IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ACCESS LIVING OF METROPOLITAN CHICAGO, a not-for-profit corporation, and SHEILA AKHTAR, LARRY BIONDI, W. CAROL CLEIGH, MARY DELGADO, JAMES A. FERNEBORG, JENNIFER HART, SHARON LAMP, RENE DAVID LUNA, J. FREDERICK STARK, individually, Plaintiffs, v. CHICAGO TRANSIT AUTHORITY, Defendant COMPLAINT Plaintiffs Access Living of Metropolitan Chicago, Sheila Akhtar, Larry Biondi, W. Carol Cleigh, Mary Delgado, Jennifer Hart, James A. Ferneborg, Sharon Lamp, Rene David Luna, and J. Frederick Stark complain of Defendant Chicago Transit Authority as follows: INTRODUCTION 1. Plaintiffs bring this action to put an end to defendant's systemic failure to provide basic and necessary public transportation services to plaintiffs and other persons with disabilities. Plaintiff Access Living of Metropolitan Chicago (?Access Living?) advocates and provides services for thousands of people with disabilities every year. Each of the individual plaintiffs has a disability; most of the plaintiffs use a wheelchair or other assistive device, one of the plaintiffs is deaf, and one is blind. The individual plaintiffs and many of plaintiff Access Living?s clients, staff, and board members are regular riders on the public buses and trains operated by defendant, Chicago Transit Authority (?CTA? or ?defendant?), and rely on this transportation to travel to work, school, social events, and community activities. On a persistent and ongoing basis, defendant has discriminated against plaintiffs by denying them equal access to public buses and trains, in violation of Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. ?12131 et seq. and Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. ? 794. 2. The CTA has discriminated against plaintiffs based on their disabilities by failing to make its bus and train systems readily accessible to and usable by people with disabilities, and by knowingly subjecting people with disabilities to extremely hazardous conditions. Among the numerous examples of defendant?s systemic failure to provide plaintiffs with equal access to its buses are: (a) the mechanical lifts needed for mobility-impaired riders to board and disembark from CTA buses are frequently malfunctioning or nonfunctioning; (b) CTA bus drivers are inadequately trained in the use of the mechanical lifts, and have persistently failed to properly use the lifts and other boarding and safety equipment for individuals with disabilities; (c) CTA bus drivers often fail to call out stops, which adversely impacts people whose disabilities make it difficult to ascertain the location of the bus, such as people who are blind or mentally retarded; and (d) CTA bus drivers often fail or refuse to pick up riders with disabilities waiting at bus stops. 3. Among the numerous examples of the CTA?s systemic failure to provide equal access to plaintiffs on its trains are: (a) CTA has failed to implement a system to ensure that mobility impaired riders who use a wheelchair can embark and disembark from CTA?s trains safely; (b) CTA station agents are inadequately trained in the use of the gap-filler, which acts as a bridge between the train platform and the train car for riders with mobility impairments; (c) CTA elevators, which are the only means of access to elevated trains for riders who are mobility-impaired, are consistently broken or turned off, thereby stranding riders with disabilities on the streets and platforms and, further, are consistently maintained in a filthy condition; and (d) CTA train personnel often fail to call out train destinations and stops, which adversely impacts people whose disabilities make it difficult to ascertain the location of the train, such as people who are blind or mentally retarded. 4. Although plaintiffs have repeatedly complained about the foregoing and similar failures to provide equal access to the plaintiffs, the level of service provided to riders with disabilities has not significantly improved. 5. By ignoring the ongoing problems faced by plaintiffs and other riders with disabilities, by continuing to deny plaintiffs equal access to buses and trains, and by causing plaintiffs serious harm through their failure to maintain their buses, trains, and equipment in proper working order, defendant has treated and continues to treat plaintiffs and other riders with disabilities as second-class citizens, denying them their basic rights to equality and dignity. Defendant?s actions have also resulted in physical injury, humiliation, emotional distress, and pecuniary loss. To redress the CTA?s past and continuing violation of their rights under federal law, plaintiffs seek injunctive relief, declaratory relief, and damages. JURISDICTION AND VENUE 6. This Court has jurisdiction over this action pursuant to 28 U.S.C. ?1331 because the claims herein arise under federal statutes -- the Americans with Disabilities Act and the Rehabilitation Act of 1973. In addition, this Court has jurisdiction over plaintiffs? claims for declaratory relief pursuant to 28 U.S.C. ??2201 and 2202. 