main entrance and called a friend, Mrs. Dorothy Fields and explained the situation to her
and asked if she/or her husband, Claybourn Fields would come and pick her up from the
hospital.

4, Mrs. Dorothy Fields stated that she was not able to come but that her
husband would come and pick me up. Plaintiff then exited the main entrance of the
hospital, walked back toward the emergency room and was grabbed by Officer Henry,
Officer Henry’s Supervisor and Officer Holiday and dragged back to the emergency room.
Plaintiff physically resisted this unlawful restraint, assault and battery, but Plaintiff being a
woman was no match for the three security officers. As the security staff was coercing
Plaintiff through the emergency room before entering the doors, her friend, Dorothy’s
Husband, Claybourn Fields, verbally intervened and asked the security staff if Plaintiff was
under arrest. Security Staff responded that Plaintiff was not under arrest. Plaintiff was
then placed into what appeared to be a psychiatric observation, locked in where she
remained for several hours.

Plaintiff continued to inquiry as to the reason for her incarceration explaining that
Jackson Park Hospital Staff should contact her personal physician, Dr. Wu, Eventually,
Plaintiff was interviewed by a hospital staff member purporting to be a medical doctor and
an hour later was interviewed by a psychiatrist. Plaintiff was removed from her
“incarceration room on the emergency 1°. floor where she shared with another patient”
and interviewed in another room; present were her friend, Larry Austin, Plaintiff's
Daughter, Lorell Augustine, the self described psychiatrist and another female staff
member. At the conclusion of the interview, the psychiatrist told Plaintiff that he found no

reason to further incarcerate Plaintiff and that he would discharge her home, Plaintiff was

13.



slippers on her feet. Larry Trask was already present at the hospital filing out forms when
Plaintiff arrived at Jackson Park. Larry Trask told hospital staff with Police and Plaintiff
present, that Plaintiff was crazy, that Plaintiff had been incarcerated in a mental hospital
on 4 (four) separate occasions; that plaintiff was currently under a doctor’s care; and that
plaintiff is on a medication schedule and refuses to take her medication.

Larry also told hospital staff that “Ms. Jones has been verbally and physically
abusive at the house of James P. Trask Sr. of 9919 S. Parnell. She has a mental history
and the police were called (3) times on 10-10-02 for disturbances. She daused against (6)
six of her siblings. She has Seven (7) different names that she is subject to use. She is a
pathological liar, has multiple personality complex, she’s schicophrenic, she thinks that she
is an attorney, preacher, private investigator a teacher and a preacher. Summons that
were written by her and has been thrown out of four different hospitals. She is very ill
mentally“. Plaintiff “broke into hr father house, had a knife, Mr. Trask was in fear for
himself and etc.”. Larry uttered the fermented false and slanderous statements to hospital
staff in the presence of the Police and Plaintiff. The hospital receptionist receiving the
aforementioned false and slanderous allegations from the Larry, stated to defendant, Larry
that if he left the hospital, then Plaintiff could also leave the hospital. Plaintiff then left
Jackson Park Hospital Emergency Room and walked outside to the front of the main
entrance of the hospital, borrowed 50 cents from a stranger waiting on the bus in the rain,
robe, and house slippers, soak and wet entered the front of the hospital and used the
public telephone. Plaintiff, called a friend, Dorothy Fields and explained the situation to
Mrs. Fields, advising her that plaintiff had no money; was only in her robe/houseshoes and

needed her to ask her husband if he would pick her up at the Jackson Park Hospital,



Plaintiff maintains that Jackson Park Hospital violated her Right to be Free of
Unlawful restraint and False Imprisonment in that, without probable cause, Jackson Park
Hospital Staff grabbed her on a public way, restrained Plaintiff, physically and coercively,
transported Plaintiff to the emergency room of Jackson Park Hospital and placed Plaintiff
in what appeared to be a psychiatric observation room, located in the emergency room of
Jackson Park Hospital and left Plaintiff there for several hours, despite Plaintiff's
continous request to be released and despite her request that staff notify her personal
physican at South Shore Hospital. Plaintiff was told hospital staff that she was going to
stay in the hospital and be transferred, even if Plaintiff didn’t agree. Plaintiff did not agree
and was placed in what appeared to be a psychiatric observation room, located in the
emergency room and left Plaintiff there for several hours, despite Plaintiff's continous
request to be released and despite her request that staff notify her personal physician at
South Shore Hospital. Plaintiff told hospital staff and security that records dating back
over 25 years would reflect that Plaintiff has never been hospitalized for any psychiatric
disorders and that her doctor (Dr. Wu) would verify same.

