Andrew Hays, Sarah E. Buck Complaint
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Transcript of Andrew Hays, Sarah E. Buck Complaint
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Mar% Stoller &'0 3y this a!tion, Christopher Stoller see%s, inter alia, de!laratory relief,
!o"pensatory da"ages, punitie da"ages, an in2un!tion and and attorney4s fees and
!osts0
PARTIES
0 Christopher Stoller, 65 is a disable adult and a resident of Coo% County, llinois0
'0 Mar% Stoller, &', is the oldest Son of Christopher Stoller, a resident of *ri+ona0
&0 Stealth Cues is a dba of Mar% Stoller, -ho does business in Coo% County, llinois and
-ho operates his business out of his rental ho"e0
50 #ef!on ndustries, C (LIMITED LIABILITY COMPANY ARIZONA) (#ef!on) a
shell7 !orporation, a one "an operation, -hi!h is the alter ego of Mar% Stoller and does
business regularly -ithin Coo% County0 #ef!on is a one "an operation,, privately held
corporation in which the principal shareholder, president, and CEO are the same person,
Mark Stoller. There is a unity of interest and ownership between the Defcon and its
euitable owner, Mark Stoller, that the separate personalities of the corporation, Defcon and
the sole owner do not in reality e!ist. Second, there is an ineuitable result if the acts of
Mark Stoller and"or Defcon are treated as those of himself and"or of the corporation alone.
#See F. Hoffman-La Roche v. Superior Court,$%& Cal. 'pp. (th )*+, )- #+&&/.Er0o the
1shell2 corporation of Defcon is a necessary party to this suit and all of the acts and torts that
Mark Stoller is char0ed with likewise attributed to his 1shell2 corporation, Defcon.
.a The law firm which represents Mark Stoller, 3ays 4irm 55C, a Chica0o law firm located
at 6. 6acker Drive, $(th4loor, Chica0o, 7llinois -&-&$. 'ttorneys *ndre- 8ays, indiidually,
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*ntonia 8ays ndiidually and Sarah 3u!%, indiidually0
5b0 9or purposes of this Co"plaint for n2un!tie and Other elief, any referen!e to
the a!ts of Mar% Stoller shall "ean that su!h a!ts are attributable to, by and through the a!ts of
#ef!on ndustries C$s offi!ers, "e"bers, o-ners, dire!tors, e"ployees, salespersons,
representaties and:or other agents0
VENUE
60 ;enue is proper pursuant to
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years due to sui!ide on @une , >>//, Christopher$s youngest son #aid,
A, died due to an oer dose of drugs on *ugust 6, >//0 Christopher$s lady friend -as %illed in
a train a!!ident on @uly &th>//0
/>0 eo Stoller 6?, brother of Christopher, filed a Petition for Buardianship of
Christopher Stoller$s estate and person in >>A in a%e County llinois >AP A5/> a guardian at itie" -as *ppointed for Christopher Stoller E=hi:it (0 Christopher Stoller
-as de!lared totally -ithout understanding or !apa!ity to "a%e and !o""uni!ate de!isions
regarding his person and totally unable to "anage his estate or finan!ial affairs on 9eb >, >//
-hen the a%e Counter Probable Court appointed a Plenary Buardian for Christopher Stoller
E=hi:it &% Christopher -as restored to !o"pensatory on O!t0 '> >/'0/
((% Christopher Stoller -as in!ar!erated fro" 4"#5"r2 &'tho$ &''- 5#ti A565st >',
&'(>0 On O1to:er >'th, &'(>Christopher Stoller -as Ordered restored to !o"peten!y0
E=hi:it &%(
/0 On or about No0 //< Mar% !alled his father Christopher Stoller and said he
!ould get his father a&'? return on Christopher$s retire"ent "oney fro" a
"utual fund he %ne- of0 Mar% as%ed his father to send hi" all of his retire"ent
funds so that he !ould inest the" for his dad0 Mar% told his dad that he !ould
hae his "oney ba!% any ti"e he as%ed for it an that Mar% -ould not spend it on
anything other than to inest it for his father0 Christopher sent Mar% *+,'''
E=hi:it &."!%
/'0 n #e!e"ber of >/' Christopher !alled Mar% Stoller and reDuested that his son
/ E=hi:it &%(
Christopher Stoller Case NoNo. 117330 is on Appeal before the Illinois Supreme Court.
