IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
SAMAR
KAUKAB,
)
)
Plaintiff, )
)
v.
) Case
No.
)
)
MAJOR GENERAL DAVID HARRIS, )
individually and in his official capacity as )
Adjutant General of the State of Illinois, ONE )
UNIDENTIFIED
MEMBER
) Judge
OF THE ILLINOIS NATIONAL )
GUARD, ARGENBRIGHT SECURITY, INC., )
ONE UNIDENTIFIED MALE EMPLOYEE OF )
ARGENBRIGHT SECURITY, INC. AND )
TWO UNIDENTIFIED FEMALE EMPLOYEES )
OF ARGENBRIGHT SECURITY, INC., )
)
Defendants. )
COMPLAINT
Plaintiff, Samar Kaukab ("Ms. Kaukab"), by and through her attorneys, makes this
Complaint against defendants as follows:
PRELIMINARY STATEMENT
1. This civil rights action arises out of the unlawful surveillance, stop, continued
detention, strip search of, and unwarranted, forced removal of religiously significant clothing
from, Ms. Kaukab at O'Hare International Airport ("O'Hare") on November 7, 2001. Ms.
Kaukab was subjected to this unlawful course of conduct because of her ethnicity, religion and
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT
ONE UNIDENTIFIED MALE EMPLOYEE OF)
Plaintiff, Samar Kaukab ("Ms.
Kaukab"), by and through her attorneys, makes this
Complaint against defendants as follows:
This civil rights action arises out of the unlawful surveillance, stop, continued
detention, strip search of, and unwarranted, forced removal of religiously significant
Kaukab at O'Hare International Airport on November 7,
the Fourteenth Amendment to the United States Constitution.
declaratory and injunctive relief as well as money damages.
Count II asserts Illinois state law claims and is brought pursuant to 28 U.S.C.
Plaintiff's claims for declaratory and injunctive relief are authorized by 28
training for those serving in the Illinois National Guard.
Argenbright is, on information and belief, the security company with which United Airlines
without sufficient legal justification and based on her ethnicity, religion and national
Three unidentified employees of Argenbright are defendants in this action
To the right of the metal detector was an xray machine for purposes of screening carry-on
release at the end of her detention,
The security employee also stuck the wand inside Ms.
Following a conversation with the National Guardsman, the unidentified male security employee
her ethnicity, religion and national origin constitute denial of equal protection of the
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