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Catholic Charities APPEAL TO THE ILLINOIS APPELLATE COURT FOR THE FOURTH .JUDICIAL DISTRICT

Catholic Charities APPEAL TO THE ILLINOIS APPELLATE COURT FOR THE FOURTH .JUDICIAL DISTRICT

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Published by Tom Ciesielka

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Published by: Tom Ciesielka on Oct 06, 2011
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10/06/2011

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APPEAL
TO THE
ILLINOIS
APPELLATE COURTFOR
THE
FOURTH .JUDICIAL DISTRICT
FROM
THE
CIRCUIT
COURT
FOR
THE
SEVENTH .JUDICIAL
CIRCUIT,
SANG AMON COUNTY,
ILLINOIS
CATHOLIC
CHARITIES
OF
THE
DIOCESE
OF
SPRINGFIELD-IN-ILLINOIS,
an
Illinoisnon-profit corporation,
CATHOLICCHARITIES
OFTHE
DIOCESE
OF
JOLIET,
INC.,
an
Illinois non-profit corporation,
andCATHOLIC
SOCIAL SERVICES
OF
SO.ILLINOIS, DIOCESE
OF
BELLEVILLE, an
Illinois non-profit corporation,Plaintiffs-Appellants,vs.
)
)))))))
))
)
STATE
OF
ILLINOIS, LISA MADIGAN, in )
her
official capacity as the Attorney
General
)
of
the State
of
Illinois, ERWIN McEWEN, )in his official capacity as Director
of
the
Dep't
)
of
Children
&
Family Services,
State
of
Illinois, )the DEPARTMENT
OF
CHILDREN
&
FAM-)
IL
Y SERVICES, State
of
lIIinois,
ROCCO
.J.
)CLAPS in his official capacity as Director
of
the )
Department of Human
Rights, State
of
Illinois, )
and
the DEPART:\JENT OF HUMAN
RIGHTS,)
State
of
lIIinois, )Defendants-Appellees, )and
)
)
SUSAN
TONE
PIERCE, as Next Friend and on )Behalf
of
a certified class
of
all
current
andFuture
foster children in custody
of
DCFS in
B.H.
v.
McEwen,
No.
88
cv
5589
(N.I).II1.
1988);
SARAH
RIDDLE
and
KATHERINE
)
)
)
)
)
Intervenors-Appellees. )
(
-+
Case
No.
2011
MR
254Hon .John Schmidt
Judge
Presiding
C!0fl< the
Circuit Court
11
 
Illinois, Diocese
of
Belleville, Illinois non-profit corporations ("Plaintiffs"), hereby appeal
to
theAppellate Court
of
Illinois
for
the Fourth District {"the Appellate Court"} from the SummaryJudgment Order entered
by
the Circuit Court in this cause on August 18,2011, which grantedDefendants' motion for summary judgment, deniedPlaintiffs' motion for summary judgment,and vacated the Preliminary Injunction which the Circuit Court had previously entered. (A copy
of
the August
18,
2011
Summary Judgment Order is attached hereto and incorporated herein asExhibit A). Plaintiffs also appeal from all interlocutory orders merged into that judgmentincluding, but not limited
to,
the Circuit Court's .August 1,2011 Order granting Intervenors'motion
to
intervene (a copy
of
which docket entry Order
is
attached hereto and incorporatedherein as Exhibit B), the Circuit Court's August 17,
2011
Order denying Plaintiffs' motion tostrike intervenors' affidavits in support
of
summary judgment (a copy
of
the transcript pagesmemorializing the Circuit Court's Order from the bench is attached hereto and incorporatedherein as Exhibit C). and the Circuit Court's September 26.2011 Order denying Plaintiffs'motions for reconsideration and stay (a copy
of
which docket entry Order
is
attached hereto andincorporated herein as Exhibit D).
By
this appeal, Plaintills will ask the Appellate Court
to
reverse the Summary JudgmentOrder entered
by
the Circuit Court in Defendants' favor on August
18,
2011. as well as the otherorders and rulings identillcd
supra,
to
grant Plaintiffs' motion l(lr summary judgment and
to
cntt:f
of
Plaintiffs
on
Counts! through V their Second Amended
&
a penmmlent
\meml"Ll
&
,>upp!(;111cnlll
 
appropriate.
In
the alternative. PlaintitTs will
ask
the Appellate
Court
to reverse the
SummaryJudgment Order entered
by
the
Circuit
Court
in
Defendants'
favor
on August
18.2011,
as well asthe
other orders and
rulings
identilied
supra.
to reinstate the preliminary injunction
previouslyentered
by
the
Cireuit Court.
to
remand
this
cause
for further proceedings,
and
for
such other
relief
as
this
Court deems
just
and
appropriate.
Of
Counsel:
Thomas
Brejcha
Peter Breen
Thomas
More Society,
A
public interest
law finn
29 South LaSalle Street -Suite
440
Chicago,
IL
60603
Tel. 312-782-1680
Attorneyfill'
all
Plaintiffs
James
C. Byrne
Spesia
&
Ayers
1415
Black RoadJoliet.
IL
60435
TeL
815-726-4311
Attorne);,/hr ('otholie Charities
lor
the Diocese
(~rJ(}liet,
Inc.
Bradley
E.
Huff
Richard Wilderson
Graham
&
Graham, Ltd.
1201
South Eighth StreetSpringfield,
IL
62703
TeL
217-523-4569
Attorneys
fill' Catholic Charities
fi)l'
the Diocese o(Sprinldieid-in-II/inois
David
Wells
Catherine
A.
Schroeder
Thompson
Coburn
LLPOne
US Bank
Plaza
51.
Louis,
M063101-1611Tel. 314·552·7500
Attorneys
jiJr ('atho{ic
";ociai Servr'ces
lilt
Southern
Iliinois. Diocese
olBellevilie
11

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