&
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send hi" a !opy of the bro%erage a!!ount sho-ing the "utual fund a!!ount0
Mar% said if Christopher -ould hae to pay the the !apitol gains on the in!rease
in the alue of the "utual fund0 Mar% said that he had to "eet -ith his a!!ountant
to dis!uss it0 On or about #e!e"ber '/, >/' Christopher Stoller !alled his son
Mar% and reDuested his *+,'''%''to be i""ediately returned0 Mar% said that
Christopher
Stoller -astes his "oney, and that he !ould inest the @*+,''' in bro%erage
a!!ount and that by the ti"e he -ould be ready to retire he !ould hae
@+','''%'' Mar% said he -asn$t going to return Christopher$s retire"ent "oney
fro" his retire"ent a!!ount0 Mar% said he -as going to inest Christopher$s
retire"ent funds in #ef!on to buy pool !ues0 See a true and !orre!t !opy of Mar%
Stoller Stealth Cues -eb site "ar%ed as E=hi:it &"(% Mar% told his father
Christopher, Bo fu!% yourself7 Causing Christopher Stoller serer e"otional
stress0 On @anuary &
th
>/& Christopher sent his son a letter de"anding his "oney
ba!%0 E=hi:it &""% #efendant, Mar% Stoller ad"itted !o""ingling his father
funds -ith those of #ef!on0
/&0 Christopher Stoller$s 6>> in the a!!ounts of #ef!on and Stealth Cues0 Mar%
Stoller is a one "an operation -ho regularly !o="ingles his personal funds into
the a!!ounts of his shell7 !orporation #ef!on0
/50 Mar% !alled his father, Christopher Stoller on or about @anuary 5, >/& and said
that he -ould return his father$s retire"ent "oney of 6>>, and not to !all
hi" until @anuary /6, >/&07
5
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/60 Christopher !alled hi" on @anuary /5, >/&0 Mar% refused to ans-er his phone
after @anuary /6, >/&0
//&0 Mar% Stoller refused to respond0EHI/& Christopher Stoller "ade a poli!e report to the
Northla%e Poli!e #epart"ent in Northla%e, llinois to Offi!er Wo2ni+, eport No0
/&=>/&>'0 Offi!er Wo2ni+ !alled Mar% Stoller0 Mar% Stoller refused to tal% -ith
Offi!er Wo2ni+0 Mar% said he -as ta%ing the 5 th*"end"ent07
/A0 0 On @anuary /, >/& Christopher Stoller filed a !o"plaint -ith the llinois
Se!urities #epart"ent Mr. Frank LoscuitoE=hi:it >% Mr os!uito sent to
Mar% an //! letter0 Mar%$s la-yer Mr0 *ndre- 10 8ays sent a letter to Mr0
os!uito, falsely !lai"ing that the retire"ent "onies that Christopher Stoller sent
his son Mar%, -as a gift0
>0 On @anuary , >/& Christopher Stoller filed a "ail fraud !o"plaint -ith the
F0S0 Postal nspe!tion Seri!e E=hi:it )% Christopher Stoller also filed a
!o"plaint -ith the llinois *ttorney Beneral$s Offi!e E=hi:it )"%
/0 Mar% Stoller has refused to return the said retire"ent funds of @*+,'''%''
!ausing the plaintiff serer e"otional stress and finan!ial hardship0 Christopher
has sin!e been for!ed to "oe out of his retire"ent !o"pleG -hi!h proided
"eals, furniture and house %eeping, into an old peoples ho"e, lo- in!o"e
apart"ent, -here he has no furniture and no "eals proided0 Christopher does
not hae enough "oney to pay for his liingeGpenses, food and !urrent bills
6
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be!ause of the in2ury !aused by his son and the defendants0
0 On or about Mar% Stoller !onta!ted his attorneys*ndre- 8ays, *ntonia 8ays and
Sarah 3u!% (Mar%$s a-yers) and infor"ed hi" that he had ta%en 6>> fro" his
father under false pretense, !lai"ing that he -ould inest his father$s 6>> -hile had
no intention to do so0 Con!o!ted a false affir"atie defense infor"ing Mar% not to
-orry that he !ould !lai" that the "onies that his father gae hi" to inest -as really a
gift7 an not to -orry that they -ould hand this "atter, 2ust li%e they did the preious
"atter for hi" in a%e County -hen Mar% had preiously sued his father su!!essfully0
When in fa!t Mar%$s la-yers %ne- that the said 6>> -as not a gift be!ause the
Plaintiff had filed & !ri"inal !o"plaints against his son, Mar% for ta%ing the 6>>0>>0
t -as !lear that Mar% defrauded his father out of 6>> aided and abetting by the
8ays a- fir", his attorneys*ndre- 8ays, *ntonia 8ays and Sarah 3u!%0 See
Thornwood v. Jenner & Block, 344 N.E.2d ! "#ll.$%%.23'. #n Januar(
o) 24 Mark in)or*ed his )ather that the +a(s r* told hi* that the
+a(s Fir* would %revail on -( clai*in that /hristo%her ave his son
the *one( as a i)t0, so that he was not worried.
