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In the Circuit Courtof the CookCounty,Illinois PahickTerrell, Petitioner. vs. It*k Lollino, Jr.

,Morton College CommunityCollegeDistrict 52i, and Chicago Boardof Education, behalfof on LaneTechnical High School, Respondents Discoverv in
) ) ) ) ) ) ) ) ) ) ) )

Case No.

Petition for Discovery Now comes Petitioner, the PatrickTerrell,by his attomeys, Anna E. Finn,anddmyLynn
fr

Shege Finn & Finn, Ltd., andpetitioningRespondents Discovery, of in Frankfo1infrr., J t"-': Morton college communitycollege District 527,andchicago BoardorEa#San o*$.rremor LaneTechnical High Schoolstates follows: as COMMONFACTS At all timespertinent the allegations this petition: to of Chicago, LakeCounty,lL. b' FrankLollino Jr. (hereinafter "Lollino') wasan adultresident the City of Chicago, of CookCounty,IL.
c. Morton communitycollege community college District

g H{; E;";,A3

l.

a' PatrickTenell (hereinafter "Terrell") wasa youngadultresident the of

City of North

527(hereinafter..Morton,,)

wasoperating a public communitycollegein the city of cicero, as cook county, IL. Chicago Boardof Education, behalfof LaneTechnical on High School(hereinafter "Lane") wasoperating a public high schoolandcollegepreparatory as academy the in City of Chicago, CookCounty,IL. In or around fall of 2006throughanduntil the summer the of 2011,Lollino was employed Morton asa basketball by coach.

a J.

Upon informationandbeliel prior to this and/orduringat leastsomeportionof this time, at alongwith serving, various coach, by Lollino hadbeenemployed Laneasa basketball

teacher. and/ordrivers' education points,asa physicaleducation 4. Upon informationandbelief,while Lollino wasat Lane,andprior to his beinghired at of allegations of a Morton,Laneperformed reviewor investigation Lollino conceming playersand/orother on conductor commentary his part toward basketball inappropriate students. or 5 . Upon informationandbelief,Lanetook certainprecautionary disciplinarymeasures and to of Lollino duringthe course and/orsubsequent this reviewor investigation, against at a time prior to his beinghiredby Morton. coachof the the 6. In or around fall of 2008,Lollino, who hadbecome headbasketball for Tenell to enroll at Mortonandplay basketball the team,recruited Morton'sbasketball college. programat Morton dueto an in to 7. In2009, Tenell wasunable participate the basketball injury unrelated basketball. to wherebyTerrellwould have 8 . At somepoint in late2010,Lollino setup an arrangement Terrell andthe between with Lollino actingasa middleman housing closeto campus, landlordto collectandturn overthe rent. housingarrangements made,in wholeor in part,sothat Terrellwould be able were 9 . These season. teamfor the 2010-2011 to rejoin the basketball until summer of thereafter 10.Beginningin or around winter of 2010,andcontinuing the Tenell to suffer that caused in of 2011,Lollino began engage a course conduct to extreme emotional distress anxiety,includingbut not limited to: and to describing Tenell varioussexualactsthat Lollino a. Repeatedly graphically and hadperformed the pastwith both malesandfemales. in in b. Constantly inviting andurgingTerrell to engage similaractswith Lollino and others. for in c. Offeringpayment and/orhousingassistance exchange sexualfavors.
d. Asking Terrell to stayin a hotel room with him during an upcomingaway game

that waslatercancelled.

e' Constantlycontactingandharassing Terrell at all hoursof the day andnight, via text messages, facebook posts, phonecalls,andin-person visits,evencornering him afterpractices games or and/orpressuring to takeridesin his vehicle. him f. Sought obtainpromises assurances Tenell that he would not tell to and from anyone elseaboutwhat Lollino wassayinganddoing. g' Implying that Tenell might sufferadverse consequences a basketball as player andstudent he did not complywith Lollino's requests demands. if and h. Lollino continued course conduct this of despite Terrell'srepeated refusals, becoming increasinglybrazenin requests threats retributionfor nonhis and of compliance and/or breachof silence aboutthe situation. 1l' This continuous relentless and course conduct Lollino eventually of by caused Terrellto leavebothMorton andits basketball team,to forgo scholarship assistiurce he had that beenreceiving, to transferinto another and community college. 12.Yet eventhereafter, Lollino continued contact to Terrellandalludeto their unfinished "business," how they needed "work something and to simpleout," implying that Terrell shouldcomebackto Morton, andhavehis rent covered Lollino in exchange sexual by for favors;the lastsuchcommunication havingbeenmadeby Lollino in or aroundthe summer 2011. of 13.Realizing that Lollino would not voluntarilystopthis harassment, Terrellwascompelled to hire legalcounsel represent protecthim, which led, uponinformationand to and belief, to Lollino's separation from Morton in or around middleof Augustof 2011. the 14.DespiteTerrell'sreportsof sexualharassment theproperofficials at Morton, to Morton allowedLollino to continue headbasketball as coachfor a periodthereafter. 15' Lollino, usinghis positionasheadbasketball coachon behalfof Morton, contacted at leastoneothermember the local basketball of community, in retributionand and retaliation Terrell'sreportsof sexual for harassment, madedisparaging, defamatory, slanderous, libelousaccusations and against Terrell. 16' Tenell continues suffersevere to emotional aftereffects distress anxietyandto of and constantlyworry aboutthe impact of theseunwarranted, unpleasant demeaning and incidentsuponhis reputationandhis future asa student,basketball player, andhuman being.

17' Tenell now desires pursueall avenues to madeavailable law to by

seekredress against

all partiesresponsible wholeor part for the damages hassuffered. in he 18' Uponinformationandbelief,documents, materials, information and necessary for Tenell to fully explorehis legaloptionsarein the possession controlof each or of the named respondents discovery listedin this petitionfiled pursuant 735ILCS 512in as to 402et seq.,anddiscovery requests that endareattached to hereto. 19' Withoutthis discovery, Terrellcannotfully evaluate potentiallegalclaims,nor canbe his determine necessary properpartiesagainst the and whom he might seekredress. 20. To the extentlegallypermitted, Tenell furtherrequests protective that ordersbe entered, which,in the discretion the court,would help to limit or prevent unnecessary of the public disclosure the sensitive of factsunderlyingthis proceeding. Wherefore, Petitioner, PatrickTerrell,praysfor an orderrequiringeachnamedrespondent to answer discovery all requests within 28 daysof the receiptthereof,for a protective order preventing unwarranted disclosure sensitive of materials, for furtherrelief asthe courtdeems and appropriate just. and Respectfully submitted,

of Mr. Terrell'sAttorneys Amy Lynn Strege Finn & Finn, Ltd. 128N. WestStreet Waukegan,IL 60085 TeI.8471599-0202 ARDC # 6294686

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