STATE OF ILLINOIS
IN THE EIGHTH JUDICIAL CIRCUIT
ADAMS COUNTY
RONI QUINN, as the parent and guardian )
�J.L. )
)
)
Plaintiff, )
)
Vs. ) Case No. 2020-MR- 166
)
QUINCY PUBLIC SCHOOL DISTRICT )
NO. 172. )
)
)
, Defendants. )
FIRST AMENDED VERIFIED COMPLAINT
Plaintiff, RONI QUINN, ("Quinn") as the parent and guardian of J.L., by and through her
attorney, Thomas G. DeVore, Erik D. Hyam, and the Silver Lake Group, Ltd., for her First
Amended Complaint for Declaratory and Injunctive Relief against Defendant, QUINCY PUBLIC
DISTRICT NO. 172, ("Board") hereby states as follows:
U
FACTS COMMON TO ALL CO NTS
1. Quinn resides in Adams County, Illinois.
2. Quinn is the biological mother and legal guardian of J.L.
3. J.L. attends the 4th grade in the Quincy Public School District #172 ("District")
which District is within Adams County.
4. Quinn brings this cause of action on her own behalf, and on behalf of her minor
child J.L.