Motion for Summary Judgment in FARAH GOHARI et al vs MCDONALD?S CORPORATION et al| Trellis.Law

On June 20, 2016 a Exhibit,Appendix was filed involving a dispute between Farah Gohari, Gohari Farah, and Mcdonald?S Corporation, Mcdonald?S Fran. O?Hare T, Mcdonald?S Fran. O'Hare T, for Class Actions in the District Court of Cook County.

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Hearing Date: No hearing scheduled
Location: <>
J udge: Calendar, 9
FILED
10/21/2022 5:30 PM
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ
CIRCUIT CLERK
COUNTY DEPARTMENT, CHANCERY DIVISION
COOK COUNTY, IL
2016CH08261
FARAH GOHARI as the Named Calendar, 9
Class Representative Plaintiff, and all 20001446
others similarly situated,

Plaintiff, Case No. 2016 CH 08261
Vv.
Hon. Cecilia A. Horan
McDONALD’S CORPORATION,
LOTT #1, INC., McDonald’s franchise at
O’Hare Airport, Terminal 1, Concourse C,
and LOTT #1, INC., McDonald’s franchise at
O’Hare Airport, Terminal 1, Concourse B,

Defendants.

EXHIBIT A

DEFENDANT McDONALD’S CORPORATION’S MEMORANDUM
OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT
EXHIBIT A
ELECTRONICALLY FILED
12/28/2016 6:08 PM
2016-CH-08261
CALENDAR: 15
PAGE 1 of 18
CIRCUIT COURT OF
IN THE CIRCUIT COURT OF COOK COUNTY, ILLI COUNTY, ILLINOIS
ANCERY DIVISION
COUNTY DEPARTMENT, CHANCERY DIVISIONL ERK DOROTHY BROWN

Farah Gohari as the Named )
Class Representative Plaintiff, )
and all others similarly situated )
Case No. 16 CH8261
Vv Hon. Judge Kathleen M. Pantle

McDonald’s Corporation;
Lott #1, Inc. - McDonald’s franchise at O’ Hare
Airport, Terminal 1, Concourse C;
Lott #1, Inc. - McDonald’s franchise at O’Hare
Airport, Terminal 1, Concourse B

First Amended - CLASS ACTION COMPLAINT

1 Plaintiff Farah Gohari brings this action against Defendants, arising from mispriced

menu items pursuant to Illinois Common Law Fraud (Count I — dismissed as to McDonald’s

Corporation), Illinois Consumer Fraud Act (Count II — upheld), and Civil RICO (Count IID), for

charging prices above the posted advertised price to consumers at McDonald’s locations at

O’Hare Airport in Chicago, and being aware and put on notice of the difference between the

posted menu prices and the actual prices charged, thus, the operators (Lott #1, Inc.) and

McDonalds’s Corporation executed a scheme to defraud consumers. Allegations are on

personal knowledge with respect to the Plaintiffs own purchase experience, and for other

allegations, based on knowledge and belief. Plaintiff Gohari’s allegations regarding her purchase

are representative of the class members’ consumer purchases — her’s is a consumer transaction,

at her purchase location, and representative of those at other O’Hare locations operated by the

same franchisee, and are alleged to underscore the Class and Civil RICO allegations, inter alia

the knowledge its actions were wrong, and intent to continue.

Plaintiff and Defendants

2. Plaintiff Farah Gohari is a citizen of the state of Kansas.

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3 Defendant McDonald's Corp. is headquartered at One McDonald's Plaza

Oak Brook, Illinois.

4 Defendant Lott #1, Inc. is registered as an Indian Corporation, with the Illinois

Secretary of State, its President is Derrick Lott and his address is listed as one in Illinois, and its

registered agent is in Illinois.

5 McDonald’s operates directly, or through franchisee operators under its control, in

O'Hare Airport, Terminal 1, Concourse C, Chicago, Illinois as well as in other Terminals inside

O’Hare Airport, in addition to the thousands of McDonald’s restaurants in Chicago, Illinois, the

United States, and worldwide.

6. Defendant Lott#1 operates at least both McDonald’s franchise at O’Hare Airport,

Terminal 1, Concourse C, and McDonald’s franchise at O’Hare Airport, Terminal 1, Concourse
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Jurisdiction exists for this court pursuant to 735 ILCS 5/2-209 because, inter alia

as alleged in this Class Action Complaint: Defendants transact business in this state; defendants

have committed a tortious act within this state; defendants own, use or possess real estate within

this state; defendants have made or performed a contract in this state; and defendants do business

in this State. Defendants headquarters are located in this State.