7. Venue is proper in the Northern District of Illinois because the defendant resides in this district within the meaning of 28 U.S.C. ?1391, and because the events, acts, and omissions giving rise to plaintiffs? claims occurred in this district. PARTIES 8. (a) Plaintiff Access Living is a center for independent living funded through the Rehabilitation Act, 29 U.S.C. ? 796f, to serve and represent people with disabilities in the Chicago metropolitan area. As a center for independent living, its mandated mission is to work for ?equal access of individuals with significant disabilities to society and to all services, programs, activities, resources, and facilities, whether public or private and regardless of the funding source.? 29 U.S.C. ? 796f-4. Access Living works toward the full equality, inclusion, and empowerment of people with all types of disabilities, including physical, cognitive, sensory, psychiatric and neurological disabilities. The purposes and goals of Access Living include: to act for and on behalf of people with disabilities in the Chicago area; to work to remove architectural, communicative, attitudinal, and programmatic barriers that interfere with the civil rights of people with disabilities to live independently in the communities of their choice; to take such actions as may be necessary to effect change in rules, practices or policies of government and private entities that are unlawful or inequitable as they relate to people with disabilities; and to provide advocacy for people with disabilities regarding access to work, transportation, education, recreation, and health care in the City of Chicago. (b) Access Living provides counseling, independent living skills training, advocacy, and information and referral services to people with disabilities. The majority of its employees, board members, and clients have physical disabilities. In order to gain access to Access Living?s services, Access Living?s clients require the train and bus services of the CTA. The staff and board require train and bus services to attend work, to attend governance meetings, and to further the goals and purposes of Access Living. (c) Congress requires Access Living ?to increase the availability and improve the quality of community options for independent living? and ?to provide independent living core services? for persons with disabilities, which includes ?individual and systems advocacy.? 29 U.S.C. ?? 796; 796f-4(b)(4) and (5). These ?community options? and ?core services? frequently require the use of dependable transportation and the ?systems advocacy? includes the eradication of discrimination against people with disabilities, including discrimination in public transportation. 9. Plaintiff Sheila Akhtar sustained a spinal cord injury in 1976 and has used a wheelchair since that time. She has a physical impairment that substantially limits her in major life activities, including the major life activity of walking. She works full-time at Access Living and also is attending a one-year paralegal course at Wright Junior College in Chicago. Ms. Akhtar regularly uses CTA buses and trains to travel throughout the city, attending meetings for her job, commuting to and from school, shopping, and visiting family and friends. 10. Plaintiff Larry Biondi has cerebral palsy. He has used a wheelchair since early childhood. He has a physical impairment that substantially limits him in major life activities, including the major life activity of walking. He is a graduate of Southern Illinois University, where he majored in speech and communication. He works full-time at Progress Center for Independent Living in Forest Park. Mr. Biondi regularly uses CTA buses and trains in connection with his job, to visit family and friends, and to attend restaurants and amusements in Chicago. 11. Plaintiff W. Carol Cleigh has used a wheelchair since 1994 due to injuries sustained from an accident as well as a neurological condition. She has a physical impairment that substantially limits her in major life activities, including the major life activity of walking. She has a bachelor?s degree in religious studies and a master?s degree in divinity. Ms. Cleigh works as a legislative aide for State Representative Julie Hamos. She is president of the board of directors of Progress Center for Independent Living and is also active in several other organizations. She regularly uses CTA buses and trains in connection with her job and community activities. 12. Plaintiff Mary Delgado is an individual with a mobility impairment due to the effects of polio. She has used a wheelchair since 1993. She has a physical impairment that substantially limits her in major life activities, including the major life activity of walking. She has worked full-time since 1972, and currently works for Access Living. Ms. Delgado regularly uses CTA buses, and occasionally uses CTA trains, in connection with her job, as well as to visit friends, go to restaurants, and attend sports events. 