'0 Mar% Stoller -as in possession of &> pie!es of Capodi"onte 9igurines that
belonged to Christopher Stoller, -hi!h are alued oer >,>>>, along -ith ten
-ater !olor paintings by E"anuel -hi!h Mar% Stoller, has refused to return to his
father, Christopher -hi!h are alued at another />,>>>0
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COUNT ONE
AND AS FOR A FIRST CAUSE OF ACTION
.DECLARATORY 4UD7MENT +> ILCS B&+'(!
FRAUDULENT INDUCEMENT
(a)0 1he allegations in Paragraphs / through >(a) aboe are in!orporated by referen!e
in this Count One as if fully restated herein0
'0 On or about No0 //' Mar% falsely represented that if his father, Christopher
gae hi" his retire"ent funds of 6>> that Mar% -ould be able to greatly
in!rease the interest pay"ents for Christopher0 Mar% represented that in order to
"aGi"i+e the return on inest"ent of Christopher$s retire"ent funds that
Christopher turn all of those funds oer to Mar%0
&0 Mar% represented that he had the %no-ledge, s%ill and the ability to inest"ent
Christopher$s retire"ent funds in the highest returning inest"ent0
50 #uring the negotiations Mar% &', had an unfair bargaining po-er oer his
disabled father, Christopher 65, -ho is disabled, suffers fro" depression and 2ust
got out of 2ail after & H years0
60 #uring the negotiations in Noe"ber of >/', Mar% "ade fraudulent
indu!e"ents, pro"ises and other representations to his father that en!ouraged
hi" to send Mar% the retire"ent "onies by telling Christopher that Mar% !ould
get a >I return on Christopher$s "oney0
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Mar% if !ertain indu!e"ents, pro"ises and other representations had not been
"ade by Mar%0
?0 W8EE9OE Plaintiffs see% re!oery of a!tual and !o"pensatory da"agesJ
punitie da"agesJ attorney4s feesJ and eGpenses and !osts for in2uries !aused by
Mar%$s fraudulent indu!e"ent0 Plaintiff$s see%s su!h other and further relief as
this Court "ay dee" 2ust and proper or to -hi!h they "ay be entitled as a "atter
of la-0
&-% COUNT TWO AND AS FOR A SECOND CAUSE OF ACTION .FRAUD!