8 Section 18 U.S.C. 1964 authorizes state courts to have original jurisdiction to

enforce Civil RICO.

9 Venue is proper in the Circuit Court of Cook County. The underlying

transactions occurred in this county. The Defendants can be found in this county and transact

business in this county.

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Class Action Allegations

10. This action may be brought and properly maintained as a class action pursuant to

Illinois Code of Civil Procedure 735 ILCS §2-801. Plaintiff brings this action for herself and as

a representative member for all others similarly situated of the proposed class of all people who

purchased mismarked McDonalds’s menu items, advertised at O’Hare Airport. The class is

defined as:

All persons who purchased McDonald’s items at O’Hare Airport in
Chicago, Illinois, that were mismarked and advertised for less on the Menu
and were charged more than the advertised price at the register. (The known
dates of purchase include at least the period from sometime before May 28,
2016 and continuing through June 19, 2016; exact time frame to be
determined by discovery).

1 Numerosity. The proposed class is so numerous that the individual joinder of all

52 Soo members is impracticable. While the exact number and identities of the class members are
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of law or fact exist that arise from Defendants’ actions; such questions are common to all class

members and predominate over any questions affecting only individual members of the class.

The questions of law and fact common to the class include:

Did Defendants’ advertised price on its menu not reflect the price charged at the register?

How and Why did this difference occur?

Defendants’ awareness and actions/inactions regarding this difference?

How long did this false advertised price remain in effect?

What standards and practices were applied by defendants to ensure that prices charged at
the register were the same as those on the menu display?

13. Adequacy of Representation. Plaintiff will fairly and adequately protect and

pursue the interests of the members of the Class. Plaintiff understands the nature of the claims

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herein, has no disqualifying interests, and will vigorously represent the interests of the Class.

Plaintiff's counsel, Clinton A. Krislov and the law firm of Krislov & Associates, Ltd.,

additionally have vast complex litigation, tort, consumer class action and trial litigation

experience.

14. Appropriateness of a class action. Class litigation is an appropriate method for

the fair and efficient adjudication of the claims involved. Questions of law and/or fact are

common to the class, and predominate over any questions affecting only individual members,

such that a class action is superior to other available methods for fair and efficient adjudication

15; The rights of class members to be charged at the advertised price in a retail

consumer setting is a clear question of law that is common to the entire class. The relatively

small amount per customer deters the likelihood of individual actions. Under these
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16. Class certification is appropriate because the prosecution of separate actions by

individual members of the class would create a risk of inconsistent or varying standards of

operation to confirm menu and register agreement.

17: Class certification is also appropriate because defendants acted on grounds

generally applicable to the Class, making appropriate equitable, injunctive and or declaratory

relief.

18. Class certification is appropriate because common issues of law or fact

predominate over issues involving only individual class members.

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19% Defendants have incorrectly charged and, despite knowing of the discrepancy,

continued to charge amounts at the register different from prices shown in the location’s menu

display, that apply generally to the class.

20. The vast majority of the class members who were wrongly overcharged will be

identifiable by Defendants’ computer records corresponding to credit card charges, such that

Defendants’ records will identify the exact number of wrongly charged items, and, for credit and

debit card purchases, be able to actually correct the overcharges by crediting the purchasers’

accounts.

Factual Allegations of Defendants’ Conduct

21. Plaintiff Farah Gohari was traveling through O’Hare Airport on or about May 28, 2016

She and her husband had a layover in Chicago, at O’Hare Airport. Plaintiff's layover was less
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22. Plaintiff and her husband have health considerations that require them to eat

breakfast at a regular and customary time.

23. Plaintiff waited in line for about 15 to 20 minutes at McDonald’s at the Terminal

1 Concourse C restaurant, and placed an order.

24. When the McDonald’s register operator announced the total of the order, Plaintiff

determined that the amount seemed greater than it should be and inquired about the price of her

items.

25: The register operator informed the Plaintiff that the amounts on the electronic

Menu board were wrong.

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26. Plaintiff then chose new items, but again noticed that the amount seemed greater

than expected; again inquired, and was similarly informed by McDonald’s employee that the

prices shown on the electronic Menu board for the chosen items were wrong.

275 The employee became annoyed with Plaintiff
for delaying the speed of the line,

and chastised Plaintiff about not being willing to just pay the overcharge. McDonald’s employee

was rude to Plaintiff, who simply inquired about the price of the items, and was concerned that

the items were misadvertised and overpriced.