Plaintiff states that as an institution substantially supported by Federal Funding,
Jackson Park Hospital is obliged to observe and comply with all Federal funding, Jackson
Park Hospital is obliged to observe and comply with all Federal Statues and the United
States Constitution. Specifically, the 5 Amendment and the 14‘ Amendment prohibits
the denial of a citizen‘s right to “proceed on their way“ except by due process. By
accepting Federal Funding Jackson Park Hospital becomes an agent of the Federal
Government and must adhere to the dictates of federal Statues and the Constitution. With

respect to the instant case, Fundamental due process required that Jackson Park Hospital



were exposed to numerous examples that Defendant, Larry was lying or fabricating the
allegations against plaintiff. For example, when Defendant, Larry provided the arresting
officers with a document, apparently, concerning Plaintiff's alledged incarceration in a
mental institution, the fact that the document gave a birth year of 1975 should have alerted
the arresting officers to the possibility that the document was bogus. Since violations of
any federal statue and or constitutional right violates federal law, Plaintiff invokes the
District Court Federal Question Jurisdiction. Moreover, Plaintiff alleges that the conduct
of the arresting officers complained of in this case is also violative of the United States
Code, Title 42 United States Code Section 1983.

RELEIF

Plaintiff respectfully, request $250,000.00 (Two Hundred and fifty Thousand
Dollars) in compensatory damages. Plaintiff argues that she is entitled to compensatory
damages in the aforementioned amount because of the intentional infliction of emotional
distress associated with being incarcerated in a mental facility, unjustifiably.

In addition, Plaintiff respectfully request $750,000.00 (Seven Hundred and Fifty
Thousand Dollars) in punitive damages because the behavior of the arresting officers was
intentional and malicious

Wherefore, Plaintiff , Lois Trask, respectfully request that her requested be granted
along with any and all other order this honorable court and this Honorable Judge deems

just and necessary and for this she shall forever pray.

COMBINED Sou ell

Plaintiff Demands a Jury Trial.

Lois Trask
7776 S. Coles Avenue
Chicago, Illinois 60649



Emergency Room. Claybourn Fields, Mrs. Field’s Husband, stated that he would come
and pick up Plaintiff. After telephonic speaking with Claybourn Fields, Plaintiff was
returning to the emergency room area outside of the hospital. At this point, Plaintiff was
grabbed by Jackson Park Hospital Security Staff, Officer Henry, Officer Henry’s
Supervisor and a third unknown security staff and was dragged back through the
emergency room entrance- as plaintiff was grabbed by hospital staff, plaintiff physically
resisted the three security staff, protesting that they had no right to cohearse plaintiff back
into the hospital. As hospital security continued to drag plaintiff back into the emergency
room, her friend Claybourn Fields, approached the emergency room entrance and asked
the three hospital security staff why they were dragging plaintiff into the hospital.
Specifically, Mr. Fields asked the hospital security staff if plaintiff was under arrest and
they replied that she was not under arrest. Plaintiff continued to refuse an medical
treatment and stated that she did not need to see a doctor. Security Officers (Henry) and
unknown other officer grabbed Plaintiff and physically, dragged her with the assistance of
an unknown nurse. Plaintiff was placed in a locked room with windows reinforced with a
steel or metal screen that was also dirty with roaches crawling all about her wet feet and
clothes, Plaintiff was kept incarcerated for hours.

Plaintiff states that the defendant’s behavior complained of in this action,
constitutes false imprisonment and a violation of the 4" Amended of the United States
Constitution, prohibiting, unreasonable searches and seizure. Plaintiff states that the
Chicago Police Officers who seized her person and incarcerated her at Jackson Park
Hospital were acting outside of the provisions of the 4" Amendment in that Plaintiff's

seizure was unreasonable. Plaintiff seizure was unreasonable because the arresting officers



evaluation. Jackson Park Hospital is a State Actor or Agency of the State for purposes of
Federal Question Jurisdiction and Title 42, United States Code, Section 1983, analysis and
construction.

