Gatlin v. Village of Summit et al

Filing 155

MOTION by Plaintiff Maria Gatlin for judgment (Estes, Ryan)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
)
Maria I. Gatlin,
)
)
Plaintiff,
)
)
Case No. 1:14-cv-03808
v.
)
)
Village of Summit, and
)
Judge Matthew F. Kennelly
Les Peterson in His Official and Individual
)
Capacities,
)
)
Defendants.
)
MOTION FOR ENTRY OF FINAL JUDGMENT

Plaintiff, Maria Gatlin, by and through her attorneys, O’Connor | O’Connor, P.C., hereby moves
this Court for Entry of Final Judgment as follows:

1. Plaintiff Maria Gatlin is entitled to $79,846.51 as backpay damages payable by
Defendant Village of Summit.
2. This Court declares that Defendant Village of Summit violated Plaintiff’s rights under the
Americans with Disabilities Act, 42 U.S.C. §126, and the Illinois Human Rights Act, 775
ILCS 5/1-101 et seq., by failing to provide Plaintiff with a reasonable accommodation
and by unlawfully terminating her employment.
3. This Court declares that Defendant Village of Summit and Defendant Les Peterson
unlawfully deprived Plaintiff Maria Gatlin of her employment without affording her due
process of law, in violation of her constitutional rights under the Fourteenth Amendment
of the United States Constitution, and Article I, §2 of the Illinois State Constitution.

4. Defendants Village of Summit and Les Peterson will take any and all actions necessary in
order to completely and officially correct the records of all applicable governmental and
quasi-governmental entities, including its own records, which indicate that Plaintiff’s
employment with Summit was terminated, that Plaintiff was terminated “for cause,” that
Plaintiff abandoned her position, or which indicate anything contrary to the findings of
this Court.
5. Defendant Village of Summit and Les Peterson will correct the records of all applicable
governmental and quasi-governmental entities, including its own records, to indicate that
Plaintiff Maria Gatlin retired from Defendant Village of Summit Police Department on
August 18, 2013.
6. Defendants Village of Summit and Les Peterson will take any and all actions necessary in
order to completely and officially correct the records of the Summit Police Pension Fund
and Summit Police Pension Board which indicate that Plaintiff’s employment with
Summit was terminated, that Plaintiff was terminated “for cause,” that Plaintiff
abandoned her position, or which indicate anything contrary to the findings of this Court.
7. Defendants Village of Summit and Les Peterson will take any and all actions necessary in
order to completely and officially correct the records of the Summit Police Pension Fund
and Summit Police Pension Board to indicate that Plaintiff Maria Gatlin retired from
Defendant Village of Summit Police Department on August 18, 2013.
8. To the extent necessary, Plaintiff will cooperate with Defendants so that Defendants can
fully comply with this Order.

WHEREFORE, Plaintiff Maria Gatlin prays that this Honorable Court grant her Motion for
Entry of Final Judgment.

Respectfully Submitted,
Maria Gatlin

By:
Kevin F. O’Connor
One of Her Attorneys

Kevin F. O’Connor (ARDC # 6300449)
Heewon O’Connor (ARDC # 6306663)
Ryan O. Estes (ARDC # 6312755)
O’Connor | O’Connor, P.C.
110 E. Schiller St., Ste. 312
Elmhurst, IL 60126
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