28. The McDonald’s employee informed Plaintiff that the advertised prices had been

wrong for some time, and that neither she nor a McDonald’s manager would alter or lower the

price of the order to adhere to the price advertised.

29. Plaintiff then selected other items to order instead, settling on items that she did
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leave McDonald’s, pick another restaurant, order food, eat and make her next flight.

30. Plaintiff had waited in line for about 20 minutes, and spent additional time

selecting and reselecting items.

31; Plaintiff complained to the McDonald’s employee at the register that it is not fair

to have misadvertised prices on the Menu.

S25 She requested a complete correction of the price. The McDonald’s employee was

rude, complained that the Plaintiff/customer was holding up the line, and the employee refused to

alter the price.

3338 Plaintiff made a final (third) selection of items, purchased them and upon being

given the reccipt, discovered these prices were also in excess of the price shown on the electronic

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Menu board — advertised price. Plaintiff
was charged $6.20 for a steak and egg McMuffin meal,

which was advertised on the electronic menu to be $4.80. Ex. | and Ex. 2, attached.

34, Plaintiff believes that the McDonald’s Menu and register are electronic, and on

information and belief, are likely computerized in such a way that pricing information could be

reprogramed in both in a minimal amount of time.

35. Similarly, McDonald’s IT department, as one of the largest restaurant businesses

in the world, could also, on information and belief, adjust and synchronize pricing issues on its

own computerized cash registers and menus in a minimal amount of time.

36. As well, McDonald’s, by its monitoring of the operation of its Company-owned

and franchised locations, assumes a responsibility to its customers and its own worldwide

reputation, to ensure that advertised prices are the same as those actually charged customers.
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38. Plaintiff made a complaint to McDonald’s prior to filing this lawsuit, and received

anon-descript response that they would investigate the matter, but, received no apology or

refund.

395 Prior to the time of initial filing, as late as June 19, 2016, counsel for Plaintiff

investigated the McDonald’s O’Hare prices as alleged above, and confirmed Plaintiff's claims,

and found similar overcharges compared with menu boards at the O’Hare Airport McDonald’s at

Terminal 1 Concourse C, and Terminal 1, Concourse B, store numbers 17278 and 17277

respectively. Indeed, on June 19, 2016, Plaintiff's Counsel’s investigator traveled to O’Hare; he

visited McDonald’s store number, 17278 in Terminal 1 Concourse C and made purchases and

took a photo of the menu board. The item, Steak & Egg McMuffin (meal) was offered on the

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menu at $4.80, but he was charged $6.10. He also visited McDonald’s store number 17277, in

Terminal 1 Concourse B and made purchases and took a photo of the menu board. The item,

Steak & Egg McMuffin (meal) was offered on the menu at $4.80, and he was charged $6.20.!

COUNT I: FRAUD?

40. The allegations of paragraphs | through 39 are incorporated as if fully set forth

herein.

41. Defendants' conduct, as alleged and described above, constitute a knowingly false

statement of material fact. Defendants knowingly continued to advertise false price information

on its menu and charge consumers more than the menu price. The duration of the mischarges

and allegations of knowledge of the wrong prices, underscore the knowledge and intent to

defraud.
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knowingly misstating the menu price, Defendants misled customers about the pricing, and

overcharged travelers at O’Hare Airport.

43. Defendants’ presentation of prices on their menu boards were made with the

intent to induce Plaintiffto rely on the presented prices in making purchase decisions.

''In light of the Court’s Order, Plaintiff re-alleges in order to preserve and not plead over the
allegations for appeal; also to support Class Certification, and support Count III to demonstrate
the Plaintiffs and Class’ allegations (that the pricing was wrong, known to be wrong, Defendant
knew it, and continued the practice) as to the newly named Defendant and the newly plead Count
III. The investigation and its results show Defendants’ knowledge of the wrong, yet continued
mispricing without correction, but are not submitted as a separate claim or claimant. A response
to this allegation is not called for by Defendants at this time.
? Plaintiff re-allege the dismissed Count I, to preserve and not plead over the Count for appeal.
McDonald’s need not respond to this Count I.

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44 Plaintiff reasonably believed the Defendants’ menu price was accurate and in

justifiable reliance bought the item.

45. As a direct and proximate result of omissions, fraud and deceit Plaintiff
and the

class have suffered damages, losses and injuries.