'>0 1he allegations in Paragraphs / through A aboe are in!orporated by referen!e
in this Count t-o as if fully restated herein0
'/0 On or about No //', defendants falsely and fraudulently represented to the
plaintiff that Mar% -ould ta%e Christopher$s retire"ent funds 6>>, and put
the" in a "utual fund that -ould gie a return of >I0
'0 1he representations "ade by defendant -ere in fa!t false0 1he true fa!ts -ere
Mar% too% his father$s retire"ent funds and did not intend to inest those funds
for his father but to %eep the "oney for hi"self and inest it in #ef!on to buy
pool !ues0
''0 When the defendant "ade these false representations Mar% %ne- the" to be
false, and these representations -ere "ade by the defendant, -ith the intent to
defraud and de!eie plaintiff and -ith the intent to indu!e plaintiff to send Mar%
his retire"ent funds0 *t the ti"e defendant "ade the pro"ises to plaintiff,
defendants had no intention of perfor"ing the"0
A
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'&0 Plaintiff, at the ti"e these representations -ere "ade by defendant and at
the ti"e plaintiff too% the a!tions herein alleged, -as ignorant of the falsity
of defendant$s representations and belieed the" to be true, and: or
Plaintiff, at the ti"e this pro"ise -as "ade and at the ti"e plaintiff too%
the a!tions herein alleged, -as ignorant of defendant$s se!ret intention not
to perfor" and plaintiff !ould not, in the eGer!ise of reasonable diligen!e,
hae dis!oered defendant$s se!ret intention0) n relian!e on these
representations, plaintiff -as indu!ed to and did send his son 6>>0 8ad
plaintiff %no-n the a!tual fa!ts, Plaintiff -ould not hae ta%en su!h a!tion,
if plaintiff had %no-n of the a!tual intention of defendant, plaintiff -ould
not hae ta%en su!h a!tion0 Plaintiff$s relian!e on defendant$s
representations -as 2ustified be!ause Mar% &' is the oldest son of
Christopher and Christopher 65, trusted his oldest son0
WHEREFORE *s a proGi"ate result of defendant$s fraud and de!eit and the fa!ts hereinalleged, plaintiff -as defrauded by reason of -hi!h plaintiff has been da"aged in the su" of6>>0>>0
0 n doing the a!ts herein alleged, defendant a!ted -ith oppression, fraud, and "ali!e, andplaintiff is entitled to punitie da"ages in the su" of />>,>>>0>>0
Plaintiffs pray for 2udg"ent against defendantKK and ea!h of the", as follo-s.
/0 9or !o"pensatory da"ages in the su" of />>,>>>0>>J0 9or punitie da"ages in the su" of />>,>>0>>J
/>
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'0 9or !osts of suit in!urred hereinJ and reasonable attorney$s fees0&0 9or su!h other and further relief as the !ourt "ay dee" proper0
COUNT THREE
AND AS FOR A THIRD CAUSE OF ACTION
.CONVERSION 735 ILCS 5/13-205 !
'50 1he allegations in Paragraphs / through '5 aboe are
in!orporated by referen!e in this Count t-o as if fully
restated herein0
'60 Christopher Stoller had 6>> of retire"ent funds0
'0 WHEREFORE,plaintiffs pray for 2udg"ent against
defendants and ea!h of the", as follo-s.
&/0 9or !o"pensatory da"ages in the su" of />>,>>>0>>0
a0 9or punitie da"ages in the su" of />>,>>0>>J
b0 9or !osts of suit in!urred hereinJ and reasonable
attorney$s fees0
//
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!0 9or su!h other and further relief as the !ourt "ay
dee" proper0
COUNT FOUR
AND AS FOR A FOURTH CAUSE OF ACTION
., >/'0
&&0 Christopher deliered and:or transferred the eG!lusie possession
of the said property of the bailor to the bailee0
&50 Mar%, the bailee a!!eptan!e of eG!lusie possession by the bailee
on the agreed ter"s and !onditions that Mar% -ould hold it in his
!are not transfer to third parties and:or sell it0 Mar% had eG!lusie
possession and !ontrol of these ite"s fro" @anuary /A, >>? until
'Willia! ". #$S$, 2012 WL 3%3&7&&(#$S$District Court for the District of South Cro!i"#$%#) llinois la- reDuires that a plaintiff establish the follo-ing ele"ents to sho- a pri"a fa!ie !aseof bail"ent (/) an agree"ent by the bailor to transfer or delier and the bailee to a!!ept eG!lusiepossession of the property of the the goods for a spe!ified purposeJ () the a!tual deliery or transfer ofeG!lusie possession of the property of the bailor to the baileeJ and (a!!eptan!e of eG!lusie possessionby the bailee0 Williams v. U.S.supra (sin!e the da"age:theft see"s to hae allegedly o!!urred at theO48ara air port, it follo-s that llinois la- applies0
/
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the presen!e0
&60 Christopher Stoller "ade a de"and on or about Septe"ber /5,
>/& for Mar% Stoller to return the said ite"s and he has refused0
&>,>>>0
0 9or punitie da"ages in the su" of />>,>>0>>J
'0 9or !osts of suit in!urred hereinJ and reasonable
attorney$s fees0
&0 9or su!h other and further relief as the !ourt "ay dee"
proper0
CO#NT 5CA#SE O' ACTION 'OR INTENTIONAL IN'LICTION O' EMOTIONAL
STRESS
&'. The !!etio"s i" Prrhs % throuh &' *o+e re i"cororte *-
refere"ce i" this Cou"t i+e s if fu!!- restte herei".