13. Plaintiff James A. Ferneborg is blind. He has a physical impairment that substantially limits him in major life activities, including the major life activity of seeing. He received a bachelor?s degree in history in 1973 from the University of Illinois at Chicago. He also has a master?s degree from DePaul University in rehabilitation administration. He is the Associate Executive Director at Blind Services Association. He is also a board member of several organizations, including Progress Center for Independent Living. Mr. Ferneborg regularly uses CTA buses and trains in connection with his job and community activities. 14. Plaintiff Jennifer Hart is deaf. She has a physical impairment that substantially limits her in major life activities, including the major life activity of hearing. She has bachelors? degrees in deaf education and in fine arts. She works part-time at Hearing Loss Link in Oak Park, Illinois, and part-time at Columbia College in Chicago. She is also attending school to become a graphic designer. She regularly uses CTA trains, and occasionally uses CTA buses, to commute to work, to visit family and friends, and to travel to cultural centers and events in Chicago. 15. Plaintiff Sharon Lamp has a neuro-muscular disorder and uses a wheelchair. She has a physical impairment that substantially limits her in major life activities, including the major life activity of walking. She has a bachelor?s degree in accounting from DePaul and worked as an accountant until 1993. She is currently in a masters? degree program in disability studies at the University of Illinois at Chicago, and is working towards her doctorate. Ms. Lamp regularly uses CTA trains, and occasionally uses CTA buses, to commute to school and to attend meetings at Progress Center for Independent Living, where she is a member of the board of directors. 16. Plaintiff Rene David Luna sustained a spinal cord injury in 1977 and has used a wheelchair since that time. He has a physical impairment that substantially limits him in major life activities, including the major life activity of walking. He has a bachelor?s degree in political theory from DePaul University. He currently works full time at Access Living and is also a fellow at the Center for Urban Research and Learning at Loyola University Chicago. Mr. Luna is doing graduate work at the University of Illinois at Chicago. He is on the boards of several community groups. Mr. Luna regularly uses CTA buses and trains in connection with his job, his education, and to attend music and sports events in the city. 17. Plaintiff J. Frederick Stark has a mobility-impairment due to a stroke he had in 1972, while a sophomore at the Wharton School of the University of Pennsylvania. He has a physical impairment that substantially limits him in major life activities, including the major life activity of walking. He graduated in 1977 with a B.S. in Management. He received an M.B.A. from New York University. He is active in many community groups and organizations, including ADAPT, Concrete Change, and Not Dead Yet. He is on the board of directors of Progress Center for Independent Living. Mr. Stark regularly uses CTA buses and trains to travel to meetings related to his various community activities. 18. Defendant CTA is a public entity within the meaning of Title II of the ADA. It is established pursuant to state law, Metropolitan Transit Authority Act, 70 ILCS 3605/1 et seq. FACTUAL ALLEGATIONS 19. CTA runs buses and trains in the city and nearby suburbs that are regularly used by plaintiffs and other persons with disabilities. It operates fixed route public transit lines along prescribed routes according to a fixed schedule as these terms are used in 42 U.S.C. ?12141(3). 20. CTA advertises and holds itself out to the public as offering routes on its buses and trains that are ?accessible? to riders with disabilities. The CTA Map, which the CTA makes available to the general public, states that ?[m]ore than half of all bus routes are accessible,? and uses a wheelchair symbol on its Map to identify those bus routes that are ?accessible routes.? The CTA Map also uses a wheelchair symbol on its Map to identify ?accessible train stations.? 21. Defendant has, on a persistent, ongoing, and systemic basis, failed to provide equal access to plaintiffs in the fixed route public bus and train lines that it operates. Through its acts and omissions, set forth more fully in the paragraphs that follow, defendant has denied plaintiffs equal access to the buses and trains that it operates. Bus Lines 22. Defendant has failed to make the CTA?s fixed route public bus system readily accessible to and usable by plaintiffs and other persons with disabilities by, among other things: a. the failure adequately to inspect, maintain, and service the mechanical bus lifts, which are needed to allow persons with mobility impairments to board and disembark. The lifts on defendant?s buses are frequently malfunctioning or nonfunctioning, thereby denying basic public transportation services to plaintiffs and other individuals with disabilities; b. the failure adequately to inspect, maintain, and service the bus doors through which persons with mobility impairments board and disembark. The doors on these buses are frequently malfunctioning or nonfunctioning, thereby denying basic public transportation services to plaintiffs and other individuals with disabilities; c. the failure adequately to inspect and maintain the safety clamps