COUNT II: VIOLATION OF THE CONSUMER FRAUD ACT

46. Plaintiff repeats and realleges the facts and allegations contained in paragraphs |

through 39 above, as if fully set forth herein.

47. At all relevant times, there was in full force and effect in Illinois the Consumer

Fraud Act, 815 ILCS 505/1, et seg. (“The Act” or the “Consumer Fraud Act”).

48. Under the Illinois Consumer Fraud and Deceptive Business Practices Act, any

unfair or deceptive act or practice in the conduct of trade or commerce is actionable. (815 ILCS
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Unfair methods of competition and unfair or deceptive acts or
practices, including but not limited to the use or employment of any
deception, fraud, false pretense, false promise, misrepresentation or
the concealment, suppression or omission of any material fact, with
intent that others rely upon the concealment, suppression or
omission of such material fact, or the use or employment of any
practice described in Section 2 of the “Uniform Deceptive Trade
Practices Act”, approved August 5, 1965, in the conduct of any trade
or commerce are hereby declared unlawful whether any person has
in fact been mislead, deceived or damaged thereby. In construing
this section consideration shall be given to the interpretations of the
Federal Trade Commission and the federal courts relating to Section
5(a) of the Federal Trade Commission Act.

50. The Act expressly incorporates violations of the Uniform Deceptive Trade

Practices Act, 815 ILCS 510/I, et seq., (“Uniform Act”), and the Uniform Act provides at

Section 2, 815 ILCS 510/2, in pertinent part:

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§ 2. A person engages in a deceptive trade practice when, in the
course of his business, vocation or occupation, he: ...

qd) passes off goods or services as those of another...

(5) represents that goods or services have sponsorship, approval,
characteristics, ingredients, uses, benefits, or quantities that
they do not have or that a person has a sponsorship, approval,
status, affiliation, or connection that he or she does not
have...

(9) advertises goods or services with intent not to sell them as
advertised;

(12) engages in any other conduct which similarly creates a
likelihood of confusion or of misunderstanding.

In order to prevail in an action under this Act, a plaintiff need not
prove competition between the parties or actual confusion or
misunderstanding.

Pa 00 This Section does not affect unfair trade practices otherwise
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(a) Any person who suffers damage as a result of a violation of this Act committed by
any other person may bring an action against such person. The court, in its discretion may
award actual damages or any other relief which the court deems proper. Proofof public
injury, a pattern, or an effect on consumers generally shall not be required...

(c) Except as provided in subsection (f), (g), and (h) of this Section, in any action
brought by a person under this Section, the Court may grant injunctive relief provided in
this Section, reasonable attorney’s fees and costs to the prevailing party. (Emphasis added).

52. Plaintiffis a person under the Act and user of Defendants’ business services.

535, As set forth above, Defendants misrepresented the true price of the items for sale,

and when confronted with the wrong price, refused to correct the wrong price.

A deceptive act or practice.

54. Defendants’ conduct - to charge more than the price displayed on its menu board -

misled customers about the pricing and overcharged travelers at O’Hare Airport and violated the

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Consumer Fraud Act as a material deceptive act or practice. Defendants concealed the true

nature of the price, and fooled customers into paying more that the advertised price for menu

items.

Intent on the Defendants’ Part that the Plaintiff Rely on the Deception.

55: Defendants intended that customers rely on the prices shown on defendants’

menu boards in choosing to purchase items from McDonald’s.

56. Defendants are in the best position to correctly divulge their true intentions,

practices and such details to the Plaintiff
and the class. Defendants can quickly adjust the menu

pricing and register price.

Occurred in Trade and Commerce.

57. Defendants’ wrongful conduct, as alleged herein, occurred in trade and commerce
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58. The Defendants’ scheme is also unfair.

59: Defendants’ policy is unethical and is oppressive and unscrupulous because it was

done for its own profit at the expense of the Plaintiff
and consumer class, causing substantial

injury.

COUNT III: VIOLATION OF 18 U.S.C. § 1962(c)

60. The allegations of this First Amended Complaint, particularly that there was the

same operator of both O’Hare locations (Lott #1, Inc.), and the fact that McDonald’s Corporation

and the operators were on notice of the scheme and continued the scheme underscore this RICO

Count in particular: including a pattern of Racketeering Activity, a person, employed or

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associated with an enterprise, engaged in interstate commerce, through a pattern, of conducting

the predicate activity — the racketeering activity, and causing injury to the plaintiffs.

