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					                       IN THE UNITED STATE DISTRICT COURT
                                EASTERN DIVISION

GWENDOLYN HICKS, on behalf of                )
herself and as next friend of her minor      )
children, EARNEST HICKS, JR.;                )
LATASHA BENISON; and NATHAN                  )
BENISON, JR., individually and on            )
behalf of all similarly situated persons,    )
                      Plaintiffs,            )
                                             )      No. _______________
                Vs.                          )
                                             )      Judge _________________
HOWARD A. PETERS, III, Secretary             )
of the Illinois Department of Human          )
Services,                                    )
                      Defendant.             )


       Plaintiffs, by their attorneys, request that Defendant produce the following documents at

the offices of Plaintiffs’ counsel John Bouman, 205 W. Monroe, 2nd Floor, Chicago, Illinois

60606, within 14 days after service, or within such other time as the Court may order, pursuant to

Fed. R. Civ. P. 34. Please organize and label the documents to correspond with the categories in

each request.

                            DEFINITIONS AND INSTRUCTIONS

1. 305 ILCS 5/11-30 is referred to herein as “the multi-tiered durational residency

2. “Document” or “documents” means every original (and every copy of any original, or of any

    copy, which differs in any way from any original), every writing or recording of every kind

    of description, whether handwritten, typed, drawn, sketched, printed, or recorded by any

    physical, mechanical, electronic, or electrical means whatever, including but not limited to

    investigative reports, books, articles, monographs, curriculum vitae, records, papers,

    pamphlets, correspondence, communications, memoranda, notes, notebooks, worksheets,

    reports, lists, analyses, summaries, written memorials of oral communications, photographs,

    photographic slides, negatives, films, filmstrips, video tapes, audio tapes, computer tapes,

    computer discs, and recordings.

3. These discovery requests shall be deemed continuing, so as to require further and

    supplemental responses in the event Defendant becomes aware of any responsive information

    or knowledge between the time of initial answer and the time of hearing or trial.

                                   CLAIMS OF PRIVILEGE

        All objections and responses to these requests for documents which fail or refuse to

respond fully on the ground of any claim of privilege of any kind whatever shall state the nature

of the claim of privilege and state all facts relied upon in support of the claim of privilege or

relating thereto.

                               REQUESTS FOR DOCUMENTS

1. All documents that constitute or contain information relating to the number of cases in which

    the State of Illinois has applied the multi-tiered durational residency requirement, from
   enactment to the present, as to each of the following Illinois cash public aid programs under

   the Illinois Public Aid Code:

   (a) Article III (Aid to the Aged, Blind and Disabled or AABD program);

   (b) Article IV (Temporary Assistance for Needy Families or TANF program); and,

   (c) Article VI (General Assistance or GA program).

2. All documents that contain information relating to the reason(s) why Illinois enacted the

   multi-tiered durational residency requirement.

3. All documents that contain information relating to Illinois’ request(s) between 1985 and the

   present to the federal government for a waiver of governing federal laws or regulations which

   would allow Illinois to impose and/or enforce (a) the multi-tiered durational residency

   requirement, or (b) any other reduction or denial of benefits to newly arriving Illinois


4. All documents that contain information relating to Illinois’ inclusion of the multi-tiered

   durational residency requirement as part of its state Temporary Assistance for Needy

   Families (TANF) plan.

5. All documents that contain information relating to implementation and/or enforcement of the

   multi-tiered durational residency requirement, including but not limited to policy

   memoranda, information memoranda, manual releases, Department of Public Aid and
   Department of Human Services forms, Worker Action Guide, charts, correspondence, notes,

   training materials, and data stored electronically.

6. As to each of the cash aid programs (AABD, TANF, GA), all documents that contain

   information relating to an Illinois State interest, if any, served by the multi-tiered durational

   residency requirement, including all documents cited in response to Plaintiffs’ First Set of

   Interrogatories, Interrogatory No. 2.

One of Plaintiffs’ Attorneys

John M. Bouman
Wendy Pollack
Dory Rand
Carolyn Shapiro
Margaret Stapleton
Poverty Law Project
National Clearinghouse for Legal Services
205 W. Monroe St., 2nd Floor
Chicago, IL 60606
(312) 263-2820
FAX 263-3846

Henry Freedman
Executive Director
Welfare Law Center
175 Seventh Avenue, Suite 1205
New York, NY 10001-6708
(212) 633-6967
FAX 633-6371

Attorneys for Plaintiffs

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