AFILED 5:14 PM 20191.001530 12wPerson Jury FILED 2/11l2019 5:14 PM IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS DOROTHY-BROWN CIRCUIT CLERK COUNTY DEPARTMENT, LAW DIVISION COOK COUNTY, IL DAVID KRUPA, 201 9L001 530 Plaintiff, v. No. CHICAGO TEACHERS UNION and JEAN INE MUIR a/k/a an Muir?, JURY TRIAL DEMANDED Defendants, and, MARTY QUINN, BETH QUINN, MICHAEL J. MADIGAN, CITIZENS FOR MARTY QUINN, and 13TH WARD DEMOCRATIC ORGANIZATION, . Respondents in Discovery. COMPLAINT FOR DEFAMATION NOW COMES Plaintiff, DAVID KRUPA, and for his Complaint against Defendants CHICAGO TEACHERS UNION and IEANINE MUIR (a/k/a ?Jan Muir?), with MARTY QUINN, BETH QUINN, MICHAEL J. MADIGAN, CITIZENS FOR MARTY QUINN, and 13TH WARD DEMOCRATIC ORGANIZATION as Respondents in Discovery pursuant to 735 ILCS states as follows: INTRODUCTORY This action presents just the latest instance of unlawful Machine conduct practiced against a reform minded 19 year old Aldermanic candidate by powerful and clearly worried supporters of his incumbent Machine opponent. Apparently ?ling thousands of false af?davits with the Board of Election Commissioners of the City of Chicago to remove David from the ballot was not enough (see Krupa v. Quinn, Case No. 19 cv 543 in the United States District Court for the Northern District of Illinois), David Krupa must now suffer his reputation being FILED DATE: 5:14 PM 2019L001530 smeared by false criminal allegations arising from a powerful Machine union and a staff member at a school where his opponent?s wife wife is an employee. The statements of that union and staff member that David somehow, at some unstated time, engaged in ?cyberstalking? and ?cyberbullying? by publishing offensive material on a school website, are false. David Krupa not only did not engage in any such conduct, has never attended or even entered the school in question. He therefore seeks judgment for defamation. PARTIES 1. Plaintiff DAVID KRUPA (hereinafter is a resident of Cook County, Illinois. 2. Defendant CHICAGO TEACHERS UNION (hereinafter is a labor organization as de?ned by the Illinois Education Labor Relations Act, 1 15 ILCS 5/1 et seq. The CTU is recognized by the Illinois Educational Labor Relations Board as the. ?Exclusive Representative? for teachers employed by Chicago Public Schools. The headquarters of the CTU is located at 1901 East Carroll Avenue, Chicago, Illinois. 3. Defendant EAN INE MUIR a/k/a an Muir is a resident of Cook County Illinois. While her actual name is ?Jeanine Muir?, MUIR commonly goes by the name an Muir.? I 4. Respondent in Discovery MARTY QUINN is joined pursuant to 735 ILCS 5X2- 204 (2018). MARTY QUINN is a resident of Chicago, Illinois. At all times relevant QUINN was an Alderman of the City of Chicago representing the 13th Ward of the City of Chicago and Chairman of Respondent in Discovery CITIZENS FOR MARTY QUINN. I 5. Respondent in Discovery BETH QUINN is joined pursuant to 735 ILCS 5/2?204 (2018). BETH QUINN is the wife of MARTY QUINN and a resident of Chicago, Illinois. FILED DATE: 21?11f2019 5:14 PM 6. Respondent in Discovery MICHAEL J. MADIGAN (hereinafter is joined pursuant to 735 ILCS 5/2?204 (2018). MADIGAN is a resident of Chicago, Illinois. At all times relevant hereto MADIGAN was Speaker of the Illinois House of Representatives, Representative in the Illinois House of Representatives representing the 22nd Illinois House District of the State of Illinois, Chairman of the Illinois Democratic Party, Democratic Ward Committeernan for the 13th Ward in the City of Chicago and Chairman of Respondent in Discoveryl 3TH WARD DEMOCRATIC ORGANIZATION. 7. Respondent in Discovery CITIZENS FOR MARTY QUINN (hereinafter FOR is joined pursuant to 735 ILCS 5/2?204 (2018). CITIZENS FOR QUINN was at all times relevant hereto an Illinois political committee based within Cook County, State of Illinois. 