INTHEUNITEDSTATESDISTRICTCOURT

FORTHENORTHERNDISTRICTOFILLINOIS
EASTERNDIVISION

TAMARAWUERFFEL,

Plaintiff,

v.

CaseNo.14CV3990
COOKCOUNTYSHERIFFSOFFICE,
THOMASDART,inhisindividualand
officialcapacity,RONALDZYCHOWSKI,
ZELDAWHITTLER,DANAWRIGHT,
MARLONPARKS,andHELENBURKEin
theirindividualcapacities,andthe
COUNTYOFCOOK,aunitoflocal
Government,

Defendants.

PlaintiffDemandsTrialbyJury

COMPLAINT

Plaintiff TAMARA WUERFFEL, through her undersigned counsel, complaining

against Defendants, COOK COUNTY SHERIFFS OFFICE, THOMAS DART, in his
individual and official capacity, RONALD ZYCHOWSKI, ZELDA WHITTLER, DANA
WRIGHT, MARLON PARKS, and HELEN BURKE, in their individual capacity, and
theCOUNTYOFCOOK,
1/
aunitoflocalGovernment,statesasfollows:
1. Plaintiff TAMARA WUERFFEL (Wuerffel) brings this action to redress
actsofretaliationinviolationoftheFirstAmendmentpursuantto42U.S.C.1983and

1/
CookCountyisnamedonlyasanindispensablepartyforpurposesofindemnification.
SeeCarverv.SheriffofLaSalleCo.,324F.3d947(7thCir.2003).