61. Plaintiff re-alleges and incorporates the foregoing paragraphs, 1-60.

62. A private civil action may be brought by a plaintiff under the provisions of the

Racketeer Influenced and Corrupt Organizations Act (RICO), alleging a violation of Title 18

U.S.C. § 1962(c), which states as follows:

It shall be unlawful for any person employed by or associated with any enterprise
engaged in, or the activities of which affect, interstate or foreign commerce, to
conduct or participate, directly or indirectly, in the conduct of such enterprise’s
affairs through a pattern of racketeering activity or collection of unlawful debt.

63. A violation of (RICO) 18 U.S.C. § 1962(c) requires:

() a culpable person;

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(5) of racketeering activity (“the predicate acts”); and

(6) causing injury to plaintiffs “business or property”

64 Culpable Person. RICO defines a “person” as an “entity capable of holding a

legal or beneficial interest in property.” Thus, McDonalds’s Corporation and Lott #1, Inc. are

each a “person” within the meaning of 18 U.S.C. §1961(3) because they are capable of holding a

beneficial interest in property.

65. Conducts or acquires an “enterprise.” RICO defines an enterprise as “any

individual, partnership, corporation, association or other legal entity, and any union or group of

individuals associated in fact although not a legal entity.” Defendants McDonalds’s Corporation

and Lott #1, Inc. are engaged in an Enterprise consisting of McDonald’s and its franchisees.

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The relationship between McDonald’s Corp. and Lott #1, Inc. is based upon a franchise

agreement between them, and the operation of a McDonald’s franchise details the Enterprise.

66. There is an ascertainable structure within the Enterprise with a pattern of

racketeering which constitutes the "Enterprise" within the meaning of 18 U.S.C. 1961(4).

Defendants conducted and participated directly or indirectly, in the conduct of the Enterprise's

affairs through a pattern of racketeering activity. Defendants intentionally used interstate wire to

charge credit cards and debit cards for the collection of charges in excess of those prices

advertised on McDonald’s digital signs and payment of accrued franchise royalties to

McDonald’s.

67. Plaintiff relied on Defendants sales misrepresentations. Plaintiff relied on

Defendants that the purchases were accurate. By advertising and maintaining inaccurate menu
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and continuing the fraudulent pricing, Defendants conducted an Enterprise to profit from the
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false advertising and false pricing. Plaintiffis entitled to correct pricing in order to making a

knowing purchase, free from Consumer Fraud. Plaintiff was unaware of material facts to make a

non-fraudulent purchase. Defendant concealed key and important fact such as the correct price,

and did not inform Plaintiff, or thousands of customers at O’Hare, for weeks or months even

after it was known to the Defendants that the advertising and pricing was wrong. Had Plaintiff

known, Plaintiff would have acted differently. Defendants’ execution of the scheme and

operation of the fraudulent pricing is the proximate cause of Plaintiffs’ loss.

68. By concealing, and knowingly continuing the practice of sales misrepresentations,

omitting material facts, making false statements and promises concerning its menu items and

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prices, Defendants conducted an Enterprise to profit from the sale of menu items at O’Hare

Airport.

69. Plaintiff is entitled to know the correct price of items prior to purchase.

70. Plaintiff was unaware of material facts to make a knowing purchase.

71 Defendant concealed key and important facts — such as the correct price of menu

items.

72 Had Plaintiff known, Plaintiff would have acted differently.

933 Defendants’ execution of the scheme is the proximate cause of Plaintiffs’ loss.

74 Affects Interstate or Foreign Commerce. The interstate commerce requirement

is satisfied if either the activity of the enterprise or the predicate acts of racketeering affects

interstate commerce. Defendants’ enterprise affects interstate commerce by:
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using the interstate wire system to charge and collect prices for goods higher than

advertised.

Defendants’ enterprise affects interstate commerce by providing food sales in Illinois, at O’Hare

International Airport to interstate travelers arriving, laying over, and departing.

75. Racketeering Activity. Each such use of the federal wires transfer system

(“wires”) in furtherance of the Defendant’s scheme constitutes wire fraud, in violation of 18

U.S.C. §1341, and in turn is a "racketeering activity" within the meaning of 18 U.S.C. §1961(1).

Defendants knowingly used a federal wire transfer system (“wires”) in furtherance of the

foregoing scheme. The elements of wire fraud have been identified as:

qd) a plan or scheme to defraud;

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(2) intent to defraud;

(G3) reasonable foreseeability that the mail or wires will be used; and

(4) actual use of the mail or wires to further the scheme.