5>0 1his !ause of a!tion for intentional infli!tion of e"otional distress
is pre"ised on the outrageous !ondu!t of the defendant, the son &', of the
& Knieriem v. Izzo, ll0 #
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Plaintiff, ta%ing the entire retire"ent funds, 6>> fro" his father
Christopher Stoller 65, leaing hi" penniless, su!h !ondu!t is so eGtre"e
and outrageous that is goes beyond all possible bounds of de!en!y in
Publi! 9inan!e Corporation 0 #ais, 66=ll0 # ?5, A>0 eaing the
father, penniless, unable to buy his "onthly "edi!ations and gro!eries for
the "onth0(/A
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WHEREFORE,plaintiffs pray for 2udg"ent against defendant and ea!h
of the", as follo-s.
/0 9or !o"pensatory da"ages in the su" of />>,>>>0>>J
0 9or punitie da"ages in the su" of />>,>>0>>J
'0 9or !osts of suit in!urred hereinJ and reasonable
attorney$s fees0
&0 9or su!h other and further relief as the !ourt "ay dee"
proper0
*nd a preli"inary in2un!tion against the !he!%ing a!!ounts
and any and all inest"ent a!!ounts of the defendants,
a!!ounts re!eiable, of disbursing any funds up to an
in!luding />>,>>>0>>, during the penden!y of this
litigation0
CO#NT %CA#SE O' ACTION 'OR WILL'#L AND WANTON MISCOND#CT
NELIENCE5
1&. The !!etio"s i" Prrhs % throuh 1/ *o+e re i"cororte *-
refere"ce i" this Cou"t Si9 fu!!- restte herei".
550 1he #efendant, Mar% Stoller &', the oldest son of the Plaintiff
5 n tort la-, negligen!e is a distin!t !ause of a!tion0 1he estate"ent (Se!ond) of torts definesnegligen!e as !ondu!t that falls belo- the standard established by la- for the prote!tion of otheragainst unreasonable ris% of har"07 Negligen!e generally !onsists of fie ele"ents, in!luding thefollo-ing. (/) a duty of !are o-ed by the defendant to the plaintiffJ (e) a brea!h of that dutyJ (')ana!tual !ausal !onne!tion bet-een the defendant$s !ondu!t and the resulting har"J(&)proGi"ate!ause, -hi!h relates to -hether the har" -as foreseeableJ and (5) da"ages resulting fro" thedefendant$s !ondu!t0
/5
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Christopher had a spe!ifi! duty to his father to safeguard his personal
property, the 6>>, the Capodi"onte 9igures, Paintings his !lothing0
560 1he #efendant brea!hed that that duty, -hen he failed to return
to Plaintiff his 6>> and the Capodi"onte 9igures, Paintings his
!lothing0
5>,>>>0>>J
0 9or punitie da"ages in the su" of />>,>>0>>J
'0 9or !osts of suit in!urred hereinJ and reasonable
attorney$s fees0
&0 9or su!h other and further relief as the !ourt "ay dee"
proper0
*nd a preli"inary in2un!tion against the !he!%ing a!!ounts
and any and all inest"ent a!!ounts of the defendants,
/6
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a!!ounts re!eiable, of disbursing any funds up to an
in!luding />>,>>>0>>, during the penden!y of this
litigation0
AS 'OR A SE*ENT+ CA#SE O' ACTION (#N,#STENRIC+MENT%)
1'. The !!etio"s i" Prrhs % throuh 12 *o+e re i"cororte *-
refere"ce i" this Cou"t Si9 fu!!- restte herei".
60. 1he #efendant, Mar% Stoller &', the oldest son of the Plaintiff
Christopher -as enri!hed by the unauthori+ed ta%ing of the Plaintiff$s
retire"ent funds of 6>>0
6/0 1he #efendant, the &' year old son of the the Plaintiff Christopher
Stoller, 65, too% his entire retire"ent funds of 6>> at the eGpense of
the Plaintiff, leaing hi" destitute0
60 t is against eDuity and good !ons!ien!e to per"it the other party
to retain the 6>> fro" the #efendant, that -hi!h is sought to
be re!oered0
6'0 Mar% Stoller, &', ta%ing of the entire retire"ent funds fro" his
father, Christopher Stoller was si*%l( un)air and not riht.