used to secure the wheelchairs of persons with mobility impairments on buses. These clamps are frequently missing, malfunctioning, or nonfunctioning; d. the failure adequately to inspect and maintain the belts and straps used to secure people with mobility impairments inside buses. This equipment is often malfunctioning or nonfunctioning; e. the failure adequately to train its employees, including drivers, regarding the proper and safe use of the equipment necessary to provide equal access to persons with disabilities on the buses CTA operates, including lifts, doors, clamps, and safety straps; f. frequently and persistently placing nonaccessible buses on purportedly accessible bus lines; g. the failure to assign to designated accessible bus lines a sufficient number, as determined by CTA?s own analyses, of buses with working lifts,; h. CTA bus drivers? and other personnel?s frequent and persistent failure properly to use the equipment needed to provide equal access to persons with disabilities on the bus lines operated by defendants, including lifts, doors, clamps, and safety straps. On numerous occasions, defendant?s employees have failed or refused to use this equipment at all, seriously endangering plaintiffs? health and safety; i. CTA bus drivers? frequent and persistent failure, because of plaintiffs? disabilities, to pick up plaintiffs and other riders clearly identifiable as having disabilities who are waiting at bus stops; j. CTA bus drivers? frequent and persistent failure to deploy lifts when requested by people whose disabilities are not readily apparent; k. CTA bus drivers? frequent and persistent failure to provide plaintiffs with adequate time to complete their boarding or disembarking from defendant?s vehicles; and l. CTA bus drivers? frequent and persistent failure to call out the bus number and make next stop announcements, severely impeding the ability of visually impaired persons, like Plaintiff Ferneborg, and people with mental retardation to know when to disembark defendant?s buses; m. CTA?s personnel?s failure to treat individuals with disabilities in a courteous and professional manner, including their failure to adequately document and address complaints about accessibility to the CTA bus system. . Train Lines 23. Defendant has failed to make the CTA?s fixed route public train system readily accessible to and usable by plaintiffs and other persons with disabilities by, among other things: a. the failure to keep CTA station elevators in operating condition; b. the failure adequately to supervise and monitor the cleanliness of the CTA station elevators; c. CTA employees? repeated failure to respond to calls from riders with disabilities seeking assistance in accessing the public train system; d. the failure adequately to train its employees to use the gap-filler, which acts as a bridge between the train platform and the train car for riders with mobility impairments; e. the repeated failure to ensure the availability of a gap-filler for riders with mobility impairments to board and disembark from the train; f. the failure to employ adequate numbers of personnel to ensure that riders with disabilities have equal access to the train and train station; g. the failure to provide an adequate number of designated wheelchair spaces on trains and to properly designate those cars that do have wheelchair spaces; h. the failure to provide at stations and on the telephone accurate information as to whether elevators are in service; i. the failure to provide prompt alternative accessible transportation to riders with mobility disabilities when a designated accessible station is not in fact accessible to said riders; j. the failure to implement a proper emergency evacuation program for the safe evacuation of riders with disabilities; k. CTA employees? frequent and persistent failure to provide sufficient time for persons with disabilities to board and disembark from the trains; l. CTA employees? frequent and persistent failure, upon arriving at a given station, to call out the train line and destination, severely impeding the ability of severely visually impaired persons, like Plaintiff Ferneborg, and people with mental retardation to know when to board defendants? trains; m. CTA employees? frequent and persistent failure to make next stop announcements severely impeding the ability of visually impaired persons, like Plaintiff Ferneborg, and mentally retarded persons to know when to disembark from defendant?s trains; n. the failure to provide visual information about decisions to reroute or express the train, severely impeding the ability of hard-of-hearing and deaf riders, such as Plaintiff Hart, to know when to board or disembark from the train; o. the failure to provide accessible paths of travel in and to CTA stations. p. CTA personnel's failure to treat individuals with disabilities in a courteous and professional manner, including their failure to adequately document and address complaints about accessibility to the CTA bus system. Harm to Plaintiffs 24. Plaintiff Access Living and the individual plaintiffs have filed numerous complaints concerning the problems with access described above using the complaint mechanism established by the CTA. 25. Despite plaintiffs? complaints, the quality of service provided to plaintiffs and other people with disabilities has not significantly improved on the bus and train lines operated by defendant, nor have plaintiffs been compensated or otherwise provided with a remedy for the repeated violations of their rights. 