The Emergency Room Intake Staff at Jackson Park Hospital, after being advised
by Plaintiff's brother, Larry Trask and the arresting and escorting police officers, Security
Officers at Jackson Park Hospital, Officer Henry and Officer Holliday, concerning the
alleged behavior of Plaintiff that supposedly provided “probable cause” to suspect that
plaintiff required a coerced psychiatric evaluation, the intake staff, Yvonne G, Wallace
stated to Larry Trask “that if he (Larry Trask) left the hospital before Plaintiff was
transferred to Tinley Park Mental Hospital, then Plaintiff could also leave the hospital.”

Plaintiff left the emergency room and went outside on 75“ and Stony Island, where
she made a phone call, using a public telephone situated just inside the main entrance of
the hospital. Plaintiff exited the main entrance and had only walked a short distance back
toward the emergency room when Jackson Park Hospital Security Guards, Officer Henry,
Officer Holiday and Officer Henry’s Supervisor, (Name Unknown) grabbed Plaintiff of the
sidewalk and dragged Plaintiff back to the emergency room and physically coerced
plaintiff into a room with windows covered by a steel or metal screen, Plaintiff was
incarcerated in the aforementioned room for several hours and was never advised, by
Jackson Park Hospital Staff, as to the reason for her incarceration. Plaintiff repeatedly
inquired concerning the reason for her incarceration, however hospital staff refused to
address Plaintiff's Inquiry. 1n addition, Plaintiff requested that the hospital staff contact
the head nurse and/or her doctor and hospital staff was unresponsive to Plaintiffs request.

Plaintiff again requested that her doctor, Dr. Wu be contacted.



United States District Court
Northern District Of Illinois
Eastern Division Ke

City of Chicago Police Dept.
David Holliday, Sergeant John
Doyle, H, Wilson, #17355, and transferred from The Honorable Judge
C. Janotu, #16940 & Unkn. Ins. Co. ) Plunket and Magistrate Judge Keys
Jackson Park Hospital, Security Dept.) HOCKETED
Officer Henry and Officer Smith and ) 2003
Unknown other Africian American) oct 30
Male Officer, Yvone Gillin Wallace, ) The Honorable Presiding Judge MANNING

And Unknown Insurance Company. ) Honorable Magistrate Judge Levin

Combined with 02 C. 7468

Lois Trask, 7
Plaintiff
: ‘Gy eg €o
Vs. ) No. 027384 ase, "ey,
My Q
) 720,
)
)
)

Officers, & Officer Holiday. )
NOTICE OF FILING
To: April R. Walkup Chicago Police Dept.
Querrey & Harrow, 3510 South Michigan

175 W. Jackson Blvd. #1600 Chicago, Illinois 60605

PLEASE TAKE NOTICE that on the 29 day of October, 2003 I filed with the
Clerk of the U.S. District Court for the Northern District of Illinois, Plaintiff's Amended
Combined Complaint against Jackson Park, Hospital, Staff, Security Staff and the Chicago
Police Department and Staff as per order of the Honorable Judge Manning, same was
completed and filed.

Qov Sagat
Lois Trask

CERTIFICATE OF SERVICE
Please take note that on October 29, 2003, I served a copy of the above mentioned motion
to all parties listed on the record for service by depositing same in the U.S. Mailbox with
proper postage affixed to same at 220 S. Dearborn, Chicago, Illinois, before the 5:00 hour

on this 29th day of October 2003. a ‘
Qe = ARDY a

Lois Trask

7776 S. Coles Avenue
Chicago, Illinois 60649
773-734-7238

a/



regulated by the State, in addition to the other (joint-activities with the state, Plaintiff as
that the court declare Jackson Park Hospital a “State Actor” or agent of state for purpose
of the Court’s Federal Question Jurisdiction and/or title 42 United States Code, Section
1983 Construction.
STATEMENT OF FACTS