8. Respondent in Discovery 13TH WARD DEMOCRATIC ORGANIZATION (hereinafter is joined pursuant to 735 ILCS 5/2204 (2018). 13TH WARD was at all times relevant hereto an Illinois political committee with its principal place of business based in Cook County, State of Illinois. JURISICTION AND VENUE 9. This Honorable Court has subject matter jurisdiction over this matter pursuant to 111. Const. art. VI, IX. 10. This Honorable Court has personal jurisdiction over the Defendants pursuant to several subsections of 735 ILCS 5/2?209, including but not limited to because the Defendants I reside or are headquartered in Cook County, Illinois. FILED DATE: 2H?li2019 5:14 PM I I. This Honorable Court has personal jurisdiction over the Respondents in Discovery pursuant to several subsections of 735 ILCS 5/2?209, including but not limited to because the Defendants reside or are headquartered in Cook County, Illinois. 12. Venue is proper in this Honorable Court pursuant to 735 ILCS because the Defendants reside or are headquartered in Cook County, Illinois and because the events complained of took place in Cook County, Illinois. STATEMENT OF FACTS 13. DAVID is a candidate for the of?ce of Alderman for the 13"1 Ward of Chicago in the municipal election occurring in Chicago Illinois on February 26, 2019 (the ?Election?). 14. sole opponent in the Election is MARTY QUINN. 15. On information and belief QUINN holds his aldermanic position exclusively through the political support of MADIGAN, supports all political positions and operations of MADIGAN as a loyal surrogate, and receives and follows the directives of MADIGAN concerning political matters, including but not limited to (I) actions within the government of the City of Chicago, (2) actions as Alderman within the 13th Ward of the City of Chicago, and (3) political activities and endorsements. QUINN also routinely works on campaigns for MADIGAN and acts on behalf of MADIGAN as a political strategist and political operative. 16. . The purpose of CITIZENS FOR QUINN is to elect MARTY QUINN to office. CITIZENS FOR QUINN is staffed by and/or employs campaign workers and supporters of QUINN and MADIGAN. At all times relevant hereto, CITIZENS FOR QUINN acted by and through its employees and/or agents. . FILED DATE: 2111,2019 5;14 PM 2019mm 530 Defendant 13TH WARD conducts political activities in the 13th Ward of the City of Chicago under the direction of MADIGAN and MARTY QUINN. At all times relevant hereto, CITIZENS OR QUINN acted by and through its employees and/or agents. 18. MUIR is, on Plaintiff?s information and belief, based upon review of the website of Nathan Hale Elementary School of Chicago, Illinois, a teacher at said school. Nathan Hale Elementary School is located in the 13th Ward of the City of Chicago. 19. On Plaintiff 3 information and belief, based upon review of the website; of Nathan Hale Elementary School of Chicago, BETH QUINN is also employed at said school and is a colleague of MUIR. 20. On or before February 1, 2018, Defendants, and possibly others unknown to Plaintiff including but not limited to one or more Respondents in Discovery, created a letter on the letterhead of the CTU and signed by MUIR (the ?False Letter?), a copy of which is attached hereto as Exhibit 21. The False Letter opens with the salutation ?Dear 13th Ward Resident.? 22. The False Letter contains the statement that MUIR is a ?middle school teacher? and a ?member of the Chicago Teachers Union.? 23. The False Letter contains the statement that DAVID engaged in ?cyberstalking? and ?cyberbullying? by ?breaching a school computer and posting disturbing language and imagesthat shocked me and my students? (hereinafter the ?Statement?). 24. The False Letter contains the statement that that ?this letter is part of my attempt to hold him accountable for his actions? referring to DAVID. FILED DATE: 21"] ?13201 9_5:14_ PM 2019L001530 25. The False Letter contains the statement that purported conduct ?demonstrates a complete disregard for women and a pattern of judgment that disquali?es him . for public office.? 