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in violation of Plaintiffs rights to free political association (Count I); to redress acts of
genderdiscriminationpursuanttoTitleVIIoftheCivilRightsActof1964(CountII);to
redressactsofretaliationpursuanttoTitleVIIoftheCivilRightsActof1964(CountIII);
for violation of Plaintiffs equal protection rights guaranteed under the United States
Constitution pursuant to 42 U.S.C. 1983 (Count IV); and for intentional infliction of
emotionaldistressunderIllinoislaw(CountV).
JurisdictionandVenue
2. This Court has jurisdiction pursuant to 28 U.S.C. 1331, 42 U.S.C. 1983
and 28 U.S.C. 1343. This Court has supplemental jurisdiction over state law claims
pursuantto28U.S.C.1367.
3. Venue is proper in this judicial district under 28 U.S.C. 1391(b) and (c)
becausePlaintiffandallDefendantseitherresideinthisdistrictorhavetheirprincipal
placeofbusinessinthisdistrict,andalleventsgivingrisetoPlaintiffsclaimsoccurred
withinthisdistrict.
Parties
4. Plaintiff Wuerffel has been employed with the Cook County Sheriffs
Officesince1998andholdstherankofSergeant.
5. Defendant COOK COUNTY is a municipality incorporated under the
lawsoftheStateofIllinois.CookCountyadministersitselfthroughdepartments,oneof
whichistheCookCountySheriffsOffice(SheriffsOfficeorCCSO).
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6. Defendant COOK COUNTY SHERIFFS OFFICE is a department of
COOKCOUNTY.
7. At all relevant times, Defendant THOMAS DART (Sheriff Dart) served
in the elected position of Sheriff of Cook County, Illinois. Sheriff Dart is sued in her
officialandindividualcapacity.
8. Defendant Dart was a policy maker for the Sheriffs Office and has final
policymakingauthoritywithregardtoconductallegedherein.
9. Defendant RONALD ZYCHOWSKI, (Zychowski) is sued in his
individual capacity. Defendant Zychowski is a Commander for the Cook County
SheriffsPoliceDepartment(CCSPD).
10. Defendant Zychowski was delegated with final policy making authority
withregardtohisactsandconductallegedherein.
11. DefendantZychowskiactedundercoloroflaw.
12. Defendant ZELDA WHITTLER (Whittler) is sued in her individual
capacity.DefendantWhittleristheUndersheriffoftheCookCountySheriffsOffice.
13. Atalltimesrelevanthereto,DefendantWhittlerhasservedintheposition
ofUndersheriffsolelyatthediscretionandpleasureoftheSheriff.DefendantWhittleris
afinalpolicymakerand/orwasdelegatedwithfinalpolicymakingauthorityandwasa
decisionmakerfortheSheriffsOfficeandwithregardtotheconductallegedherein.
14. DefendantWhittleractedundercoloroflaw.
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15. DefendantDANAWRIGHT(Wright)issuedinherindividualcapacity.
Atalltimesrelevanthereto,DefendantWrightservedasFirstDeputyChiefofPolice.
16. DefendantWrightwasdelegatedwithfinalpolicymakingauthoritywith
regardtoheractsandconductallegedherein.
17. DefendantWrightactedundercoloroflaw.
18. DefendantMARLONPARKS(Parks)issuedinhisindividualcapacity.
DefendantParksisaChieffortheCookCountySheriffsPoliceDepartment(CCSPD).
19. Defendant Parks was delegated with final policy making authority with
regardtoheractsandconductallegedherein.
20. DefendantParksactedundercoloroflaw.
21. Defendant HELEN BURKE (Burke) is sued in her individual capacity.
At all times relevant hereto, Defendant Burke served as Chief, Bureau of
Administration.
22. Defendant Burke was delegated with final policy making authority with
regardtoheractsandconductallegedherein.
23. DefendantBurkeactedundercoloroflaw.
AdministrativeProceedings
24. On December 23, 2013, Plaintiff Sergeant Wuerffel filed a charge of
discrimination with the Equal Employment Opportunity Commission (EEOC),
allegingdiscriminationbaseduponhersexandallegingretaliation.
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25. OnoraboutMarch3,2014,Plaintiffreceivedanoticeofrighttosuefrom
theEEOConhercharge.
26. Plaintiffsgender discriminationclaimsare timelyfiledwithin 90 daysof
thereceiptofthenoticeofrighttosue.
FactsUponWhichClaimsAreBased
27. Plaintiff Wuerffel has had an exemplary record with the Sheriffs Office
forover15years.SergeantWuerffelisahighlydecoratedSergeantandreceivedletters
andcommendationsforheroutstandingperformanceasasupervisorwiththeSheriffs
Office.
28. PlaintiffWuerffelhasneverbeendisciplined.