1. On October 12, 2002, at approximately 3:30 p.m., at 9919 S. Parnell,
Chicago, Illinois Larry K. Trask Sr., Plaintiff's brother, called the police. When the police
arrived, Larry Trask told the police that Plaintiff had been incarcerated in a mental
institution on 4 (four) separate occasions; that Plaintiff was under a doctor’s care; that
Plaintiff was on a medication schedule and was refusing to take her medication. Larry
Trask ( hereafter called Larry) produced a document that he purported to be evidence that
Plaintiff had been incarcerated in a mental institution and was on medication. Larry
offered the document to the police officer, while police were examining the document,
Plaintiff noted that the birth year on the document was 1975. Plaintiff, pointed out to the
police officers examining the document, that the birth year on the document indicated
1975. The police officer said, “ That’s too bad, you’re under arrest and you’re going to
Jackson Park Hospital.” (Plaintiff handcuffed to her back, while in Robe and House Shoes
and escorted out of 9919 S. Parnell, Chicago, Illinois. Handcuff were too tight) Larry
further told the police officers that Plaintiff had entered her deceased mother’s room,
pushed into her mother’s abdomen causing her demise; and that Plaintiff had attempted to
poison her father.

Larry told police that he wanted Plaintiff locked up in Tinley Park Psychiatric

Ward and that Plaintiff had to go to Jackson Park Hospital first, before she could be

11.



obtain probable cause to believe Plaintiff required a coerced psychiatric evaluation; as the
statement of facts illustrate, defendants cannot make such a showing because all available
information defendants were privy to did not establish probable cause.

Plaintiff states that Jackson Park Hospital should be considered a “State Actor” or
Agency of the State of Illinois because of the subsequent rational. Jackson Park Hospital
as an organization is funded by the Federal Funds and because of that federal funding is
obliged to perform certain and specific public functions. Fore example, citizens exhibiting
signs of psychiatric collapse, suicidal and/or homicidal ideation; without regard to that
citizen’s ability to pay, are oftentimes taken to Jackson Park Hospital for an initial
psychiatric evaluation. Jackson Park Hospital’s participation in the aforementioned
example pre supposed significant public funding. Moreover, this action of initial
psychiatric evaluation “ of destitute citizens is a “custom or usage,” that is statutorily
given to State Mental Health Agencies; Illinois Department of Public Health.

Plaintiff, further states that the Supreme Court’s “State Compulsion Test” is also
satisfied by the foregoing illustration - in that “initial psychiatric evaluation” performed on
indigent citizens is an obligation imposed on Jackson Park Hospital by contract and by
Law. Plaintiff states that the “Nexus Test” is also satisfied by the previously mentioned
illustration, Jackson Park Hospital is heavily regulated by both state and federal agencies;
in addition, Jackson Park Hospital personnel are heavily regulated by both state and
federal agencies; in addition, Jackson Park Hospital Personnel are also heavily regulated,
For example, nurses, doctors, etc. are licensed and regulated by the Illinois Department of
Licensing and Regulation.

Therefore, because Jackson Park Hospital performs functions traditionally

10,



United States District Court
Northern District Of Illinois

Eastern Division

LOIS TRASK,

Plaintiff,

Vs. No. 02 C 7384
City of Chicago Police Dept.
David Holliday, Sergeant John as ordered by the Honorable Judge Manning
Doyle, H, Wilson, #17355, and transferred from The Honorable Judge
C. Janotu, #16940 & Unkn. Ins. Co. ) Plunket and Magistrate Judge Keys
Jackson Park Hospital, Security Dept.)
Officer Henry and Officer Smith and )
Unknown other Africian American _)
Male Officer, Yvone Gillin Wallace, ) The Honorable Presiding Judge MANNING
And Unknown Insurance Company. ) Honorable Magistrate Judge Levin
Officers, & Officer Holiday. )

Defendants.

