IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

CLINT HARRIS and

(Name deleted from internet copy),

by his/her father and

next friend, CLINT HARRIS,

Plaintiffs,

v.

The CITY OF CHICAGO and

RICHARD M. DALEY, Mayor,

Defendants.

Now Come Plaintiffs, Clint Harris and (name deleted), by (his/her) father and next friend Clint Harris, and complaining of Defendants, City of Chicago and Richard M. Daley, Mayor, state as follows:

1. This case is brought pursuant to 42 U.S.C. § 1983, alleging a violation of Plaintiffs’ civil rights by Defendants City of Chicago and its Mayor, Richard M. Daley. Plaintiffs allege that Defendants planned ceremony commemorating the September 11, 2001, tragedies is in violation of the Establishment Clause and should be enjoined.

2. This Court has jurisdiction under 28 U.S.C. § 1343 (3), which provides for District Court jurisdiction of actions to redress the deprivation under color of any right or privilege secured by the federal Constitution. Venue is proper in this Court under 28 U.S.C. 1391, as the acts giving rise to the cause of action all occurred within the City of Chicago.

3. Plaintiff Clint Harris is an individual taxpaying citizen of the City of Chicago. His (child), (name deleted), is (deleted) years old. Neither plaintiff is an adherent of any religious sect or belief. Plaintiff (the child) appears as Plaintiff through Clint Harris, (his/her) father and next friend.

4. Defendant City of Chicago is a municipality in the Northern District of Illinois. It has approximately 3,000,000 residents.

5. Defendant Richard M. Daley is the Mayor of Chicago. As such, he is the Chief Executive Officer and administrator of the city. Specifically, the Mayor and his office staff promulgated a news release (attached hereto as Exhibit A) regarding the planned "remembrance" ceremony on September 11, 2002, in the Civic Center Plaza.

6. As described in the Mayor’s press release, the City is intending to hold an "Interfaith Observance and Unity Prayer" ceremony commemorating the September 11, 2001, tragedies. It is to occur on September 11, 2002, the one year anniversary of the events.

7. The "centerpiece" of the ceremony is to be a prayer, which will receive a "mass reading". The prayer is called the "Chicago Prayer of Hope, Unity and Remembrance". It was written, presumably at the City’s request, by various prominent religious leaders in the City.

8. The City has announced that it will print up and distribute the prayer to the "audience" and to churches, synagogues, mosques and other places of worship.

9. The press release also states that:

"... houses of worship across the city will ring bells or engage in other traditional expressions of their faith, such as the call of muezzin in mosques and the chanting of priests in Hindu temples.

"... Various religious leaders will share the podium.

"The Mayor urged Chicagoans to participate in the ceremony, but asked children to remain in school. He asked schools to suspend their normal activities at noon so students can share in the observance.

"He said the City has asked houses of worship across the city to remain open throughout the day for individual prayers and meditation."

10. Plaintiff (name deleted) attends (name of school), a Chicago Public School.

11. Plaintiff Clint Harris has placed a telephone call to the City of Chicago in an attempt to determine the contents of the Chicago Prayer, but the City of Chicago refused to provide a copy of the prayer, even though it exists.

12. Plaintiff Clint Harris also called the Office of the Archbishop of Chicago. Personnel there reported that, although the Archbishop had seen the prayer, the City instructed the office not to release a copy to anyone before the ceremony.

13. Plaintiffs are informed, and so allege, that the planned ceremony described above violates the Establishment Clause of the United States Constitution.

14. Plaintiffs have no adequate remedy at law to prevent the City from holding the ceremony, and will suffer irreparable harm if the ceremony is not enjoined.

WHEREFORE, Plaintiffs urge that this Court:

1. Declare the rights and liabilities of the parties.

2. Specifically, declare that the planned ceremony, to be held near the seat of government, during which a state sponsored prayer will receive a mass reading, violates the Establishment Clause.

3. Enter a preliminary injunction and/or temporary restraining order enjoining any ceremony which employs a state sponsored prayer.

4. Enter such other and further relief this Court deems just under the circumstances.

Respectfully submitted,

Richard D. Grossman

RICHARD D. GROSSMAN

LAW OFFICES OF RICHARD D. GROSSMAN

135 South LaSalle Street, Suite 1540

Chicago, IL 60603

(312) 701-0141