29. Atallrelevanttimes,SergeantWuerffelsatisfactorilyfulfilledherassigned
duties.
30. Sergeant Wuerffel scored second in rank after the Lieutenants
promotionalprocessinoraboutDecember2012.
31. Thereareonly4femalesergeantsontheCookCountySheriffsPoliceout
of55sergeantsandtherearenofemaleLieutenants.
32. Four days after the promotional interview for lieutenant, Commander
Zychowski began harassing Sergeant Wuerffel about her overtime for court
appearances.
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33. On November 18, 2012, Commander Zychowski denied paying Sergeant
Wuerffel the full overtime request for the court appearance on the Coulter case.
However,hepaidtwomaleofficerswhoalsoattendedcourtfortheirfullovertime.
34. On December 26, 2012, Commander Dwyer made comments in roll call
thattheywerewatchingSergeantWuerffel.
35. In January 2013, Commander Zychowski began singling Sergeant
Wuerffelout,statingonlyhecouldapprovebenefittimeforhertouse,eventhoughhe
wasnotherimmediatesupervisor,andherefusedtoapproveovertimeforher,whereas
similarlysituatedmaleemployeeswereabletohavetheirovertimecardsapprovedby
theirimmediatesupervisor.
36. On January 12, 2013, Sergeant Wuerffel complained to Chief Parks
regardingZychowskiharassingher.
37. Commander Zychowski did not permit Sergeant Wuerffel to adjust her
schedule to reduce overtime, whereas other male employees were permitted to adjust
theirschedules.
38. OnJanuary19,2013,SergeantWuerffelcomplainedagaintoChiefParks.
39. InJune2013,SergeantWuerffelwasdeniedbeingaFieldTrainingOfficer
supervisorbyChiefParks.
40. On June 25, 2013, Sergeant Wuerffel learned that Chief Parks initiated a
complaintagainstWuerffelwiththeSheriffsOfficeofProfessionalReview(OPR)in
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January,falselyaccusingherofsubmittingimproperovertimerequests,eventhoughhe
hadadmittedtoherthatheknewshedidnothingwrong.
41. All of Sergeant Wuerffels overtime requests were signed off on and
approvedbyhersupervisors,includingChiefParksandCommanderZychowski.
42. In August 2013, Commander Zychowski denied permitting Sergeant
Wuerffel to work a roadside safety check and regular overtime, while two male
sergeantswithlesssenioritythanherwereallowedtoworkovertime.
43. Sergeant Wuerffel was again denied the opportunity to work a roadside
safetycheckonAugust28,2013.
44. In August 2013, Sergeant Wuerffel complained to OPR about being
harassed by Commander Zychowski. OPR did not take any steps to investigate her
complaints.
45. InSeptember2013,SergeantWuerffelwasdeniedtrainingfortheHostage
Negotiationsteamthatshehadbeenapartofsince2003.
46. On October 11, 2013, Sheriff Dart promoted four male employees to
lieutenant. Sergeant Wuerffel was passed over for promotion even though she scored
higherthanthreeofthemalespromoted.
47. DefendantspassedPlaintiffoverinfavorofalessqualifiedcandidatefor
thepromotiontolieutenant.
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48. Defendants passed Plaintiff over in favor of a candidate who was
politicallyconnected,hadclout,and/orcontributedtoDartspoliticalcampaign.
49. The promotions decisions for the Cook County Sheriffs Police for
positionsofLieutenantareultimatelymadebyDefendantDart.
50. Defendants Burke and Wright participated in and approved the
promotion of less qualified and politically connected employees over Sergeant
Wuerffel.
51. SergeantWuerffelisobjectivelymorequalifiedthanotherindividualsthat
DefendantspromotedtoLieutenant.
52. Defendants initiated the false OPR investigation against Sergeant
Wuerffel, in part, in order to promote male employees and employees with clout
insteadofher.
53. On November 20, 2013, Sergeant Wuerffel requested to meet with
DefendantWrighttodiscussthefalseOPRinvestigationanddiscrimination.Defendant
WrightrefusedtomeetwithSergeantWuerffel.
54. On or about December 3, 2013, Commander Zychowski again denied
SergeantWuerffelovertimebytakingheroffascheduledhireback.
55. On December 4, 2013, Sergeant Wuerffel contacted Sergeant Little from
her Union regarding Commander Zychowski removing her from the scheduled
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overtimeassignment.SergeantLittleinformedSergeantWuerffelthathewouldcontact
ChiefParksregardingtheongoingissuewithCommanderZychowski.