COMBINED AMENDED COMPLAINT AT LAW-COUNT II

Combined with 02 C. 7468

eee SH

TORT OF FALSE IMPRISONMENT AND INTENTION INFLICTION OF MENTAL

DISTRESS
NOW COMES, the Plaintiff, Lois Trask, Pro Se Litigant and submits her
Amended Complaint in accordance with the Court’s instructions from the Honorable
Judge Manning Court to combine this complaint (02 C-7384 with 02 C 7468) complaining
of the unlawful restraint and false imprisonment she was subjected to by Jackson Park
Hospital Staff and Security Staff. Specifically, on October 12, 2002, Plaintiff was
transported by Chicago Police Officers to Jackson Park Hospital’s Emergency Room, at

7500 S. Stony Island, Chicago, Illinois supposedly for purposes of coerced psychiatric



Darrick Trask, Lorell Jones, Deliliah Stidwell, Clenert Trask, Officer Doyle and two police

officers names unknown

Plaintiff's was escorted from her father house, handcuffed with only a robe on and
her under garments and placed in a police squad car, amidst plaintiff constant protest and
request to allow her to put on clothing. The arresting officer’s decline to allow Plaintiff to
put on clothing and instead took plaintiff as she was. Plaintiff complained to the arresting
officers that her handcuffs were so tight, it caused Plaintiff to cry out in pain and continue
to complain and continued to say that the handcuffs, interfered with her Blood/Circulatory
System, bowel system, nervous System, aching joints, low blood pressure, skin disorder,
Heart Problems, stress, depression and Rhmatoid Arthritis. Officers were unresponsive to
Plaintiff's complaint and need of pain medication.

Plaintiff was transferred to the Police Station, 11100 S. Monterey, Chicago,
Illinois, in.a squad car, handcuffed to her back while in her father‘s living room, singing at
the piano as her father played the piano. Plaintiff was immediately handcuffed to a wall,
left there for 2 % hours without being able to use the washroom and her cell phone was
taken from her and never returned. Police Officers, H. Wilson #17355 and C. Janotu
#16940 (312-747-6381) then transported Plaintiff in a dirty patty wagon to the Emergency
Room of Jackson Park Hospital. Plaintiff, requested that if she must go to a hospital that
she would prefer going to her own doctor at South Shore Hospital. Both officers agreed
that they were taking her to South Shore Hospital. When the patty wagon stopped and
Plaintiff was complaining that she did not want to go to Jackson Park because of personal
reasons, After arriving at Jackson Park Hospital, the upon named police officers forced

Plaintiff out of the wagon. Plaintiff has on a robe with only her undergarments and house

3.



allowed to leave and did so. Plaintiff demands a Jury Trial.
RELIEF

Plaintiff respectfully request $300,000.00 ( Three hundred thousand dollars) in
damages for the unlawful restraint and false imprisonment of the Plaintiff. Plaintiff also
request $9000,000.00 (nine hundred thousand dollars) in punitive damages because the
defendant’s behavior complained of was engaged with focused intent and malice along
with any and all other orders this Honorable court and this Honorable Judge deems just
and necessary and for this she shall forever pray.

Sow Yo

Lois Trask

For the Plaintiff - 99500
Lois Trask - Pro Se
7776 S. Coles Avenue
Chicago, Illinois 60649
773-734-2558

14.



that plaintiff had a gun and knife in her purse. Officer, David Holliday, searched Plaintiff's
person, while in the living room of her father’s house and purse and stated that there was
no gun or knife found. Larry Trask Sr. then told the officer that Plaintiff was crazy- that
plaintiff had been incarcerated in a Mental Institution on 3 (three) separate occasions; that
Plaintiff was under a doctor’s care and that Plaintiff is on a medication schedule and
refuses to take her medication. Larry Trask, Sr. then produced a document that he
represented to the police as verifying that Plaintiff had been incarcerated in a Mental
Institution. As the officer examined the document, proffered by Larry Trask Sr., Plaintiff
observed that the birth year contained on the document was for 1975.

