IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, LAW DIVISION

DWIGHT GUNN, AS INDEPENDENT )

ADMINISTRATOR OF THE ESTATE OF )
VERONA ETRULIA GUNN; )
VICKI STEVERSON; AND MARIS OLIVER, )
)
Plaintiffs, )
) No. 19 L ______________
vs. )
)
CITY OF CHICAGO, A Municipal Corporation; )
and JOHN DOE CHICAGO POLICE OFFICERS )
1–2, ) JURY TRIAL DEMANDED
)
Defendants. )

COMPLAINT AT LAW

Plaintiffs, Dwight Gunn, as Independent Administrator of The Estate of Verona Etrulia Gunn,

Vicki Steverson, and Maris Oliver (“Plaintiffs”), by and through their attorneys, Action Injury Law

Group, LLC and Romanucci & Blandin LLC, complaining of Defendants, John Doe Chicago Police

Officers 1-2 (“Defendants”), state:

1. This action is brought against the City of Chicago and John Chicago Police Officers 1-2

for the harm caused by the willful and wanton operation of police cars at unconscionably high speeds

through the densely populated Austin neighborhood on the West Side of Chicago, which resulted in the

death of Verona Etrulia Gunn, the eighty-four year-old mother of Dwight Gunn, Derrick Gunn and

Vicki Steverson. The operation of police cars at excessive and recklessly high speed through

neighborhoods populated with families, pedestrians, bicyclists, and cars continues to be supported and

condoned by the City of Chicago, despite the fact that more people are killed or injured in the Chicago

area as a result of the reckless operation of police cars than anywhere in America other than Los

Angeles, California.1

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https://www.usatoday.com/story/news/2015/07/30/police-pursuits-fatal-injuries/30187827/
https://www.nbcchicago.com/news/local/Chicago-Sees-at-Least-3-Police-Chases-in-Less-Than-12-Hours-378280201.html
 PARTIES

2. Verona Etrulia Gunn was an eighty-four-year-old resident of the City of Chicago at the

time of her death.

3. The independent administrator of the Estate of Verona Etrulia Gunn is Dwight Gunn. He

received his appointment from the Probate Court of the Circuit Court of Cook County, Illinois on June

10, 2019.

4. Dwight Gunn, Derrick Gunn, and Vicki Steverson are the children and only heirs of

Verona Etrulia Gunn. On the day their mother died, they were residents of Cook County.

5. Plaintiff, Maris Oliver, is a resident of the City of Chicago.

6. Defendant City of Chicago is a municipal corporation incorporated under the laws of the

State of Illinois, and was, at all times material to the allegations made in this complaint, the employer of

Defendants John Doe Chicago Police Officers 1-2.

7. Defendants John Doe Chicago Police Officers 1-2 were at all times material to the

allegations made in this complaint sworn Chicago police officers acting within the scope of their

employment with the City of Chicago.

FACTS

8. On or about May 25, 2019, at approximately 10:00 pm, Plaintiffs Verona Etrulia Gunn,

Vicki Steverson, and Maris Oliver were seated in a Toyota sedan (“Toyota sedan”) that stopped at the

intersection located at Laramie and Division (the “Intersection”), in Chicago.

9. While Verona Etrulia Gunn, Vicki Steverson and Maris Oliver were seated in the

Toyota sedan at the Intersection, approximately 10-12 police vehicles raced through the intersection at

high speeds on the way to a potential crime scene to assist in the apprehension of a suspect.

10. The police vehicles of John Doe Chicago Police Officers 1-2, an unmarked police SUV

and marked police van, crashed into each other.

11. After the police vehicles of John Doe Chicago Police Officers 1-2 crashed into each

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other, one or both of the police vehicles crashed into the automobile in which Verona Etrulia Gunn,

Vicki Steverson and Maris Oliver were seated.

12. Eighty-four-year-old Verona Etrulia Gunn was severely injured when the two police

vehicles crashed into Toyota sedan. She was transported to Community First Medical Center in

Chicago for treatment of her injuries. From there, she was transferred to Illinois Masonic Hospital in

Chicago, where, approximately three and one half hours after the crash, she died.

13. Vicki Steverson was injured when the two police vehicles crashed into the Toyota sedan.

She was transported to Norwegian American Hospital where she was treated for her injuries and later

discharged.