56. On December 5, 2013, Sergeant Wuerffel was told there would be a
meeting to address the issues of harassment with Zychowski on December 11, 2013 in
ChiefParksoffice.
57. Instead,onDecember5,2013,SergeantWuerffelwassuspendedwithpay.
58. On December 20, 2013, Sergeant Wuerffel was placed on leave without
pay by Defendants Whittler and Wright. Similarly situated males, have not been
suspendedwithoutpay.
59. Male officers worked more overtime in 2012 than Sergeant Wuerffel did,
buttheyhaveneverbeeninvestigated.
60. Sergeant Wuerffel was questioned four times during the OPR
investigation.SergeantWuerffelwastoldduringtheseinterrogationsthatshecouldnot
have a Union Representative and an attorney present during the interrogation. OPR
refused to let Sergeant Wuerffel make changes to her statement that had been
incorrectlysummarizedbyinvestigators.
61. Sergeant Wuerffel had valid rights under Weingarten, the Collective
Bargaining Agreement, and the Illinois Uniform Peace Officers Disciplinary Act to
havebothherUnionRepresentativeandherattorneypresentduringtheinterrogation.
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62. Sergeant WuerffelinformedtheSheriffsOfficecommandstaff,including
Undersheriff Whittler, of the discrimination and retaliation. To date, Sheriff Dart and
hiscommandstaff,includingbutnotlimitedtoDefendantsParks,Whittler,andWright,
have not responded to Sergeant Wuerffels complaints of the ongoing discrimination
andretaliation.
63. No investigation was made into Sergeant Wuerffels complaints of
discrimination.
64. Defendants did absolutely no investigation into the complaints made by
SergeantWuerffelthatshewasbeingretaliatedagainstbytheOPRinvestigation.
65. Defendants have subjected Sergeant Wuerffel to further retaliation by
bringing additional investigations against her in an effort to find something to
terminateherfor.
66. Defendants have manufactured charges against Sergeant Wuerffel and
others to retaliate against them for their political affiliation and/or complaints of
politicaldiscriminationandretaliation.
67. Defendants with the knowledge and/or consent of Defendant Dart have
also engaged in selective enforcement of charges against employees based on political
affiliationornonaffiliationandthosewhohavecomplainedofdiscrimination.
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68. Defendants have engaged in a pattern and practice of retaliation against
employeesbasedontheirpoliticalaffiliationandinresponsetotheircomplaintsabout
discrimination.
69. Defendants and Defendants command staff and supervisors had
knowledge of the complained of conduct and refused or failed to take action to
terminateorcorrectsuchconduct,althoughtheyhadthepowerandauthoritytodoso.
COUNTI
(1983PoliticalDiscrimination)
70. Plaintiff restates and realleges by reference paragraphs 1 through 69 as if
fullysetforthhereinagainstallDefendants.
71. At all times relevant hereto, Defendants acted as employees, supervisors,
andfinalpolicymakersfortheCookCountySheriffsOfficeanditsrespectiveagencies.
72. The First Amendment protects a wide spectrum of free speech and
association, including a public employees right to free association, to support or not
support a political candidate of their own choosing, and to speak out and oppose
politicaldiscrimination.
73. Defendants unlawfully retaliated against Plaintiff for the exercise of her
rights under the First Amendment, by including but not limited to the following:
Defendants intentionally subjected Plaintiff to unwarranted discipline, denying her
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right tocounsel during OPR interrogations,denying herpromotion toLieutenant,and
issuingchargesforherterminationonbaselessOPRinvestigations.
74. Defendants have acted under color of state law at all material times
hereto.
75. TheconductofDefendantsviolatedPlaintiffsrightstofreeassociationas
securedbytheFirstAmendmenttotheConstitution.
76. Defendants are aware that it is unlawful to retaliate or discriminate
against someone because of their political affiliation and/or perceived political
affiliation.
77. Defendants know that employees must be treated equally regardless of
theirpoliticalaffiliationand/orperceivedpoliticalaffiliation.