26. Defendant?s conduct, as set forth herein, violates clearly established federal law. 27. Denial of a service as fundamental as public transportation severely impedes plaintiffs and other people with disabilities from full and equal enjoyment of the rights of citizenship in a free society. In particular, the denial of full and equal access to public transportation results in isolation, loneliness, social deprivation; produces humiliation, frustration, and low self-image; limits employment opportunities; limits opportunities to participate in numerous programs, activities, and services (including those offered by Plaintiff Access Living); and imposes unnecessary, irrational, and unlawful obstacles to independent living. For all these injuries, plaintiffs are entitled to damages in an amount to be determined according to proof. 28. Defendant has seriously injured plaintiffs in other ways as well. Some of the plaintiffs have suffered physical injuries as the direct and proximate result of malfunctioning equipment or defendant?s failure to provide access. In addition to physical injuries and resulting medical expenses, plaintiffs? injuries include, without limitation, emotional distress, frustration, humiliation, time lost from education and work, expenses for alternative transportation, telephone charges, and pain and suffering. Furthermore, plaintiffs have repeatedly been delayed in arriving to work, school, church, medical appointments, social engagements, and other activities because of the acts and omissions described herein. For all these injuries, plaintiffs are entitled to damages in an amount to be determined according to proof. 29. Plaintiffs are informed and believe, and on that basis allege, that defendant has acted intentionally, willfully, in bad faith, with malice and oppression, and with reckless indifference for plaintiffs? rights under federal law, in committing the acts and omissions set forth herein. 30. Defendant is continuing to discriminate against plaintiffs based on their disabilities, by denying plaintiffs equal access to fixed route public transit, resulting in ongoing and irreparable injury to plaintiffs. 31. Plaintiffs have no plain, speedy, and adequate remedy at law. Pecuniary relief alone will not afford adequate and complete relief for the ongoing acts and omissions complained of herein. COUNT I VIOLATION OF TITLE II OF THE AMERICANS WITH DISABILITIES ACT, 42 U.S.C. ?12131 ET SEQ., BY THE CTA 32. Plaintiffs incorporate by reference each and every allegation set forth in paragraphs 1 through 31, inclusive. 33. In enacting the Americans with Disabilities Act of 1990 (?ADA?), Congress made specific findings that society has tended to isolate and segregate people with disabilities; that individuals with disabilities continually encounter various forms of discrimination, including both outright exclusion and the failure to make modifications to exclusionary criteria; that the Nation?s proper goals regarding individuals with disabilities are to assure equality of opportunity, full participation, independent living, and economic self-sufficiency for such individuals; that the continuing existence of unfair and unnecessary discrimination denies individuals with disabilities the opportunity to compete on an equal basis and to pursue those opportunities for which our free society is justifiably famous; and that continuing existence of discrimination and prejudice against people with disabilities costs the United States billions of dollars in unnecessary expenses. 42 U.S.C. ?12101(a). 34. The express purpose of the ADA is to provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities; to provide clear, strong, consistent, enforceable standards addressing discrimination against individuals with disabilities; and to ensure that the federal government plays a central role in enforcing the standards established in the Act on behalf of individuals with disabilities. 42 U.S.C. ?12101 (b). 35. Each individual plaintiff is a ?qualified individual with a disability? under the meaning of Title II of the ADA, 42 U.S.C. ?12131(2) . 36. The CTA is a ?public entity? within the meaning of Title II of the ADA. 42 U.S.C. ?12131(1). 37. The CTA operates a fixed route system of public transportation, under the meaning of Title II of the ADA. 42 U.S.C. ?12141(3). 38. Through the acts and omissions alleged herein, the CTA has, by reason of plaintiffs? disabilities: excluded plaintiffs from participation in the CTA?s programs, services and activities; denied plaintiffs the benefits of the CTA?s programs, services, and activities; and subjected plaintiffs to discrimination, in violation of Title II of the ADA, 42 U.S.C. ?12132. 