14. Maris Oliver was injured when the two police vehicles crashed into the Toyota sedan

and was treated for her injuries at a hospital.

15. At the time and place described in preceding paragraphs, the City of Chicago, by and

through one of more of its police officers, including but not limited to John Doe Chicago Police

Officers 1-2, had a duty to operate their vehicles in the exercise of their duties as the employer of

police officers and as Chicago police officers.

COUNT I
Willful and Wanton Conduct - Wrongful Death - 740 ILCS 180/1, et seq.
Against All Defendants

16. Plaintiffs incorporate the preceding paragraphs into this Count of the complaint.

17. At the time and place described in preceding paragraphs, the City of Chicago, by and

through one of more of its police officers, including but not limited to John Doe Chicago Police

Officers 1-2, acted with utter disregard for the safety of others in one or more of the following ways:

a. Proceeded at speeds that created unwarranted danger to others, including Verona

Etrulia Gunn,Vicki Steverson, and Maris Oliver;

b. Initiated and continued a high-speed vehicle route to a potential crime scene to

assist in the apprehension of a suspect when the level of inherent danger created by
the speed at which they were travelling outweighed the necessity to arrive as soon as
possible at the crime scene;

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 c. Initiated and continued a high-speed vehicle route to a potential crime scene to
assist in the apprehension of a suspect when the volume of pedestrian and vehicular
traffic did not reasonably warrant the high-speed automobile drive to the crime
scene;

d. Continued a high-speed vehicle route to a potential crime to assist in the

apprehension of a suspect when it was clear that the high-speed drive created a risk
of harm to others on the roadway, including Verona Etrulia Gunn, Vicki Steverson
and Maris Oliver;

e. Operated a motor vehicle with willful or wanton disregard for the safety of others,
in violation of 625 ILCS 5/11-503.

18. As a proximate result of one or more of the aforementioned acts, Verona Etrulia Gunn

sustained injuries that resulted in her death.

19. Decedent Verona Etrulia Gunn is survived by her heirs, who are her three children,

Dwight Gunn, Derrick Gunn, and Vicki Steverson.

20. The death of Verona Gunn has caused Dwight Gunn, Derrick Gunn, and Vicki

Steverson to suffer pecuniary damages, including the loss of support, comfort, love, affection,

protection and society of their mother, decedent Verona Etrulia Gunn.

WHEREFORE, Plaintiff, Dwight Gunn, as Independent Administrator of The Estate of Verona

Etrulia Gunn, demands judgment against the City of Chicago and John Doe Chicago Police Officers 1-

2 for an amount in excess of fifty-thousand dollars ($50,000.00) in damages, costs, disbursements,

interest, and for any further relief that this Court deems fair and just.

COUNT II
Willful and Wanton Conduct - Survival - 755 ILCS 5/27-6
Against All Defendants

21. Plaintiffs incorporate the preceding paragraphs into this Count of the complaint.

22. At the time and place described in preceding paragraphs, the City of Chicago, by and

through one of more of its police officers, including but not limited to John Doe Chicago Police Officers

1-2, acted with utter disregard for the safety of others in one or more of the following ways:

a. Proceeded at speeds that created unwarranted danger to others, including Verona

Etrulia Gunn,Vicki Steverson and Maris Oliver;

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 b. Initiated and continued a high-speed vehicle route to a potential crime scene to assist
in the apprehension of a suspect when the level of inherent danger created by the
speed at which they were travelling outweighed the necessity to arrive as soon as
possible at the crime scene;

c. Initiated and continued a high-speed vehicle route to a potential crime scene to assist
in the apprehension of a suspect when the volume of pedestrian and vehicular traffic
did not reasonably warrant the high-speed automobile drive to the crime scene;

d. Continued a high-speed vehicle route to a potential crime scene to assist in the

apprehension of a suspect when it was clear that the high-speed drive created a risk
of harm to others on the roadway, including Verona Etrulia Gunn,Vicki Steverson
and Maris Oliver;

e. Operated a motor vehicle with willful or wanton disregard for the safety of others, in
violation of 625 ILCS 5/11-503.

