FILED
Kankakee County
21st Judicial Circuit
8/1/2019 11:30 AM
Sandra M Cianci
CIRCUIT COURT CLERK

IN THE CIRCUIT COURT FOR THE TWENTY-FIRST JUDICIAL CIRCUIT
KANKAKEE COUNTY, ILLINOIS
JOHN KRAFT,
EDGAR COUNTY WATCHDOGS, INC.
PLAINTIFFS,
v.
CITY OF KANKAKEE
DEFENDANT.

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Case No.

2019CH146

COMPLAINT
NOW COME the Plaintiffs, JOHN KRAFT, and the EDGAR COUNTY WATCHDOGS,
INC., by their attorneys, AMBROZIAK & ASSOCIATES, and bring this suit to Overturn
Defendant's refusal, and willful violation of the Illinois Freedom of Information Act, to properly
respond to Plaintiffs’ Freedom of Information Act request. In support of this Complaint, Plaintiffs
state as follows:
INTRODUCTION
1.

Pursuant to fundamental philosophy of the American constitutional form of government, it

is the public policy of the State of Illinois that all persons are entitled to full and complete
information regarding the affairs of government and the official acts and policies of those who
represent them as public officials and public employees consistent with the terms of the Illinois
Freedom of Information Act (hereafter "FOIA"). 5 ILCS 140/1.
2.

Restraints on access to information to the extent permitted by FOIA are limited exceptions

to the principle that the people of this state have a right to full disclosure of information relating
to the decisions, policies, procedures, rules, standards and other aspects of governmental activity
that affect the conduct of government and the lives of the people. 5 ILCS 140/1.
1 Page

 3.

All public records of a public body are presumed to be open to inspection or copying. Any

public body that asserts that a record is exempt from disclosure has the burden of proving by clear
and convincing evidence that it is exempt. 5 ILCS 140/1.2.
4.

Each public body shall, promptly, either comply with or deny a request for public records

within 5 business days after its receipt of the request, unless the time for response is properly
extended under subsection (e) of this Section. Denial shall be in writing as provided in Section 9
of this Act. Failure to comply with a written request, extend the time for response, or deny a request
within 5 business days after its receipt shall be considered a denial of the request. 5 ILCS 140/3(d).
Emphasis added.
5.

Each public body denying a request for public records shall notify the requester in writing

of the decision to deny the request, the reasons for the denial, including a detailed factual basis for
the application of any exemption claimed, and the names and titles or positions of each person
responsible for the denial. Each notice of denial by a public body shall also inform such person of
the right to review by the Public Access Counselor and provide the address and phone number for
the Public Access Counselor. Each notice of denial shall inform such person of his right to judicial
review under Section 11 of this Act. 5 ILCS 140/9(a). Emphasis added.
6.

"Except as to causes the court considers to be of greater importance, proceedings arising

under this Section shall take precedence on the docket over all other causes and be assigned for
hearing and trial at the earliest practicable date and expedited in every way" 5 ILCS 140/11.
PARTIES
7.

Plaintiffs, JOHN KRAFT and the EDGAR COUNTY WATCHDOGS, INC. (hereafter

“ECW”), are the FOIA requesters in this case. Plaintiffs are News Media and Nonprofit as defined
in 5 ILCS 140/2.

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 8.

CITY OF KANKAKEE (hereafter “KANKAKEE”) is a public body located in Kankakee

County, Illinois.
9.

The records sought are non-exempt public records of KANKAKEE.

10. KANKAKEE willfully and intentionally violated the FOIA by Defendant’s ongoing and
constant refusal to, and failure to properly respond to the FOIA request shown below and in the
attached Exhibits hereto and incorporated herein.
11. The aforementioned paragraphs 1-10 are incorporated in Count I as if fully restated therein.
COUNT I
FOIA Request - July 11, 2019
12. On July 11, 2019, Plaintiff Kraft, on behalf of ECW, submitted a request pursuant to the
FOIA to Defendant Kankakee by emailing the Kankakee Clerk, and the Kankakee Mayor. See
Exhibit A. In their July 11 FOIA request, Plaintiff sought the following documents:
1) A copy of all sales tax sharing agreements/settlements approved at a city council
within the past 30 days; and
2) A copy of the response sent to the Daily-Journal who requested substantially the
same information. See Exhibit A.
13. On July 22, 2019, six (6) business days after Kankakee’s receipt of the FOIA request,
Plaintiff emailed the Kankakee Clerk and Kankakee Mayor, informing the Mayor that the
requested records are late and again asking for said records. See Exhibit B1. By statute,
Defendant’s response must be either denied, extended, or otherwise responded to within 5 business
days after receipt of the request, or July 19, 2019. 5 ILCS 140/3(d).
14. On July 24, 2019, eight (8) business days after Kankakee’s receipt of the FOIA request,
Plaintiff emailed the Kankakee Clerk and Kankakee Mayor, stating “Third request, and second
reminder that this FOIA request is late and your inactions are in violation of state law.” See Exhibit
3 Page