78. On September 4, 2012, a federal jury found that Defendant Cook County
SheriffsOfficeandDefendantDartinhisofficialcapacity,alongwithScottKurtovich,
who was the First Executive Assistant in the Sheriffs Office, violated the 21 plaintiffs
First Amendment rights under the United States Constitution in the case of Burruss, et
al.v.CookCountySheriffsOffice,etal.,CaseNo.08C6621(N.D.Ill.).Thejuryawarded
$1,560,000incompensatory(notincludingbackpayorfrontpay)andpunitivedamages
tothe21plaintiffemployeesoftheSheriffsOffice.Defendantsfiledaposttrialmotion
to vacate the verdict, which the District Court denied. The District Court upheld the
jurysverdict,andheldinrelevantpart:TheCountyisliableundersection1983,justas
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Kurtovich is individually, because the jury found that the County made an official
decision to disband SORT in retaliation against Plaintiffs. . . . The court therefore will
notsetasidethejurysliabilityfindingsagainstDefendants.
79. The jury in the Burruss case found that Defendants Director Scott
Kurtovich violated federal law and the First Amendment to the United States
ConstitutionbyretaliatingagainstPlaintiffs.
80. Despite this finding and the District Courts affirmation of the jurys
verdict, Defendants in this case have not disciplined or terminated Scott Kurtovichs
employmentfromtheSheriffsOffice.
81. Defendants have not disciplined or terminated Scott Kurtovichs
employment despite Defendant Darts own written policy that political retaliation
willnotbetoleratedintheSheriffsOfficeandwillbesubjecttotermination.
82. Instead,afterthejurysverdict,DefendantDartpromotedScottKurtovich
to be the Director over the Training Academy and in charge of training, including
training on the Sheriffs policy on political discrimination and retaliation in the
workplace.
83. Despite Shakman, Defendant Sheriffs Office is still not investigating or
turns a blind eye to complaints of political discrimination and retaliation. The
investigations are superficial and intended to exonerate command staff, supervisors,
and the Sheriffs Office of complaints of political discrimination and retaliation.
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Employees who violate the law and the Sheriffs written policy against political
discrimination are not disciplined, and the message is sent that such conduct is
condonedandtoleratedwithintheSheriffsOffice.
84. TheactionsoftheDefendantsinviolatingPlaintiffsandotheremployees
Constitutional rights under the First Amendment were intentional, willful, and
maliciousand/orinrecklessdisregardofPlaintiffsrightsassecuredby42U.S.C.1983
andtheCivilRightsActof1991.
85. Defendants conduct caused Plaintiff damages, including but not limited
to: loss of income, back pay, front pay, emotional pain and suffering, humiliation,
degradation, inconvenience, lost benefits, loss of job advancement, future pecuniary
losses,attorneysfeesandexpenses,andotherconsequentialdamages.
WHEREFORE,PlaintiffseeksthefollowingreliefastoCountIoftheComplaint:
A. All wages and benefits Plaintiff would have received but for the
retaliation, includingbutnotlimitedtobackpay,frontpay,future
pecuniarylosses,andprejudgmentinterest;
B. Compensatorydamagesinanamounttobedeterminedattrial;
C. ApermanentinjunctionenjoiningtheDefendantsfromengagingin
theretaliatorypracticescomplainedofherein;
D. A permanent injunction requiring that the Defendants adopt
employment practices and policies in accord and conformity with
the requirements of the Civil Rights Act of 1871, 42 U.S.C. 1983,
and further requiring that Defendants adopt and initiate effective
remedial actions to ensure equal treatment and nonretaliation of
employees;
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E. A declaratory judgment that Defendants actions violate the First
AmendmenttotheUnitedStatesConstitution;
F. The Court retain jurisdiction of this case until such time as it is
assured that the Defendants have remedied the policies and
practices complained of herein and are determined to be in full
compliancewiththelaw;
G. Punitive damages as allowed by law as against the individual
Defendantsonly;
H. An award of reasonable attorneys fees, costs, and litigation
expenses;and
I. SuchotherreliefastheCourtmaydeemjustorequitable.