23. As a direct and proximate result of the willful and wanton acts and omissions of the City

of Chicago and John Doe Chicago Police Officers 1-2, decedent Verona Etrulia Gunn suffered damages,

including physical and emotional injuries, past medical expenses, and conscious pain and suffering

while still alive at the automobile crash scene until she died approximately three and a half hours later at

Illinois Masonic Hospital.

24. Verona Etrulia Gunn died on May 26, 2019, as a direct and proximate result of the

willful and wanton acts and/or omissions of the City of Chicago and John Doe Chicago Police Officers

1-2 described in this complaint.

25. Verona Etrulia Gunn lost her chance of survival as a direct and proximate result of one

or more of the acts and/or omissions described in this complaint.

26. Verona Etrulia Gunn suffered injuries of a personal and pecuniary nature, including

without limitation, disability, disfigurement, pain and suffering, emotional trauma, and loss of chance of

survival as a direct and proximate result of the willful and wanton acts of the City of Chicago and John

Doe Chicago Police Officers 1-2 described in this complaint. Had she survived, Verona Etrulia Gunn

would have been entitled to compensation for the injuries caused to her by John Doe Chicago Police

Officers 1-2.

WHEREFORE, Plaintiff, Dwight Gunn, as Independent Administrator of The Estate of Verona

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Etrulia Gunn, demands judgment against the City of Chicago and John Doe Chicago Police Officers 1-

2 for an amount in excess of fifty-thousand dollars ($50,000.00) in damages, costs, disbursements,

interest, and for any further relief that this Court deems fair and just.

COUNT III
Willful and Wanton Conduct
Vicki Steverson Against All Defendants

27. Plaintiff Vicki Steverson incorporates the preceding paragraphs into this Count of the

complaint.

28. At the time and place described in preceding paragraphs, the City of Chicago, by and

through one of more of its police officers, including but not limited to John Doe Chicago Police Officers

1-2, acted with utter disregard for the safety of others in one or more of the following ways:

a. Proceeded at speeds that created unwarranted danger to others, including Verona

Etrulia Gunn,Vicki Steverson and Maris Oliver;

b. Initiated and continued a high-speed vehicle route to a potential crime scene to assist
in the apprehension of a suspect when the level of inherent danger created by the
speed at which they were travelling outweighed the necessity to arrive as soon as
possible at the crime scene;

c. Initiated and continued a high-speed vehicle route to a potential crime scene to assist
in the apprehension of a suspect when the volume of pedestrian and vehicular traffic
did not reasonably warrant the high-speed automobile drive to the crime scene;

d. Continued a high-speed vehicle route to a potential crime scene to assist in the

apprehension of a suspect when it was clear that the high-speed drive created a risk
of harm to others on the roadway, including Verona Etrulia Gunn, Vicki Steverson
and Maris Oliver;

e. Operated a motor vehicle with willful or wanton disregard for the safety of others, in
violation of 625 ILCS 5/11-503.

29. Vicki Steverson suffered serious and severe physical injuries and emotional distress, and

was otherwise affected in her ability to perform the routine activities of daily living..

WHEREFORE, Plaintiff, Vicki Steverson demands judgment against the City of Chicago and

John Doe Chicago Police Officers 1-2 for an amount in excess of fifty-thousand dollars ($50,000.00)

in damages, costs, disbursements, interest, and for any further relief that this Court deems fair and just.

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 COUNT IV
Willful and Wanton Conduct
Maris Oliver Against All Defendants

30. Plaintiff Maris Oliver incorporates the preceding paragraphs, except those relating to the

the Estate of Verona Etrulia Gunn, into this Count of the complaint.

31. At the time and place described in preceding paragraphs, the City of Chicago, by and

through one of more of its police officers, including but not limited to John Doe Chicago Police Officers

1-2, acted with utter disregard for the safety of others in one or more of the following ways:

a. Proceeded at speeds that created unwarranted danger to others, including Verona

Etrulia Gunn,Vicki Steverson and Maris Oliver;

b. Initiated and continued a high-speed vehicle route to a potential crime scene to assist
in the apprehension of a suspect when the level of inherent danger created by the
speed at which they were travelling outweighed the necessity to arrive as soon as
possible at the crime scene;

c. Initiated and continued a high-speed vehicle route to a potential crime scene to assist
in the apprehension of a suspect when the volume of pedestrian and vehicular traffic
did not reasonably warrant the high-speed automobile drive to the crime scene;

d. Continued a high-speed vehicle route to a potential crime scene to assist in the

apprehension of a suspect when it was clear that the high-speed drive created a risk
of harm to others on the roadway, including Verona Etrulia Gunn, Vicki Steverson
and Maris Oliver;

e. Operated a motor vehicle with willful or wanton disregard for the safety of others, in
violation of 625 ILCS 5/11-503.