 B1. Four minutes later, Plaintiff emailed Kankakee and asked them to disregard his previous email
due to Defendant having responded while Plaintiff was drafting his email. See Exhibit B2.
15. On July 24, 2019, eight (8) business days after Kankakee’s receipt of the FOIA request,
Kankakee responded to Plaintiff by denying item #1 of the request by claiming Kankakee “is not
in possession of agreements that have been entered into by the City and any other party.” See
Exhibit C1 and C2.
16. At no time did Plaintiff request copies of agreements “entered into by the City and any
other party.” Rather, Plaintiff’s request was for agreements/settlements “approved at a city council
in the past 30 days.” See Exhibit A.
17. By not responding to Plaintiff’s request in the five-day timeframe imposed by 5 ILCS
140/3(d), Defendant DENIED Plaintiff’s July 11, 2019 FOIA request under 5 ILCS 140/3(d).
Accordingly, Defendant violated the FOIA by not responding pursuant to statutorily mandated
timelines.
18. Furthermore, Defendant Kankakee’s July 1, 2019, Meeting Agenda listed, as action item
numbers 15 (A) (1), (2), (3), (4), and (5), which are the agreements approved at a city council as
Plaintiff requested. See Exhibit D, page 24. The council Motioned, Seconded, and voted on each
of these items, and in each vote the Motion passed.
19. The Meeting video of July 1, 2019, is available on Kankakee’s website at
https://citykankakee-il.gov/chambervideo.php and by selecting “Council Meeting 7-1-2019
resume from Ex Session.” These five settlements, which are the subject of the FOIA request, are
the first items in the video which were voted on, and approved, by the city council.

4 Page

 20. It is unfathomable that Kankakee would vote to approve five separate settlement
agreements and never retain a copy of those settlements which were voted on. Accordingly,
Defendant improperly DENIED item number 1 of Plaintiffs’ July 11, 2019 FOIA request.

WHEREFORE, JOHN KRAFT and EDGAR COUNTY WATCHDOGS, INC. pray that this
Honorable Court grant the following relief:
A. In accordance with 5 ILCS 140/11(h) of the Freedom of Information Act, afford this
case precedence on the Court's docket except as to causes the Court considers to be of
greater importance, assign this case for hearing and trial at the earliest practicable
date, and expedite this case in every way; and
B. Declare that the KANKAKEE has violated the FOIA; and
C. Order KANKAKEE to produce the requested records; and
D. Enjoin KANKAKEE from withholding non-exempt public records under FOIA; and
E. Order the KANKAKEE to pay civil penalties; and
F. Award Plaintiffs reasonable attorneys' fees and costs; and
G. Award such other relief the Court considers just and equitable.
RESPECTFULLY SUBMITTED
/S/ Denise M. Ambroziak
Denise M. Ambroziak

Denise M. Ambroziak
ARDC #6244325
AMBROZIAK & ASSOCIATES
Attorney for Plaintiffs
550 West Woodstock St. Ste 107.
Crystal Lake, IL 60014
(815) 459-4949
ambroziaklaw@comcast.net

5 Page

 EXHIBIT A

me: 

T0: KASshmin; WW
Bcc: 

Subject: FOIA request (City of Kankakee) 7-11-2019
Date: Thursday, July 11, 2019 9:19:00 PM

 

On behalf of the Edgar County Watchdogs, Inc. and in accordance with the Freedom of
Information Act I am ordering the following public records.

If you are not the FOIA of?cer, you are required to immediately forward this records order to
the appropliate FOIA of?cer as required by statute [5 ILCS 

You are required to provide these records according to the timeline set forth in the ??eedom of
infonnation act.

I am ordering the following public records under the Freedom of Information Act:

 



same information.