(1) Defendants had a scheme to defraud consumers to overpay and continue to overpay for menu

items — as alleged inter alia by execution of material omissions and violation of the Illinois

Consumer Fraud by omission of facts to cause consumers to not know the correct price of menu

items and overpay and if questioned, and to continue to misrepresent the correct price of menu

items.

(2) Defendants intended to defraud consumer consumers by not fully informing the consumers of

the correct menu item prices, and despite knowing the menu items being mispriced, continuing to

charge the overprice items, rather than correcting and conforming the price or correcting its
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(3) It is reasonably foreseeable that the federal wire system would be used in implementing this
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scheme.

(4) Defendants used the federal wire system to further their scheme every time it processed a

credit or debit card purchase, called, mailed, or emailed between the entities and or used mobile

devices for payment or coupons; and/or conspired in the execution of its scheme with the other

Defendants. Thus, the interstate/federal wires were a critical part in Defendants’ scheme to

implement, account and continue the scheme.

76. Pattern of Racketeering. Section 1961(5) defines a “pattern of racketeering” as

“at least two acts of racketeering activity . . . the last of which occurred within ten years after the

commission of a prior act of racketeering activity.” The acts must be related and continuous to

form a “pattern of racketeering.” “Related” is defined as “acts that have the same or similar

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purposes, results, participants, victims, methods of commission, or otherwise interrelated by

distinguishing characteristics and are not isolated events.” In order to properly allege an open-

ended continuity scheme, there must be a “threat of continuity.” The two factors in establishing

“continuity” are (1) the duration of the alleged misconduct; and (2) a threat of continuing

criminal conduct. Defendants continuous overcharging, accounting for sales, franchise

agreement, and continuation of the scheme, constitutes more than two acts of racketeering

activity, and thus a “pattern of racketeering.” Defendants’ electronic sales/purchases, mail, calls

and correspondence is continuous and is not an isolated event. Defendants scheme affects both

the Plaintiff and, upon knowledge and belief, many others, the Class, which constitutes a

"pattern" within the meaning of 18 U.S.C. §1961(5).

TT. Injury to Plaintiff and the Class. For there to be an injury, four factors must be
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who suffered loss by reason of Defendant wire fraud.

Jury Demand

78. Plaintiff
and the Class demand a jury trial for all claims so entitled.

Prayer for Relief

WHEREFORE, Plaintiff
and the Class pray for the following relief, that this Court by

Order:

Certify the case as a Class Action as set forth herein;

Designate (1) Farah Gohari as the Class Representative, and (2) Clinton A.

Krislov and Krislov & Associates, Ltd. as Lead Counsel;

Declare that the conduct violates the laws as alleged in cach cause of action;

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Award Plaintiffs and the Class an injunctive relief including inter alia:

- certified correct pricing;

- an accounting of sales of mispriced items for all credit and debit card purchases;

- an accounting of sales of mispriced items for all cash sales;

Award Plaintiff and class members their actual and compensatory damages;

Award damages, fees and costs as allowed under the Civil RICO statute;

Award Cy Pres damages for damages not attributable to credit or debit card

purchases;

Award reasonable attorney’s fees;

I Award costs;

J Such other legal or equitable reliefas the Court deems just and proper.
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SBe Dated: December 28, 2016 By: s/Kenneth T. Goldstein
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Kenneth T. Goldstein
KRISLOV & ASSOCIATES, LTD.
20 N. Wacker Drive, Suite 1300
Chicago, IL 60606
(312) 606-0500
Firm Atty. No. 91198
clint@krislovlaw.com
ken@krislovlaw.com

Purchased from re:SearchIL Cc 122
CERTIFICATE OF SERVICE

I, Kenneth T. Goldstein, an attorney, state that on December 28, 2016, I caused a copy of
the foregoing First Amended Complaint, to be served upon the parties listed below on the Service
List via Email.

s/Kenneth T. Goldstein

Service List:

Samera Syeda Ludwig
Kevin Shea
Nixon Peabody LLP
70 West Madison St.
Suite 3500
Chicago, IL 60602
ssludwig@nixonpeabody.com
kpshea@nixonpeabody.com

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Purchased from re:SearchIL Cc 123
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Case Info

Judge

Horan, Cecilia A. Track Judge’s New Case

Case No.

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Document Filed Date

October 21, 2022

Case Filing Date

June 20, 2016

County

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Exhibit,Appendix: FARAH GOHARI et al vs MCDONALD?S CORPORATION et al

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