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In The Circuit Court Twentieth Judicial Circuit St. Clair County, Illinois Matthias Hawkins, Plaintiff, vs. East St. Louis City Clerk, Dorene Hoosman City of East St. Louis City Council, et al., Mayor Alvin Parks Councilman Roy Mosley Councilwoman Emeka Jackson Councilwoman Latoya Greenwood Councilman Robert Eastern III City Manager, Deletra Hudson Defendant(s) ) ) ) ) ) Case No.: ________________ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Petition for Injunctive Relief

Now come, Matthias Hawkins, PRO SE, herein known as Plaintiff, on behalf of himself, and all other similarly situated registered voters located in the City of East St. Louis, the County of St. Clair and the State of Illinois. The defendants named herein are elected city officials and paid staff in the City of East St. Louis. Plaintiff is a duly registered voter in the City of East St. Louis who currently resides at 1705-B Exchange Avenue, East St. Louis, IL 62205. Plaintiff now seeks the courts immediate assistance in enforcing his right to access public information held or supposed to be held by a public organization like the City of East St. Louis as provided for in Section 1 of the Illinois Freedom of Information Act (5 ILCS 140). Defendants et al have simply failed to respond to the

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Plaintiffs duly submitted written and signed request for information. Plaintiff prays the Courts mercy in the immediate issuance a Writ of Mandamus which compels the Defendants et al to immediately release the requested public information in the form requested (data disc) to the Plaintiff for review. Plaintiff hereby requests that the Court enjoin the City of East St. Louis and/or the City Clerk from withholding public records and to order the production of any public records improperly withheld from the Plaintiff. Pursuant to Section 11 of the Illinois Freedom of Information Act (FOIA), Plaintiff also requests that the Courts mercy in the recovery of legitimate legal expenses and/or attorneys fees. Plaintiff requests the immediate reimbursement of all costs involved with any public funds that have may have been misused or stolen, submitting the information request and/or filing fees, and $100,000.00 in damages for failing to perform this most basic public service at all, much less in a timely manner. The Defendants refusal to provide the public information requested severely impairs the ability of the Plaintiff to determine exactly how much damage is being done, if any, and what that damage may cost exactly. Further, there are several other investigations that require funding that Plaintiff desires to undertake and any funds granted by the Court would be used to make East St. Louis government more transparent and user friendly. Lastly, Plaintiff prays that the Court fines each of the Defendant public bodies $5,000.00 each for each violation pursuant to Section 11(j) of the Illinois Freedom of information Act because the Defendants et al have willfully and intentionally failed to comply with the Illinois Freedom of Information Act and acted in exceptionally bad faith as evidenced by the failure to respond to plaintiffs request for public information at all to date.

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Case Background 1. On or about March 28th, 2013, Plaintiff sent two Freedom of Information requests to the City of East St. Louis; (See Exhibit 1 & 2: FOIA Letters) 2. These letters were sent via the United State Postal Service by registered mail with a signature required; (See Exhibit 3: Registered Mail Receipts) 3. FOIA Request 1 was addressed to Deletra Hudson, City Manager for the City of East St. Louis and involved a request for documents regarding the Community Development Block Development Grant (CDBG) Program where nearly $2.5 million was spent to renovate and/or build 16 units of housing involving only 12 buildings; 4. FOIA Request 2 was addressed to Dorene Hoosman, elected City Clerk for the City of East St. Louis and involved a request for minutes from the meetings of the Tax Increment Finance Commission and Joint Review Boardwhich are boards that oversee tens of millions in public funds, as well as various Public Safety Reports; 5. Plaintiff has received no response whatsoever from the City of East St. Louis nor the City Clerk nor their attorney of record as of the date of this filing;

RESPECTFULLY SUBMITTED,

MATTHIAS HAWKINS, Petitioner

Dated this Thursday, May 30, 2013

CERTIFICATE OF SERVICE Matthias Hawkins certifies that he has caused a true and correct copy of the foregoing document to be served and delivered by hand upon Attorney Waggoner, Attorney of Record for the City of East St. Louis at 301 River Park Drive, East St. Louis, IL 62220 on Thursday, May 30, 2013 at City Council Chambers.