I, and the organizations I represent (Disclosure News Magazine, Edgar County Watchdogs Inc,
and American Watchdogs Inc), qualify as both media and non-profit under the definitions in
Section 2 (c?10) ("Commercial purpose?), and the principal purpose of the request is
to access and disseminate information concerning news and current or passing
events, or for articles of opinion or features of interest to the public.;
Section 2 (?News media?) as an Investigative Reporter for Disclosure News Magazine, an
online and printed newspaper, and an Investigative Reporter for the Edgar County Watchdogs,
an online news site, and am engaged in making news reels and other motion picture for public
viewing, and as a news service to provide news and data to news or anization(s) and
nonprofits; Section 2 ("Recurrent requester"); and Section 2 (?Voluminous request")
of the Freedom of Information Act, for the purposes of being exempt to the provisions of
Section 3.1 (Requests for commercial purposes); Section 3.2 (Recurrent reques ters); Section
3.6 (Voluminous requests), and Section 6 (Authority to charge fees).

This is also a request for fee waiver, should any fees be imposed, as this information bears
on the public business of this public body and will be used to inform citizens of the
actions of their public officials and employees, of their rights and responsibilities, of
news and current or passing events, and for articles of opinion or features of interest to
the public. The principal purpose of this request is to access and disseminate
information regarding the health, safetv, and welfare or the legal rights of
the general public and is not for the principal purpose of gaining a personal
or commercial benefit.

7 Page

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EXHIBIT B1

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13|Page

EXHIBIT C1

From: 

To: 
Subject FOIA 19-308
Date: Wednesday, de 24, 2019 8:51:48 AM

Attachments: 19-308 John Kraftgf


 

SEE ATTACHED

Kristine Schmitz
City of Kankakee
304 S. Indiana Ave.
Kankakee, IL 60901
815-936-3559

Visit us at citykankakee-il. gov.

Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended
recipient(s) and may contain con?dential and privileged information. Any unauthorized review, use, disclosure or
distribution is prohibited. Ifyou are not the intended recipient, please contact the sender - by phone if possible - and

destroy all copies of the original message.

Usage Notice: Any non-business usage - jokes, spam or other inappropriate material - will potentially put the sender
and/or recipient on the blocked list prohibiting future use of the system to said sender and/or recipient

15 Page

EXHIBIT C2

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RE Cny of Kaukakee F014 Ree/m: Number [97308

Dear M: K1311,

On July 11, 21:19, the Guy of Kankakee your FOIA 1eques1 "111:1.
1equesved the rdlowmg

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or Copymg "511,03 2 ram also am the (my 11:1; 511 clugaum lo
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You have a ugln 1e have me deme1 afymu' request renewed b) we Publlc Acces Counselm
(PAC) al Office of me Anome) Geue1e1 ILCS 140/9 You can file you.
Reques1 for Renew PAC by anlg |o



Public Access Counselor

Of?ce of the Attomey General

500 South 2nd Street Spring?eld, Illinois 62706
Fax: 217-782-1396

E-mail: publicaccess??atg.stateilus

 

You also have the right to seek judicial review of your denial by ?ling a lawsuit in the State
circuit court. 5 ILCS 140/11.

If you choose to ?le a Request for Review with the PAC, you must do so within 60 calendar
days of the date of this denial. 5 ILCS Please note that you must include a copy of
your original FOIA request and this denial letter when ?ling a Request for Review with the PAC.

If you have further questions, please contact me at 815-936-3618 or via email at


Sincerely,
KW 
Kiistine Schmitz
FOIA OFFICER
City of Kankakee

Enclosures

18 Page

EXHIBIT 

  

Donald E. Green Public Safety Center
?w City Council Chambers

 
 

?I:mur-? 385 East Oak Street
KEE Kankakee, Illinois 60901

CITY COUNCIL AGENDA
MONDAY, JULY 1, 2019
7:00 P.M.

1. CALL TO ORDER

2. PRAYER - MRS. VURNICE MALONEY FROM GARDEN 0F PRAYER YOUTH
CENTER

3. PLEDGE OF ALLEGIANCE - YOUTH FROM GARDEN OF PRAYER YOUTH
CENTER

4. PUBLIC COMMENTS Please give your name and direct your comments to the
Mayor. Comments are limited to ?ve minutes.

5. ROLL CALL
A) CITY COUNCIL
B) DEPARTIVIENT HEADS

6. NIINUTES - MONDAY, JUNE 17, 2019
7. PETITIONS

8. COMMUNICATIONS
A) KANKAKEE AREA YMCA IS REQUESTING A NOISE PERNHT FOR
AREA YMCA COMMUNITY ON
WEDNESDAY, JULY 3, 2019, FROM 5:00 P.M. UNTIL 7:00 P.M.