6What Do You Need To Prove To Win An Unjust Enrichment Claim?
1nust enrich*ent is an o-liation that the law creates even without an( contract or
aree*ent. #n order )or a %lainti to %revail on a clai* o) unust enrich*ent, that %art(
is reuired to %rove that "' the other %art( was enriched, "2' at that %art(5s e6%ense,
and "3' that it is aainst euit( and ood conscience to %er*it the other %art( to retain
what is souht to -e recovered.
/
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WHEREFORE,plaintiffs pray for 2udg"ent against defendant and ea!hof the", per !ount as follo-s, per !ourt.
/0 9or !o"pensatory da"ages in the su" of />>,>>>0>>J
0 9or punitie da"ages in the su" of />>,>>0>>J
'0 9or !osts of suit in!urred hereinJ and reasonable
attorney$s fees0
&0 9or su!h other and further relief as the !ourt "ay dee"
proper0
*nd a preli"inary in2un!tion against the !he!%ing a!!ounts
and any and all inest"ent a!!ounts of the defendants,
a!!ounts re!eiable, of disbursing any funds up to an
in!luding />>,>>>0>>, during the penden!y of this
litigation0
/?
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AS 'OR A EI+T CA#SE O' ACTION (Aii. a. ai.a. 4.!i6a)7
0&. The !!etio"s i" Prrhs % throuh 0/ *o+e re i"cororte *-
refere"ce i" this Cou"t Si9 fu!!- restte herei".
01. Mr5 Sto!!er &/, o8e ut- to his fther, the P!i"tiff, Christoher
Sto!!er "ot to efru hi4.
660 The ;-s L8 fir4, A"re8 ;-s, A"to"i ;-s " Srh Buc5
8ere 8re if the ut- tht Mr5 Sto!!er &/ o8e to his is*!e fther,
Christoher Sto!!er 01, "ot to efru hi4 out of his e"tire retire4e"t fu"s of
607,$$$ for !! of the reso"s re+ious!- stte herei".
07. ;-s L8 fir4, A"re8 ;-s, A"to"i ;-s " Srh Buc5 5"e8
or shou! h+e 5"o8" tht their c!ie"t Mr5 Sto!!er *reche tht ut- "
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" h+e co"sire 8ith hi42.
7$. The P!i"tiff Christoher Sto!!er hs suffere 4es.
WHEREFORE,plaintiffs pray for 2udg"ent against defendant,indiidually, per !ount as follo-s, per !ourt.
/0 9or !o"pensatory da"ages in the su" of />>,>>>0>>J
0 9or punitie da"ages in the su" of />>,>>0>>J
'0 9or !osts of suit in!urred hereinJ and reasonable
attorney$s fees0
&0 9or su!h other and further relief as the !ourt "ay dee"
proper0
*nd a preli"inary in2un!tion against the !he!%ing a!!ounts
and any and all inest"ent a!!ounts of the defendants,
a!!ounts re!eiable, of disbursing any funds up to an
in!luding />>,>>>0>>, during the penden!y of this
litigation0
Wayne Rhine,Suite
500
309 W. Washington
Chicago, Illinois
? C; CONSP*C *N# CONCE1 O9 *C1ONCon!ert of a!tion eGists -hen t-o or "ore persons perfor" -rongful a!tspursuant to a !o""on design or one person gies substantial assistan!e to another%no-ing that the others !ondu!t !onstitutes a brea!h of legal duty0 Ciil !onspira!yinoles t-o or "ore persons -ho !o"bine for the purpose of a!!o"plishing, by their!on!erted a!tion, either a la-ful purpose by unla-ful "eans or an unla-ful purpose byla-ful "eans0 S"ith 0 Eli illy Co0, /'< ll0 d (/AA>)J ;an!e 0 Chandler, '/ ll0*pp0 'd
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8/11/2019 Andrew Hays, Sarah E. Buck Complaint
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60606 /%#=12' 12/#
/