COUNTII
(TitleVIIGenderDiscrimination)

91. Plaintiff restates and realleges by reference paragraphs 1 through 69 above

asthoughfullysetforthherein.
92. TheactionsofDefendantCookCountySheriffsOfficeasperpetratedbyits
agents and as described and complainedof above,areunlawfulemploymentpractices
in that they likely have the effect of discriminating against, depriving and tending to
depriveequalemploymentto,andotherwiseadverselyaffectingPlaintiffbecauseofher
sex, in violation of Title VII of the Civil Rights Act of 1964 as amended, 42 U.S.C.
2000e,etseq.
93. Defendant Cook County Sheriffs Office has engaged in a policy, pattern,
andpracticeofdiscriminationagainstwomen.
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94. DefendantsintentionallydiscriminatedagainstPlaintiffbasedonhergender
by denying her equal opportunities, including but not limited to: being subject to a
hostile work environment, denying her employment opportunities, pay increases,
overtimeandspecialassignments.
95. Defendants treated similarly situated males better than Plaintiff because of
hersex.
96. The actions of Defendants in intentionally discriminating against Plaintiff
have caused Plaintiff great mental anguish, humiliation, degradation, physical and
emotionalpainandsuffering,inconvenience,lostwagesandbenefits,futurepecuniary
losses,andotherconsequentialdamages.
WHEREFORE,Plaintiffrespectfullyrequests:
A. All wages and benefits Plaintiff would have received but for the
discrimination,includingbutnotlimitedtobackpay,frontpay,future
pecuniarylosses,andprejudgmentinterest;
B. Compensatory damages in an amount to be determined at trial to
compensate Plaintiff for the depression, humiliation, anguish, and
emotionaldistress,causedbyDefendantsconduct;
C. ApermanentinjunctionenjoiningtheDefendantfromengaginginthe
discriminatorypracticescomplainedofherein;
D. ApermanentinjunctionrequiringtheDefendanttoadoptemployment
practicesandpoliciesinaccordandconformitywiththerequirements
ofTitleVII,42U.S.C.2000e,etseq.;
E. TheCourtretainjurisdictionofthiscaseuntilsuchtimeasitisassured
that Defendanthasremediedthepoliciesandpractices complained of
hereinandisdeterminedtobeinfullcompliancewiththelaw;
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F. An award of reasonable attorneys fees, costs, and litigation expenses;
and
G. SuchotherreliefastheCourtmaydeemjustorequitable.
COUNTIII
(TitleVIIRetaliation)

97. Plaintiff restates and realleges by reference paragraphs 1 through 69 above

asthoughfullysetforthherein.
98. TheactionsofDefendantCookCountySheriffsOfficeasperpetratedbyits
agents and as described andcomplainedofabove,areunlawfulemploymentpractices
in that they likely have the effect of retaliating against, depriving and tending to
depriveequalemploymentto,andotherwiseadverselyaffectingPlaintiffbecauseofher
complaintsofdiscrimination,in violationofTitleVII oftheCivilRightsActof1964as
amended,42U.S.C.2000e,etseq.
99. Defendant Cook County Sheriffs Office has engaged in a policy, pattern,
andpracticeofretaliatingagainstemployeeswhocomplainofdiscrimination.
100. Defendants intentionally retaliated against Plaintiff because of her
complaints by denying her equal opportunities, including but not limited to: being
subject to a hostile work environment, denying her employment opportunities, pay
increases,overtimeandspecialassignments.
101. Defendants treated similarly situated males better than Plaintiff because of
hercomplaintsofdiscrimination.
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102. The actions of Defendants in retaliating against Plaintiff have caused
Plaintiff great mental anguish, humiliation, degradation, physical and emotional pain
and suffering, inconvenience, lost wages and benefits, future pecuniary losses, and
otherconsequentialdamages.
WHEREFORE,Plaintiffrespectfullyrequests:
A. All wages and benefits Plaintiff would have received but for the
discrimination,includingbutnotlimitedtobackpay,frontpay,future
pecuniarylosses,andprejudgmentinterest;
B. Compensatory damages in an amount to be determined at trial to
compensate Plaintiff for the depression, humiliation, anguish, and
emotionaldistress,causedbyDefendantsconduct;
C. ApermanentinjunctionenjoiningtheDefendantfromengaginginthe
discriminatorypracticescomplainedofherein;
D. ApermanentinjunctionrequiringtheDefendanttoadoptemployment
practicesandpoliciesinaccordandconformitywiththerequirements
ofTitleVII,42U.S.C.2000e,etseq.;
E. TheCourtretainjurisdictionofthiscaseuntilsuchtimeasitisassured
that Defendanthasremediedthepoliciesand practices complained of
hereinandisdeterminedtobeinfullcompliancewiththelaw;
F. An award of reasonable attorneys fees, costs, and litigation expenses;
and
G. SuchotherreliefastheCourtmaydeemjustorequitable.
COUNTIV
(1983ViolationofEqualProtection)