B) FAMILY DOLLAR IS REQUESTING STREET CLOSURE OF THE
ALLEY NEXT TO FAMILY DOLLAR ON COURT STREET BETWEEN
COURT STREET AND OAK STREET TO HOST A OF JULY
ON THURSDAY, JULY 4, 2019, FROM 5:00 P.M. UNTIL 9:00 P.M.

C) REVISED REQUEST: PLEASANT GROVE MISSIONARY BAPTIST
CHURCH IS REQUESTING PERMISSION TO HOST THEIR
BIBLE SCHOOL PARADE 2019? ON SATURDAY, JULY 6,
2019, FROM 2:30 P.M. UNTIL 3:15 P.M.

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D)

E)

F)

REVISED REQUEST: PLEASANT GROVE MISSIONARY BAPTIST
CHURCH IS REQUESTING STREET CLOSURE OF THE WEST SIDE OF
FAIRMONT AVENUE AND SPRUCE STREET TO THE EAST SIDE OF
ILLINOIS AVENUE AND SPRUCE STREET TO HOST AN 
ON SUNDAY, JULY 14, 2019, FROM 1:00 P.M. UNTIL

2:15 P.M.

ZION GATE MISSIONARY BAPTIST CHURCH IS REQUESTING
STREET CLOSURE OF OAK STREET BETWEEN GREENWOOD
AVENUE AND WILDWOOD AVENUE, ROSEWOOD AVENUE
BETWEEN COURT STREET AND CHESTNUT STREET TO HOST
THEIR CHURCH ON SATURDAY, AUGUST 17,
2019, FROM 9:30 A.M. UNTIL 4:30 P.M.

KANKAKEE SCHOOL DISTRICT 111 IS REQUESTING STREET
CLOSURE OF MERCHANT STREET WEST OF SCHUYLER AVENUE,
MINER SQUARE CIRCLE, AND THE NORTH CLOCKTOWER LOT TO
HOST THE BACK TO SCHOOL ON TUESDAY,
AUGUST 13, 2019, FROM 1:30 P.M. UNTIL 8:30 P.M.

9. STANDING COMMITTEES

A)

B)

C)

BUDGET COMMITTEE MONDAY, JUNE 10, 2019
BUDGET COMMITTEE TUESDAY, JUNE 18, 2019

COMMUNITY DEVELOPMENT COMMITTEE- MONDAY, MAY 6, 2019

10. REPORTS OF OFFICERS

A)

APPROVAL OF BILLS - $556,814.62

11. UNFINISHED BUSINESS

A)

12. NEW BUSINESS

A)

B)

C)

D)

ORDINANCE DECLARING CERTAIN PROPERTY SURPLUS OF THE
CITY OF KANKAKEE POLICE DEPARTMENT AND
AUTHORIZING THE SALE THEREOF

ORDINANCE ADOPTING THE PREVAILING WAGE RATE - 2019
ORDINANCE ADOPTING TAX INCREMENT FINANCING FOR THE
CITY OF KANKAKEE RIVERFRONT TAX IN CREMENT FINANCING
DISTRICT

ORDINANCE DESIGNATING THE CITY OF KANKAKEE

RIVERFRONT TAX INCREMENT FINANCING DISTRICT
REDEVELOPMENT PROJECT AREA

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E)

F)

G)

H)

ORDINANCE APPROVING THE CITY OF KANKAKEE RIVERFRONT
TAX INCREMENT FINANCING DISTRICT REDEVELOPMENT
PROJECT PLAN AND PROJECT

RECOMIVIENDATION TO ACCEPT THE ENGINEERING PROPOSAL
FROM PIGGUSH ENGINEERING, INC. OF $6,860.00 FOR LAND
SURVEYING SERVICES FOR RIVERSTONE DRAINAGE DITCH 
RIVERSTONE PARKWAY

RECOMMENDATION TO AWARD THE BID IN THE AMOUNT OF
$482,951.81 TO KANKAKEE VALLEY CONSTRUCTION COMPANY,
INC. FOR 2019 NET STREET MAINTENANCE PROGRAM, PEI JOB.
NO 19028.0301

APPOINTMENTS

13. MOTIONS AND RESOLUTIONS

A)

B)

C)

D)

E)

F)