Plaintiff states that casual observation of her person gives evidence that Plaintiff is
not 27 years old. Plaintiff informed the officer, examining the proffer document, that the
person date of birth indicated a birth year of 1975, clearing plaintiff is not the person
referred to in the aforementioned document. The officer responded that it was too bad
that Plaintiff was still going to Jackson Park Hospital. Officer refused to allow plaintiff to
dress, obtain her purse and or belongings. Plaintiff was handcuffed. Plaintiff asked the
arresting officers whether she was under arrest and the officers said, yes. Plaintiff then
asked the arresting officers if they were going to read her Miranda Rights and the officer
said, we'll do it later. Moreover, Larry Trask Sr. told the arresting officers that Plaintiff
had entered her mother’s bedroom, pressed on her abdomen and caused her mother’s,
demise. In addition, Larry Trask Sr. (hereafter Larry) told the arresting officers that
Plaintiff had attempted to poison her father, James Trask Sr.. At the time Larry made the
aforementioned false allegations, impuning plaintiff's reputation and character, the

following witnesses were present: James Trask Sr., Lula Stidwell, Cynthia Stidwell,



United States District Court 7~
Northern District Of Illinois Sf
Eastern Division g

City of Chicago Police Dept.
David Holliday, Sergeant John as ordered by the Honorable Judge Manning
Doyle, H, Wilson, #17355, and transferred from The Honorable Judge
C. Janotu, #16940 & Unkn, Ins. Co. ) Plunket and Magistrate Judge Keys

Jackson Park Hospital, Security Dept.)

Officer Henry and Officer Smith and )

Unknown other Aftician American)

Male Officer, Yvone Gillin Wallace, ) The Honorable Presiding Judge MANNING
And Unknown Insurance Company. ) Honorable Magistrate Judge Levin

Officers, ' 0
Defendant. ) mR
AMENDED ancnel a
got 3.020

Combined with 02 C. 7468

Lois Trask, } se, “85, 0)
Plaintiff ) Ox %
) %%,
ao
Vs. ) No. 02 C7384 aS
) %
)
)
)

Complaint at Law
TORT OF FALSE IMPRISONMENT

Count I
NOW COMES the PLAINTIFF, LOIS TRASK, PRO SE LITIGANT, and

complains of the Illegal seizure of her person by Officers of the Chicago Police
Department, 1830 West Monterey, Chicago, Illinois. Specifically, on October 12, 2002 at
9919 S. Parnell, Chicago, Illinois, “The House of James Trask Sr., Plaintiff's Father”
Plaintiff's brother, Larry Trask Sr. called the Police and advised the police that Plaintiff
Lois Trask had pulled a knife and gun on him at their father’s house.

Officers David Holliday, Sergeant John Doyle and unknown officer, responded to
the telephonic allegations of assault with a knife lodged by Larry Trask Sr. and came to

9919 S. Parnell to investigate. When the police arrived, Larry Trask Sr. told the officer


transferred to Tinley Park Psychiatric Ward. Larry told the police officers that, Plaintiff
was allegedly acting craze, pulling knifes on him and other and that she was violent with
people.

2. Plaintiff was transported, by police car to the Police Station at 11100 (2274,
District) & Monterey, Chicago, Illinois where she was handcuffed to the wall by her right
arm ( her damaged arm since 1990) for several hours. Eventually, Plaintiff was taken by
two different police officers in a paddy wagon to the emergency room of Jackson Park
Hospital, 7500 S. Stony Island, Chicago, Illinois. When Plaintiff arrived, Larry was
already at the intake desk. Larry repeated the same False allegation and complete
Fabrication he had uttered to the police while in the living room of Plaintiff's father, just
prior; but added that Plaintiff used alcohol and drugs.

Plaintiff, again asked Jackson Park Hospital to notify her personal physician
explaining that her Doctor, Dr. F. Wu, could verify that she has never been incarceration
in a mental institution. Plaintiff, repeatedly told hospital staff that the allegations provided
by her brother, Larry were false and a complete Fabrication. Specifically, Plaintiff told
hospital staff that she was not under psychiatric care and was not on any kind of
psychotropic medication, Plaintiff also told hospital staff that she did nothing to her
mother, did not poison her father and was not using alcohol or drugs. Plaintiff told
hospital staff to notify her personal doctor to verify the validity of her statements and that
medical records, dating back over 25 years would reflect same

3. Hospital staff at Jackson Park Hospital told Plaintiff that she could leave.
Plaintiff then exited the emergency room and walked outside the Hospital toward the main

entrance between 75 & 76 and Stony Island of the hospital. Plaintiff entered the hospital’s

~ 12