39. Through the acts and omissions alleged herein, the CTA has impaired Plaintiff Access Living?s ability to serve people with disabilities by making it difficult or impossible for Access Living?s employees, board members, and clients to participate in community life or reach Access Living?s offices, and difficult or impossible for Access Living?s personnel to attend meetings in and around Chicago and to reach people with disabilities in the community. 40. Through the acts and omissions alleged herein, Access Living has been frustrated from achieving its purposes and goals, including the purpose of fostering independent living for people with disabilities. In addition, Access Living has been forced to divert limited resources from the organization?s regular activities in order to investigate and address the CTA?s conduct complained of herein. 41. The CTA?s acts and omissions set forth herein are in violation of the equal access and nondiscrimination requirements set forth in Title II of the ADA, and the regulations promulgated thereunder, and have resulted in injury to plaintiffs. 42. The CTA?s conduct constitutes an ongoing and continuous violation of Title II of the ADA and, unless restrained and enjoined from doing so, the CTA will continue to violate Title II of the ADA. The CTA?s acts and omissions, unless enjoined, will continue to inflict irreparable injuries for which plaintiffs have no adequate remedy under law. WHEREFORE, plaintiffs request the relief set forth below. COUNT II VIOLATION OF SECTION 504 OF THE REHABILITATION ACT OF 1973, AS AMENDED, 29 U.S.C. ?794 ET SEQ., BY THE CTA 43. Plaintiffs incorporate by reference each and every allegation set forth in paragraphs 1 through 31, inclusive. 44. Each individual plaintiff is an ?otherwise qualified individual with a disability? under the meaning of Section 504 of the Rehabilitation Act, 29 U.S.C. ?794 (?Section 504"). 45. The CTA operates a ?program or activity receiving Federal financial assistance? under the meaning of Section 504. 46. Through the acts and omissions alleged herein, the CTA has, by reason of plaintiffs? disabilities: excluded plaintiffs from participation in the CTA?s programs, services and activities; denied plaintiffs the benefits of the CTA?s programs, services, and activities; and subjected plaintiffs to discrimination. 47. Through the acts and omissions alleged herein, the CTA has impaired Plaintiff Access Living?s ability to serve people with disabilities by making it difficult or impossible for Access Living?s employees, board members, and clients to participate in community life or reach Access Living?s offices, and difficult or impossible for Access Living?s personnel to attend meetings in and around Chicago and to reach people with disabilities in the community. 48. Through the acts and omissions alleged herein, Access Living has been frustrated from achieving its purposes and goals, including the purpose of fostering independent living for people with disabilities. In addition, Access Living has been forced to divert limited resources from the organization?s regular activities in order to investigate and address the CTA?s conduct complained of herein. 49. The CTA?s acts and omissions set forth herein are in violation of the equal access and non- discrimination requirements set forth in Section 504, and the regulations promulgated thereunder, and have resulted in injury to plaintiffs. 50. The CTA?s conduct constitutes an ongoing and continuous violation of Section 504 and, unless restrained and enjoined from doing so, the CTA will continue to violate Section 504. The CTA?s acts and omissions, unless enjoined, will continue to inflict irreparable injuries for which plaintiffs have no adequate remedy and law. WHEREFORE, plaintiffs request the relief set forth below. PRAYER FOR RELIEF Plaintiffs pray for the following relief: 1. For a declaration that defendant?s acts and omissions violate plaintiffs? rights under the Americans with Disabilities Act of 1990 and Section 504 of the Rehabilitation Act of 1973; 2. For an injunction requiring defendant to provide individuals with disabilities full and equal access to its public transit operations, and restraining defendant from discriminating against individuals with disabilities who use their public transportation system; 3. For compensatory damages on behalf of the plaintiffs according to proof; 4. For punitive damages on behalf of the plaintiffs according to proof; 5. For plaintiffs? reasonable attorneys? fees and costs; 6. For such other relief as this Court deems just and proper. DEMAND FOR JURY TRIAL Plaintiffs hereby demand jury trial in this action pursuant to Federal Rule of Civil Procedure 38(b). Dated: February 8, 1999 Respectfully submitted, By:_______________________________________ An Attorney for Plaintiffs Louis J. Aurichio Karen I. Ward Amy B. Kelley Barry C. Taylor Butler, Rubin, Saltarelli & Boyd John W. Whitcomb Three First National Plaza Equip For Equality, Inc. Suite 1800 11 East Adams Street, Suite 1200 Chicago, Illinois 60602 Chicago, Illinois 60603 (312) 444-9660 (312) 341-0022 Kathleen C. Yannias Laura J. Miller 174 North Elmwood Access Living of Metropolitan Chicago Oak Park, Illinois 60302 310 South Peoria, Suite 201 (708) 386-0353 Chicago, Illinois 60607 (312) 226-5900