaintiffs to certify a class ; Notice (yap) (Entered: 03/19/2001)

3 MOTION by defendant to dismiss plaintiff's complaint ; Memorandum in support (Attachments); Notice (las) (Entered: 03/13/2001)

4 MOTION by defendant for leave to file a memorandum of law in excess of 15 pages (las) (Entered: 03/13/2001)

5 MEMORANDUM by plaintiffs in support of plaintiffs' application for temporary restraining order (Attachments) ; Notice (las) (Entered: 03/13/2001)

6 SUPPLEMENTAL authority by defendant in connection with plaintiff's proposed motion for a temporary restraining order; Notice. (yp) (Entered: 03/15/2001)

8 MINUTE ORDER of 3/13/01 by Hon. John W. Darrah : Plaintiffs' motion for temporary restraining order is granted [7-1]. Mailed notice. (las) (Entered: 03/16/2001)

SCHEDULE set on 3/14/01 by Hon. John W. Darrah : Preliminary injunction hearing set for 10:00 4/2/01 . Mailed notice (ldg) (Entered: 03/14/2001)

11 MOTION by plaintiffs' to file verifications instanter (Attachments). (vmj) (Entered: 03/22/2001)

12 RESPONSE by plaintiffs to defendant's motion to dismiss plaintiff's complaint [3-1] (Attachments). (vmj) (Entered: 03/22/2001)

10 MINUTE ORDER of 3/15/01 by Hon. John W. Darrah: Defendant's response to plaintiff's motion to certify a class [9-1] to be filed on or before 3/22/01. Plaintiff's reply to be filed on or before 3/28/01. Hearing

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CM/ECF LIVE, Ver 2.5 - U.S. District Court, Northern Illinois - Docket Report

Page 4 of 5

03/16/2001 03/19/2001 03/20/2001 03/21/2001 03/22/2001 03/22/2001 03/22/2001 03/26/2001 03/29/2001 04/06/2001 04/06/2001
04/12/2001 04/12/2001
04/26/2001

set for 4/2/01 at 10:00 a.m. [9-1]. Mailed notice (yap) (Entered: 03/19/2001)
SCHEDULE set on 3/16/01 by Hon. John W. Darrah : Status hearing set to 9:30 4/12/01 . Mailed notice (wah) (Entered: 03/16/2001)
15 EMERGENCY MOTION by plaintiffs to compel defendant to provide immediate access to the records sought in the notice to inspect (Attachments); Notice. (cem) (Entered: 03/26/2001)
16 MINUTE ORDER of 3/20/01 by Hon. John W. Darrah: Emergency motion to compel discussed on the record. No notice (cem) (Entered: 03/26/2001)
13 SECOND EMERGENCY MOTION by plaintiffs to compel (Attachments); Notice. (mw) (Entered: 03/23/2001)
SCHEDULE set on 3/22/01 by Hon. John W. Darrah : Preliminary injunction hearing set for 4/2/01 is striken and reset to 10:00 a.m. 5/7/01 . Mailed notice (ldg) (Entered: 03/23/2001)
14 EMERGENCY MOTION by defendant for leave to file documents which bear on plaintiffs' "emergency motion" (Attachments); Notice. (mw) (Entered: 03/23/2001)
17 RESPONSE by defendant to plaintiff's motion for class certification [91]; Notice. (yp) (Entered: 03/26/2001)
18 REPLY by plaintiffs to defendant's response to motion for class certification [17-1] (Attachments). (yp) (Entered: 03/27/2001)
19 TRANSCRIPT of proceedings for the following date(s): 3/14/01 before Honorable John W. Darrah. (maf) (Entered: 03/30/2001)
SCHEDULE set on 4/6/01 by Hon. John W. Darrah : Status hearing set for 4/12/01 is stricken and reset to 9:30 5/9/01 . Mailed notice (ldg) (Entered: 04/06/2001)
20 MOTION by plaintiffs to set a date for the deposition of Sheila Vaughan or in the alternative to allow Ms. Vaufhan testify out of turn at the preliminary injuction hearing (Attachments); Notice (las) (Entered: 04/16/2001)
SCHEDULE set on 4/12/01 by Hon. John W. Darrah : Settlement conference set for 11:30 4/26/01 . Mailed notice (ldg) (Entered: 04/12/2001)
21 MINUTE ORDER of 4/12/01 by Hon. John W. Darrah : Plaintiff's motion to set a date for the deposition of Sheila Vaughan [20-1] or in the alternative to allow Ms. Vaufhan to testify out of turn at the preliminary injuction hearing is granted [20-2]. Settlement conference set for 11:30 a.m. on 4/26/01. Mailed notice. (las) (Entered: 04/16/2001)
SCHEDULE set on 4/26/01 by Hon. John W. Darrah : Status hearing set to 9:30 5/10/01 . Settlement conference held. Preliminary injunction

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Page 5 of 5

05/10/2001 05/24/2001 05/29/2001 06/14/2001 06/25/2001
07/05/2001 07/05/2001 08/08/2001 08/13/2001 08/22/2001

hearing set for 5/7/01 is stricken. Mailed notice (ldg) (Entered: 04/26/2001)
SCHEDULE set on 5/10/01 by Hon. John W. Darrah : Status hearing held and continued to 9:30 5/24/01 . Mailed notice (ldg) (Entered: 05/11/2001)
SCHEDULE set on 5/24/01 by Hon. John W. Darrah : Status hearing held and continued to 9:30 5/29/01 . Mailed notice (ldg) (Entered: 05/24/2001)
SCHEDULE set on 5/29/01 by Hon. John W. Darrah : Status hearing held and continued to 9:30 6/20/01 . Mailed notice (ldg) (Entered: 06/01/2001)
SCHEDULE set on 6/14/01 by Hon. John W. Darrah : Status hearing set for 6/20/01 is stricken and reset to 9:30 6/25/01 . Mailed notice (ldg) (Entered: 06/14/2001)
22 MINUTE ORDER of 6/25/01 by Hon. John W. Darrah : Status hearing held and continued to 7/5/01 at 9:30 a.m. Plaintiff's oral motion to amend complaint to and including 7/9/01 is granted. The matter of attorney fees will be referred to Judge Coar for consolidation with his fee issue. Mailed notice (eav) (Entered: 06/27/2001)
23 AMENDED COMPLAINT [1-1] by plaintiffs; Adding Sherrille Maynie, Marvella Everette, Kristine Ricks; Notice. (fce) (Entered: 07/06/2001)
SCHEDULE set on 7/5/01 by Hon. John W. Darrah : Status hearing held and continued to 9:30 8/9/01 . Mailed notice (ldg) (Entered: 07/06/2001)
SCHEDULE set on 8/8/01 by Hon. John W. Darrah : Status hearing set 8/9/01 is stricken and reset to 9:30 8/16/01 . Mailed notice (ldg) (Entered: 08/08/2001)
SCHEDULE set on 8/13/01 by Hon. John W. Darrah : Status hearing set for 8/16/01 is stricken and reset to 9:30 8/22/01 . Mailed notice (ldg) (Entered: 08/13/2001)
24 MINUTE ORDER of 8/22/01 by Hon. John W. Darrah: By agreement of the parties and stipulation to dismiss, this cause is dismissed. Terminating case. Mailed notice. (fce) (Entered: 08/27/2001)

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