IN THE UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

JAMES MONEY, et al., on behalf of themselves )

and all similarly situated individuals, )

)

Plaintiffs, )

)

v. ) Case No. 20 C 2093

)

J.B. PRITZKER, et al., )

)

Defendants. )

PLAINTIFFS’ MOTION FOR AN EXPEDITED HEARING ON MOTION FOR A 

TEMPORARY RESTRAINING ORDER AND/OR PRELIMINARY INJUNCTION

Plaintiffs, James Money, William Richard, Gerald Reed, Amber Watters, Tewkunzi 

Green, Danny Labosette, Carl Reed, Carl “Tay Tay” Tate, Patrice Daniels, and Anthony 

Rodesky, on behalf of themselves and the classes they seek to represent, by their undersigned 

attorneys, hereby respectfully move this Court for an expedited hearing on their Emergency 

Motion for a Temporary Restraining Order or Preliminary Injunction on April 3, 2020. In 

support of their request, Plaintiffs state as follows: 

1. Plaintiffs, prisoners currently incarcerated throughout the 28 facilities of the 

Illinois Department of Corrections (“IDOC”), face imminent danger and irreparable harm from 

the rapid and unavoidable spread of the novel coronavirus, also referred to as COVID-19.

2. Prisons are congregate settings that inherently make social distancing and other 

imperative protective measures impossible.

3. On March 25, 2020, the IDOC announced the first confirmed case of COVID-19 

of a prisoner at Stateville Correctional Center. Just five days later, Illinois Department of Public 

Health Director Dr. Ngozi Ezike announced that twelve prisoners had been hospitalized with 

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confirmed cases of COVID-19, while another 77 prisoners demonstrated symptoms but had not 

yet been confirmed. On March 31, 2020, Governor Pritzker announced that at least one Stateville 

prisoner had died from complications associated with COVID-19. As of today, there are 64 

confirmed cases of COVID-19 at Stateville.

4. The exponential spread of COVID-19 at Stateville demonstrates the imminent risk 

that all IDOC prisoners face while confined within IDOC’s prison facilities. It is imperative that 

immediate action be taken to protect the rights and lives of the incarcerated people of Illinois. 

5. Although Defendants have begun to transfer a small number of medically 

vulnerable prisoners via medical furlough and transfer to home detention, Defendants are not 

acting quickly enough to protect the lives of hundreds of thousands of vulnerable prisoners who

remain inside IDOC facilities, in congregate settings that are veritable tinderboxes waiting for 

the COVID-19 match. 

6. Plaintiffs have filed a class action lawsuit seeking protection of their federal rights 

under the Constitution and the Americans with Disabilities Act.

7. Plaintiffs also have filed an Emergency Motion for a Temporary Restraining 

Order or Preliminary Injunction. Plaintiffs urgently seek medical furlough or transfer to home 

detention on electronic monitoring for prisoners whose medical conditions and age make them 

particularly vulnerable to serious health complications and possibly death from COVID-19.

8. Prior to filing these actions, on April 1, 2020, Plaintiffs’ counsel gave notice to 

the Office of Governor Pritzker, Chief Legal Counsel for the IDOC, and the Office of the 

Attorney General.

9. In sum, the circumstances for Plaintiffs could not be more dire. Given this 

extremely urgent situation, Plaintiffs hereby request that this Court schedule an expedited 

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hearing on Plaintiffs’ Motion for Temporary Restraining Order or Preliminary Injunction on 

April 2, 2020. 

Wherefore, Plaintiffs, by their undersigned counsel, respectfully request that this Court 

grant their motion and schedule a hearing on Plaintiffs’ Emergency Motion for a Temporary 

Restraining Order or Preliminary Injunction on April 3, 2020. 

Respectfully submitted,

By: /s/ Samantha Reed

 One of the attorneys for the class

Sheila A. Bedi

Luke Fernbach*

Emily M. Grant*

Terah Tollner*

Community Justice Civil Rights Clinic

Northwestern Pritzker School of Law

375 East Chicago Avenue

Chicago, IL 60611

(312) 503-2492

sheila.bedi@law.northwestern.edu

LukeFernbach2021@nlaw.northwestern.edu

EmilyGrant2021@nlaw.northwestern.edu

ttollner@nlaw.northwestern.edu

*Law student licensed pursuant to Illinois 

Supreme Court Rule 711

Vanessa del Valle 

Roderick and Solange MacArthur Justice 

Center 

Northwestern Pritzker School of Law 

375 East Chicago Avenue

Chicago, IL 60611 

(312) 503-5932 

vanessa.delvalle@law.northwestern.edu

Jennifer Soble

Illinois Prison Project

53 W. Jackson, Suite 1056

Chicago, IL 60616

(312) 324-4465

jennifer@illinoisprisonproject.org

Alan Mills

Elizabeth Mazur

Uptown People’s Law Center

4413 N. Sheridan

Chicago, IL 60640

(773) 769-1411

alan@uplcchicago.org

liz@uplcchicago.org

Sarah Grady

Loevy & Loevy

311 North Aberdeen St., 3rd Floor

Chicago, IL 60607

(312) 243-5900

sarah@loevy.com

Amanda Antholt

Samantha Reed

Equip for Equality

20 N. Michigan Ave, Suite 300

Chicago, IL 60602

(312) 341-0022

amanda@equipforequality.org

samantha@equipforequality.org

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CERTIFICATE OF SERVICE

The undersigned, an attorney, certifies that she filed the foregoing document via the 

Court’s CM/ECF system and served a copy on the individuals in the attached service list, on 

March 31, 2020.

/s/ Samantha Reed

Samantha Reed

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