Civil Action Cover Sheet - Case Initiation
(05/27/16) CCL 0520
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
ty of Chicago
Jussie Smollett
CIVIL ACTION COVER SHEET - CASE INITIATION
‘A Gisil Action Cover Sheet - Case lnitiation shall be fled withthe
‘complaint inal civil actions. ‘The information contained herein
is for administrative purposes only and cannot be introduced into
ce. Dlease check the box in front of the appropriate case
type which best characterizes your action. Only one (1) case rype
rmay be checked with this cover sheet
Jury Demand @ Yes. Oo
)NAL INJURY/
CASE TYPES:
027 Motor Vehicle
1.040 Medical Malpractice
D047 Asbestos
048 Dram Shop
049 Product Liability
1051 Construction Injuries
(including Seructural Work Act, Road
Construction Injuries Aet and negligenes)
052 Railroad/PELA
1053 Pediatrie Lead Exposure
1061 Other Personal Injury/Wrongfal Death
01063 Intentional Tort
1.064 Miscellaneous Stautory Action
(Please Specify Below"*)
(2.065 Premises Liability
1078 Fen-phen/Redus Litigation
2.199 Silicone Implane
‘TAX & MISCELLANEOUS REMEDIES
CASE TYPES:
0.007 Confessions of Judgment
2.008 Replevin
D009 Tax
015 Condemnation
Qo17 Detinue
2.029 Unemployment Compensation
031 Foreign Transcript
0036 Administrative Review Action
085 Pestion co Register Foreign Judgment
2099 All Other Extraordinary Remedies
by; Edward N. Siskel
(Atcomey)
DEATH
(Pro Se)
‘Pro Se Only: C1 have read and agree co che terms of the
form the Clerk's Office for chis cae at this email addeess:
TILE STANT)
(COMMERCIAL LITIGATION
01070 Professional Malpractice
(other than legal or medical)
Fraud (other than legal or medical)
072 Consumer Fraud
D073 Breach of Warranty
074 Scatucory Action
(Pease specify below.)
1.075 Other Commercial Litigation
(Please specify below.*)
1076 Retaliatory Discharge
OTHER ACTIONS
(CASE -TYPES:
21062. Property Damage
1.066 Legal Malpractice
07 Libel/Slnder
1079 Pectin for Qualifed Orders
084 Pecicion to Issue Subpoena
1100 Pectin for Discovery
+ Municipal Code of Chicago, §1-21-010, et seq. & § 1-20-00, et seq
Primary Email: edward. siskel@cityofchicago.or
Secondary Email: laura.coffey@eityofchicago.org
“Tertiary Email
ers Office Elecoronie Notice Policy and choose o opt in to electronic notice
DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
Page LfIN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
CITY OF CHICAGO, a municipal corporation, )
)
Plaintiff, ) No.
ve )
)
JUSSIE SMOLLETT, an individual )
)
Defendant. )
COMPLAINT
Plaintiff the City of Chicago (“City”), by its Corporation Counsel, Edward N. Siskel,
brings this Complaint under the City’s False Statements Ordinance (“FSO”), § 1-21-010, et seg.
of the Municipal Code of Chicago (“MCC”), and the City’s Cost Recovery Ordinance (“CRO”),
MCC § 1-20-010, et seq. against Defendant Jussie Smollett (“Defendant”), seeking relief against
Defendant for false statements he made to the City, and seeking recovery of the costs of
necessary services provided by the City due to Defendant’s violations of the MCC, and in
support alleges as follows:
NATURE OF THE CASE
1. This action is brought by the City to recover civil penalties, statutory treble
damages, and attorney’s fees and costs arising from Defendant's false statements to the City. On
January 29, 2019, Defendant submitted a false police report claiming that he was the vietim of
racist and homophobic beating by unknown attackers, In reality, Defendant knew his attackers
and orchestrated the purported attack himself. Later, when police confronted him with evidence
about his attackers, he still refused to disclose his involvement in planning the attack. In
investigating Defendant's false statements and false police report, the City incurred significant
costs in order to provide services reasonably related to Defendant’s conduct.PARTIES
1. The City is a municipal corporation organized and existing under the laws of the
State of Ilinois.
2. Defendant is an actor on the televisi
filmed
mn show “Empire,” which is primarily
in Chicago. While working on “Empire,” and at all times relevant to this Complaint, Defendant
resided in the Streeterville neighborhood in Chicago, Illinois.
JURISDICTION AND VENUE
3. This Court has subject matter jurisdiction over this action pursuant to the Hlinois
Constitution art. VI, § 9.
4. This Court has jurisdiction over Defendant pursuant to 735 ILCS 5/2-209 because
Defendant violated the MCC by making false statements in Chicago, Ilinois, and the City
incurred significant costs in order to provide services reasonably related to Defendant's false
statements.
5. Venue in Cook County is proper because this cause of action arose in Cook
County, Illinois.
FACTUAL ALLEGATIONS
AL Defendant orchestrates and plans a fake attack.
6. In the fall of 2017, Defendant became friends with an individual named Abimbola
Osundairo (“Abel”), who is 25 years old and has worked with Defendant on Empire. During the
course of their friendship, Defendant and Abel socialized and exercised together, and Defendant
occasionally asked for Abel's assistance in obtaining recreational drugs.