103. Plaintiff restates and realleges by reference paragraphs 1 through 69 above

asthoughfullysetforthherein.
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104. Defendants intentionally subjected Plaintiff to unequal and discriminatory
treatmentthatalteredthetermsandconditionsofPlaintiffsemployment.
105. TheactionsofDefendantsagainstPlaintiffviolateherequalprotectionright
tobefreefromgenderdiscriminationundertheFourteenthAmendmentoftheUnited
StatesConstitutionand42U.S.C.1983.
106. DefendantCookCountySheriffsOfficefailedtoprovidepropertrainingto
its managers, supervisors, and employees to prevent gender discrimination.
Defendants failure to train was deliberately indifferent to the rights of employees
withinitspurview.
107. TheactionsofDefendantswereintentional,willful,andmaliciousand/orin
deliberateindifferenceforPlaintiffsrightsassecuredby42U.S.C.1983.
108. The actions of Defendants in intentionally engaging in and condoning
discrimination against Plaintiff based on her gender caused Plaintiff great mental
anguish, humiliation, degradation, physical and emotional pain and suffering,
inconvenience, lost wages and benefits, future pecuniary losses, and other
consequentialdamages.
WHEREFORE,Plaintiffrespectfullyrequests:
A. All wages and benefits Plaintiff would have received but for the
discrimination,includingprejudgmentinterest;

B. Compensatorydamagesinanamounttobedeterminedattrial;

C. DefendantsberequiredtopayprejudgmentinteresttoPlaintiffon
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thesedamages;

D. ApermanentinjunctionenjoiningtheDefendantsfromengagingin
thediscriminatorypracticescomplainedofherein;

E. A permanent injunction requiring the Defendants adopt

employment practices and policies in accord and conformity with
therequirementsoftheUnitedStatesConstitutionandpursuantto
42U.S.C.1983;

F. The Court retain jurisdiction of this case until such time as it is

assured that Defendants have remedied the policies and practices
complained of herein and are determined to be in full compliance
withthelaw;

G. Punitive damages as allowed by law against individual

Defendants;

H. An award of reasonable attorneys fees, costs, and litigation

expenses;and

I. SuchotherreliefastheCourtmaydeemjustorequitable.

COUNTV

(IntentionalInflictionofEmotionalDistress)

109. Plaintiff restates and realleges by reference paragraphs 1 through 69 above

asthoughfullysetforthherein.
110. The intentional acts of Defendants constitute extreme and outrageous
conduct, beyond the bounds of decency, which inflicted severe emotional distress and
mentalanguishonPlaintiff.
111. As a proximate result of Defendants unlawful acts, Plaintiff has suffered
severementalanxietyandemotionalandphysicaldistress.
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112. Defendantsactedwillfullyandmaliciouslywithrespecttotheirtreatmentof
Plaintiff.
WHEREFORE,Plaintiffrespectfullyrequests:
A. Compensatorydamages;

B. Economic losses Plaintiff sustained and will sustain as a result of

the intentional infliction of emotional distress, including
prejudgmentinterestonsuchamounts;

C. Punitivedamagesasallowedbylaw;

D. An award of reasonable attorneys fees, costs, and litigation

expenses;and

E. SuchotherreliefastheCourtmaydeemjustorequitable.

RespectfullySubmitted,

s/HeidiKarrSleper

PlaintiffsAttorney

ElectronicallyfiledonMay29,2014

DanaL.Kurtz,Esq.(6256245)
HeidiKarrSleper,Esq.(6287421)
KURTZLAWOFFICES,LTD.
32BlaineStreet
Hinsdale,IL60521
Phone:(630)3239444
Fax:(630)6049444
Email:dkurtz@kurtzlaw.us
Email:hsleper@kurtzlaw.us
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