32. Maris Oliver suffered serious and severe physical injuries and emotional distress, and

was otherwise affected in her ability to perform the routine activities of daily living..

WHEREFORE, Plaintiff, Maris Oliver demands judgment against the City of Chicago and John

Doe Chicago Police Officers 1-2 for an amount in excess of fifty-thousand dollars ($50,000.00) in

damages, costs, disbursements, interest, and for any further relief that this Court deems fair and just.

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 COUNT V
(Respondeat Superior Claim)

33. The acts of the individual police officers, including John Doe Chicago Police Officers 1-

2, described above were committed in the scope of their employment.

34. As principal, Defendant City of Chicago is liable for its agents’ actions under the

doctrine of respondeat superior.

WHEREFORE, Plaintiff demands judgment against the City of Chicago, and such other and

additional relief that this Honorable Court deems just and equitable.

COUNT VI
(Indemnification Claim pursuant to 745 ILCS 10/9-102)

35. The acts of the individual police officers, including John Doe Chicago Police Officers 1-

2, described in the above claims were committed in the scope of their employment.

36. Pursuant to the Illinois Tort Immunity Act, 745 ILCS 10/9-102, Defendant City of

Chicago is liable for any judgments in this case arising from the actions of the individual Chicago

police officers.

WHEREFORE, Plaintiff asks that this Honorable Court order Defendant City of Chicago to

indemnify the individual Chicago police officers for any judgment entered in this case arising from the

actions of the officers.

Dated: June 10, 2019 Action Injury Law Group, LLC

/s/ Andrew Stroth

Andrew M. Stroth
Carlton Odim
Amanda Yarusso
Action Injury Law Group, LLC
191 North Wacker Drive, Suite 2300
Chicago, IL 60606
Tel: (312) 771-2444
Fax: (312) 641-6866
Firm I.D. No. 59302
astroth@actioninjurylawgroup.com
carlton@actioninjurylawgroup.com
amanda@actioninjurylawgroup.com

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 Antonio M. Romanucci
ROMANUCCI & BLANDIN, LLC
321 N. Clark Street, Suite 900
Chicago, IL 60654
Tel: (312) 458-1000
Fax: (312) 458-1004
Firm I.D. No. 35875
aromanucci@rblaw.net

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 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION

DWIGHT GUNN, AS INDEPENDENT )

ADMINISTRATOR OF THE ESTATE OF )
VERONA ETRULIA GUNN; )
VICKI STEVERSON; AND MARIS OLIVER, )
)
Plaintiffs, )
) No. 19 L ______________
vs. )
)
CITY OF CHICAGO, A Municipal Corporation; )
and JOHN DOE CHICAGO POLICE OFFICERS )
1–2, ) JURY TRIAL DEMANDED
)
Defendants. )

AFFIDAVIT

I, Andrew Stroth, state under oath:

1. I am an attorney associated with Action Injury Law Group, LLC and am

responsible for filing of the Complaint at Law in this matter.

2. The total of money damages sought by plaintiffs does exceed $50,000.00,

exclusive of interest and costs.

/s/ Andrew M. Stroth `

Andrew M. Stroth
 §1-109 VERIFICATION BY CERTIFICATION

Under penalties as provided by law pursuant to § 1-109 of the Code of Civil Procedure,
the undersigned certifies that the statements set forth in this instrument are true and correct,
except as to matters therein stated to be on information and belief and as to such matters the
undersigned certifies as aforesaid that he verily believes the same to be true.

Dated: June 10, 2019 Action Injury Law Group, LLC

/s/ Andrew M. Stroth

Andrew M. Stroth
Action Injury Law Group, LLC
191 North Wacker Drive, Suite 2300
Chicago, IL 60606
Tel: (312) 771-2444
Fax: (312) 641-6866
Firm I.D. No. 59302
astroth@actioninjurylawgroup.com
carlton@actioninjurylawgroup.com
amanda@actioninjurylawgroup.com

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