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2:14-cv-02072 #1 - Complaint

2:14-cv-02072 #1 - Complaint

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Published by Equality Case Files
Doc 1 - Complaint
Doc 1 - Complaint

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Published by: Equality Case Files on Apr 16, 2014
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04/23/2014

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IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS URBANA DIVISION NAYA GRACE TAYLOR, Plaintiff, v.  AJA LYSTILA, M.D., CARLE HEALTH CARE INCORPORATED, an Illinois corporation, d/b/a CARLE PHYSICIAN GROUP, CARLE FOUNDATION PHYSICIAN SERVICES, LLC, and THE CARLE FOUNDATION, an Illinois corporation, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 2:14-cv-2072
Equitable Relief Is Sought COMPLAINT
Plaintiff NAYA GRACE TAYLOR ( “Plaintiff”) for her Complaint against Defendants AJA LYSTILA, M.D., CARLE HEALTHCARE INCORPORATED, d/b/a CARLE PHYSICIAN GROUP, CARLE FOUNDATION PHYSICIAN SERVICES, LLC, and THE CARLE FOUNDATION (collectively, “Defendants”), alleges the following:
PRELIMINARY STATEMENT
1.
 
This action seeks injunctive and declaratory relief, as well as damages, to halt Defendants’ discrimination on the basis of Plaintiff’s sex in violation of section 1557(a) (“Section 1557(a)”) of the Patient Protection and Affordable Care Act (codified at 42 U.S.C. § 18116(a)) (“Affordable Care Act”). Specifically, Plaintiff
E-FILED
 Tuesday, 15 April, 2014 02:59:14 PM Clerk, U.S. District Court, ILCD
2:14-cv-02072-CSB-JEH # 1 Page 1 of 11
 
Taylor v. Lystila
Plaintiff’s Original Complaint
 2 seeks redress for Defendants’ violation of federal law by denying Plaintiff health care services because she is a transgender woman.
JURISDICTION AND VENUE
2.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 because this action arises under section 1557(a) of the Affordable Care Act, 42 U.S.C. § 18116(a). 3.
 
 Venue is proper in this district pursuant to 28 U.S.C. § 1391 because one or more of the Defendants reside in the Central District of Illinois and because all or a substantial part of the events giving rise to the claims in this action occurred and are occurring in the Central District of Illinois. 4.
 
This matter is properly brought in the Urbana Division because the entity Defendants’ are principally located in Champaign County, the Defendant doctor maintains an office in Coles County, and the Plaintiff resides in Coles County. Further, a substantial part of the events giving rise to the claims in this action occurred and are occurring in Coles County. 5.
 
Declaratory relief is authorized pursuant to 28 U.S.C. § 2201 and 28 U.S.C. § 2202. A declaration of the law is necessary and appropriate to determine the respective rights and duties of the parties to this action.
PARTIES
6.
 
Plaintiff Naya Grace Taylor (“Naya”) is a transgender woman who is a citizen of Illinois residing in Mattoon.
2:14-cv-02072-CSB-JEH # 1 Page 2 of 11
 
Taylor v. Lystila
Plaintiff’s Original Complaint
 3 7.
 
Defendant Aja Lystila, M.D. (“Dr. Lystila”) is a citizen of Illinois who maintains an office at 2512 Hurst Drive, Mattoon, IL 61938. Dr. Lystila is a medical doctor licensed by the State of Illinois and board certified in Family Medicine by the  American Board of Family Medicine. 8.
 
Defendant Carle Health Care Incorporated, d/b/a Carle Physician Group, (the “Physician Group”) is a not-for-profit corporation organized under the laws of the State of Illinois with its principal place of business at 611 W. Park, Urbana, IL 61801. It may be served with process through its registered agent, James C. Leonard, at the same address. 9.
 
Defendant Carle Foundation Physician Services, LLC (“Physician LLC”) is a domestic limited liability company organized under the laws of the State of Illinois with its principal place of business at 611 W. Park, Urbana, IL 61801. It may be served with process through its registered agent, James C. Leonard, at the same address. 10.
 
Defendant The Carle Foundation (“Foundation”) is a not-for-profit corporation organized under the laws of the State of Illinois with its principal place of business at 611 W. Park, Urbana, IL 61801. It may be served with process through its registered agent, James C. Leonard, at the same address. 11.
 
The Foundation is an integrated group of health care services (“Carle Group”) that includes, as its subsidiaries (or otherwise related entities), the Physician Group and the Physician LLC. The Carle Group provides its services under the umbrella designation “Carle” and its logo, not readily identifying which
2:14-cv-02072-CSB-JEH # 1 Page 3 of 11

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