26. In the False Letter, MUIR urged voters in the 13th Ward ?not to vote for Mr. Krupa in the upcoming municipal election.? 27. Defendants and possibly others unknown to Plaintiff including but not limited to one or more Respondents in Discovery, caused copies of the False Letter to be sent to an extensive, but as yet unknown number of people by use of the mails and internet, with the number of recipients believed to be in the tens of thousands. 28. The actions taken by MUIR were taken as actions of both WIR individually and the CTU. COUNT I Defamation Per Se 29. DAVID re-alleges and incorporates by reference paragraphs 1 through 28 as though fully set forth herein. 30. The Statement is completely false. In fact, DAVID has never attended or even entered Nathan Hale Elementary School. 31. Defendants knew that the Statement was false at the time the False Letter was Created and published, or acted with reckless disregard concerning the veracity of the Statement. 32. Defendants published a false written statement that was intended to impeach Plaintiff?s honesty, integrity, virtue, or reputation. 33. Defendants? defamatory statement was published maliciously and With intent to destroy the Plaintiffs reputation in general and Plaintiff? chances for election as Alderman for the 13th Ward in the City of Chicago in the Election. 6 . FILED DATE: 21119019 5:14 PM 2019L001530 34. The False Letter contains statements that MUIR was a ?victim of cyberstalking and cyberbullying by Aldermanic Candidate David Krupa? and otherwise described conduct that constitutes one or more criminal offenses under the laws of Illinois. 35. As a proximate result of the foregoing defamatory statements by Defendants, Plaintiff suffered injuries, including injuries to his reputation and other damages. 36. The foregoing defamatory statements were made in bad faith by Defendants with the knowledge of their falsity or in reckless disregard concerning the veracity of the Statement and with intent to harm, so as to justify an award of punitive damages. 37. Defendants have engaged in defamation per .93 against Plaintiff by falsely imputing his commission of a criminal Offense. WHEREFORE, Plaintiff, DAVID KRUPA, respectfully requests that this Honorable Court enter judgment in his favor and against Defendants CHICAGO TEACHERS UNION and JEANTNE MUIR (a/k/a ?Jan Muir?) for compensatory damages in an amount in excess of ONE MILLION ($1,000,000) DOLLARS, and for exemplary damages in excess of THREE MILLOIN ($3,000,000) DOLLARS to punish Defendants, and defer Defendants and others from similar conduct in the future. COUNT II Defamation per Ouod 38. DAVID re-alleges and incorporates by reference paragraphs 1 through 36 as though fully set forth herein. 39. Defendants have engaged in defamation per quad against Plaintiff. WHEREFORE, Plaintiff, DAVID KRUPA, respectfully requests that this Honorable Court enter judgment in his favor and against Defendants CHICAGO TEACHERS UNION and JEANINE MUIR (aflda ?Jan Muir?) for compensatory damages in an amount in excess of ONE 7 FILED DATE: 211:2919 5_:14 PM 2019.001 530 MILLION ($1,000,000) DOLLARS, and for exemplary damages in excess of THREE MILLOIN ($3,000,000) DOLLARS to punish Defendants, and defer Defendants and others from similar conduct in the future. Anthony J. Peraica Associates, Ltd. 5130 South Archer Ave. Chicago, IL 60632 (773) 735?1700 Attorney No. 5401 1 Respectfully submitted, DAVID KRUPA FILED DATE: 2f1?1f2019 5:14 PM 2019!.001530 CERTIFICATION Under penalties as provided by law pursuant to section 1?109 ofthe Code of Civil Procedure, the undersigned certi?es that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certi?es as aforesaid that he verily believes the same to be true. 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