PROCLAMATION DECLARING JULY 2019 AS NATIONAL LEAGUE
OF CITIES SMALL CITIES MONTH

RESOLUTION APPROVING A MEMORANDUM OF UNDERSTANDING
WITH RING, LLC REGARDING A DIGITAL NEIGHBORHOOD
WATCH APPLICATION

RESOLUTION AUTHORIZING THE EXECUTION OF A SERVICE
AGREEMENT WITH OXCART PERMIT SYSTEMS, LLC TO DEVELOP
AN INTERNET APPLICATION FOR VEHICLE PERMIT
APPLICATIONS

RESOLUTION AUTHORIZING THE CHIEF OF POLICE OF THE CITY
OF KANKAKEE TO APPLY FOR AND ACCEPT FUNDS FOR 2019
DEPARTMENT OF JUSTICE FUNDING OPPORTUNITY BJA-2019-
15364

RESOLUTION APPROVING AN INTERGOVERNMENTAL
AGREEMENT WITH THE STATE OF ILLINOIS AND THE CITY OF
KANKAKEE APPROPRIATING FUNDS FOR THE HOBBIE AVENUE
IMPROVEMENT PROJECT MFT SECTION NUMBER 15-00278-00-FP

RESOLUTION APPROVING 2019 MOTOR FUEL TAX STREET
MAINTENANCE PROGRAM, SECTION GROUP IV,
PEI JOB O. 19028.0301 IN THE AMOUNT OF $142,000.00

14. EXECUTIVE SESSION

A)

PERSONNEL: THE APPOINTMENT, EMPLOYMENT,
COMPENSATION, DISCIPLINE, PERFORMANCE, OR DISNIISSAL OF
SPECIFIC EMPLOYEES OF THE PUBLIC BODY OR LEGAL COUNSEL
FOR THE PUBLIC BODY

22 Page

B)
C)

D)

E)

F)

G)

APPOINTMENTS

PERSONNEL

PENDING 0R IMMINENT LITIGATION

A) RE: CITY OF CHICAGO V. CITY OF KANKAKEE ET AL.
MATTER NO. 00322-00001

1?

SETTLEMENT AGREEMENT AND RELEASE WITH
RTA RE DIRECT EDAS

AGREEMENT BETWEEN CITY OF KAN KAKEE AND
HENRY SCHEIN, INC. REGARDING THE RTA
SETTLEMENT AND RELEASE OF FUNDS

AGREEMENT BETWEEN THE CITY OF KANKAKEE,
INSPIRED DEVELOPMENT, LLC AND RYAN LLC
REGARDING THE RELEASE OF FUNDS UPON FINAL
RESOLUTION OF LITIGATION

SETTLENIENT AGREEMENT AND RELEASE
BETWEEN RTA, COOK COUNTY, THE CITY OF
KANKAKEE AND MTS

AGREEMENT BETWEEN THE CITY OF KAN KAKEE
AND MTS REGARDING THE RTA SETTLEMENT AND
RELEASE OF FUNDS

UNION CONTRACTS

REVIEW OF EXECUTIVE SESSION MINUTES - (TO BE REVIEWED
EVERY SIX MONTHS)

MOTION TO RETURN TO OPEN SESSION

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15. ACTION RESULTING FROM THE EXECUTIVE SESSION

A) RE: CITY OF CHICAGO V. CITY OF KANKAKEE ET AL.
MATTER N0. 00322-00001

1.

SETTLEMENT AGREEMENT AND RELEASE
WITH RTA RE DIRECT EDAS

AGREEIVIENT BETWEEN CITY OF KANKAKEE
AND HENRY SCHEIN, INC. REGARDING THE RTA
SETTLEMENT AND RELEASE OF FUNDS

AGREEMENT BETWEEN THE CITY OF
KANKAKEE, INSPIRED DEVELOPMENT, LLC
AND RYAN LLC REGARDING THE RELEASE OF
FUNDS UPON FINAL RESOLUTION OF
LITIGATION

SETTLEMENT AGREEMENT AND RELEASE
BETWEEN RTA, COOK COUNTY, THE CITY OF
KANKAKEE AND MTS

AGREEMENT BETWEEN THE CITY OF
KANKAKEE AND MTS REGARDING THE RTA
SETTLEMENT AND RELEASE OF FUNDS

16. CITY COUNCIL MENIBERS CONEMENTS

17. DEPARTMENT HEAD 

18. ADJOURNMENT

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