IN THE CIRCUIT COURT OF COOK COLINTY, ILLINOIS
COI,T'{TY DEPARTMENT, CHANCERY DIVISION
i*'a
1
"p
*
;:.1
CHICAGO TEACHERS LNION,
MARILYN STEWART PRESIDENT,
MARK OCHOA FINANCIAL SECRETARY,
MARY MCGUIRE RECORDING SECRETARY,
SARAH HANAWALT TEACHER,
Plaintiffs.
VS.
BOARD OF EDUCATION OF THE CITY
OF CHICAGO, a body politic and
corporate, MARY RICHARDSON LOWRY,
individually and as President of the
Chicago Board of Education
Members, NORMAN BOBINS,
individually and as a Member of
the Chicago Board of Education
TARIQ BUTT, individually and as
a Member of the Chicago Board of
Education, CLARE MLTNANA, individually
and as a Member of the Chicago Board
of Education, ROXANNE WARD,
individually and as Member of
the Chicago Board of Education,
PEGGY DAVIS, individually and as
a Member of the Chicago Board of
Education, ALBERTO CARRERO JR.,
individually and as Member of
the Chicago Board of Education
RON HUBERMAN, individually and as
Chief Executive Officer of the Chicago
Public Schools
' i.
itu
ffififf H* 4
'' \' ''
Defendants.
COMPLAINT FOR MANDAMUS. DECLARATORY. AND INJLINCTIVE RELIEF
NOW COME the Plaintiffs, CHICAGO TEACHERS LNION, MARILYN STEWART,
MARK OCOFIA, MARY MCGUIRE, and SARAH HANAWALT by their undersigned
attorneys POLTROCK & POLTROCK and complain of Defendant BOARD OF EDUCATiON
-l-
oF THE CITY oF CHICAGo, a body politic and corporate and the individual Defendants
MARY RICHARDSON LOWRY, NORMAN BOBBINS, CLARE MLINANA, TARIQ BUTT,
ALEBERTO CARRERO JR., PEGGY DAVIS, ROXANNE WARD, and RoN HUBERMAN
individually and in their official capacities as follows:
a_N-DAMUS. DECL
COUNT I - MANDAMUS
INTRODCUTION
I '
Plaintiffs are the Chicago Teachers Union ("CTU") and the elected officers of the
chicago Teachers union who represent over 20,000 Teachers and paraprofessional and school
Related Personnel (PSRP's) in contract negotiations with the chicago Board of Education
("Board") over several issues including class sizes.
2.
in Count I, plaintiffs seek mandamus.
3.
In Count II, plaintiffs seek injunctive relief.
4.
In Count