Preview
Law Division Motion Section Initial Case Management Dates for CALENDARS (A,B,C,D,E,F,H,R,X,Z) will be heard In Person.
All other Law Division Initial Case Management Dates will be heard via Zoom
For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12
Court Date: 7/17/2024 11:00 AM FILED
5/16/2024 4:23 PM
IN THE CIRCUIT COURT OF COOK COUNTY – ILLINOIS IRIS Y. MARTINEZ
CIRCUIT CLERK
COUNTY DEPARTMENT – LAW DIVISION
COOK COUNTY, IL
FILED DATE: 5/16/2024 4:23 PM 2024L005478
2024L005478
EDWARD SOCORRO, ) Calendar, B
Plaintiff, ) 27731304
) 2024L005478
v. ) No.: _________________
)
TOUCHE, and )
NIGHT BEFORE, INC. d/b/a )
TOUCHE, and CHARLES )
RODOCKER, and KEVIN )
LEE HEINDORF, )
Defendants. )
COMPLAINT
NOW COMES the Plaintiff, Edward Socorro by and through his attorneys, Seidman,
Margulis & Fairman and for his Complaint against the Defendants, Touche, and Night Before, Inc.
d/b/a/ Touche, and Charles Rodocker, and Kevin Lee Heindorf states as follows:
FACTS COMMON TO ALL COUNTS:
1. At all times relevant to this Complaint, the Plaintiff, Edward Socorro, was a resident of
Chicago, Cook County, Illinois
2. At all times relevant to this Complaint, the Defendant, Touche, was a business licensed and
operating under the laws of the State of Illinois with a common address of 6412 North Clark Street,
Chicago, Illinois;
3. At all times relevant to this Complaint, the Defendant, Night Before, Inc. d/b/a Touche,
was a business licensed and operating under the laws of the State of Illinois with a common address
of 6412 North Clark Street, Chicago, Illinois;
4. At all times relevant to this Complaint, the Defendant, Charles Rodocker, owned, operated,
maintained and controlled the business Touche and/or Night Before, Inc. d/b/a Touche, licensed
and operating under the laws of the State of Illinois with a common address of 6412 North Clark
Street, Chicago, Illinois;
FILED DATE: 5/16/2024 4:23 PM 2024L005478
5. At all times relevant to this Complaint, the Defendant, Kevin Lee Heindorf, owned,
operated, maintained and controlled the business Touche and/or Night Before, Inc. d/b/a Touche,
licensed and operating under the laws of the State of Illinois with a common address of 6412 North
Clark Street, Chicago, Illinois;
6. On or about May 19, 2022, the Plaintiff, Edward Socorro, was a invitee and paying
customer of the aforementioned business, Touche and/or Night Before, Inc. d/b/a Touche, and was
inside of the establishment when he was asked to leave the premises by the agents and staff of
Touche and/or Night Before, Inc. d/b/a Touche.
7. At the aforementioned place and time, Plaintiff, Edward Socorro, was inside of the
establishment when he was asked by the agents and staff of Touche and/or Night Before, Inc. d/b/a
Touche to leave the premises;
8. Plaintiff, after being asked to leave the premises, was on his way out of the front door to
the establishment when one of the agents and servants of Defendant, Touche and/or Night Before,
Inc. d/b/a Touche, physically attacked Plaintiff, striking him, shoving him and ultimately causing
Plaintiff to violently fall and strike his head on the pavement outside of the front door to Touche
and/or Night Before, Inc. d/b/a Touche;
COUNT I - TOUCHE
9. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein;
10. At the aforementioned time and place the Defendant, Touche, owed a duty to exercise
reasonable care in the operation and control of its premises, including the supervision, training,
and employment of its staff, agents and servants so that they would not cause serious injury to
lawful patrons and invitees such as Plaintiff;
FILED DATE: 5/16/2024 4:23 PM 2024L005478
11. In violation of said duty, Defendant, Touche, individually and by and through it agents and
servants was guilty of one or more of the following careless and negligent acts and omissions:
a. Carelessly and negligently failed to supervise its agents and servants, and
employees including but not limited to security and hospitality personnel so that
they would not push, trip or shove or take violent physical acts against Plaintiff as
he was leaving the premises thereby causing Plaintiff serious injury;
b. Carelessly and negligently failed to train its agents and servants, and employees
including but not limited to it’s security and hospitality personnel so that they would
not push, trip or shove or take violent physical acts against Plaintiff as he was
leaving the premises thereby causing Plaintiff serious injury;
c. Failed to insure that once Defendant requested a lawful and paying patron such as
Plaintiff to leave the premises, that an individual such as Plaintiff would be allow
to peacefully leave without being tripped, pushed or shoved or have violent action
taken against Plaintiff as he was leaving the premises thereby causing Plaintiff
serious injury;
d. Was otherwise careless and negligent.
12. As a direct and proximate cause of one or more of the aforementioned negligent acts and
omissions by Defendant, Touche, the Plaintiff was violently attacked by agents and servants of
Touche causing him to strike his head on the pavement outside of the front door of Touche;
13. As further direct and proximate result of the aforementioned careless and negligent acts
and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred
medical expenses in relation to the same, lost time from work, and sustained a loss of a normal
life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose
time from work, and sustain a loss of a normal life in the future.
WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in
his favor and against the Defendant, Touche, for an amount in excess of $50,000.00 and costs of
FILED DATE: 5/16/2024 4:23 PM 2024L005478
this suit and for any other relief this Court deems equitable and just.
COUNT II – NIGHT BEFORE, INC.
14. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein;
15. At the aforementioned time and place the Defendant, Night Before, Inc. d/b/a/Touche,
owed a duty to exercise reasonable care in the operation and control of its premises, including the
supervision, training, and employment of its staff, agents and servants so that they would not cause
serious injury to lawful patrons and invitees such as Plaintiff;
16. In violation of said duty, Defendant, Night Before, Inc. d/b/a/Touche, individually and by
and through it agents and servants was guilty of one or more of the following careless and negligent
acts and omissions:
a. Carelessly and negligently failed to supervise its agents and servants, and
employees including but not limited to security and hospitality personnel so that
they would not push, trip or shove or take violent physical acts against Plaintiff as
he was leaving the premises thereby causing Plaintiff serious injury;
b. Carelessly and negligently failed to train its agents and servants, and employees
including but not limited to it’s security and hospitality personnel so that they would
not push, trip or shove or take violent physical acts against Plaintiff as he was
leaving the premises thereby causing Plaintiff serious injury;
c. Failed to insure that once Defendant requested a lawful and paying patron such as
Plaintiff to leave the premises, that an individual such as Plaintiff would be allow
to peacefully leave without being tripped, pushed or shoved or have violent action
taken against Plaintiff as he was leaving the premises thereby causing Plaintiff
serious injury;
d. Was otherwise careless and negligent.
17. As a direct and proximate cause of one or more of the aforementioned negligent acts and
omissions by Defendant, Night Before, Inc. d/b/a/Touche, the Plaintiff was violently attacked by
agents and servants of Touche causing him to strike his head on the pavement outside of the front
door of Touche;
FILED DATE: 5/16/2024 4:23 PM 2024L005478
18. As further direct and proximate result of the aforementioned careless and negligent acts
and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred
medical expenses in relation to the same, lost time from work, and sustained a loss of a normal
life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose
time from work, and sustain a loss of a normal life in the future.
WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in
his favor and against the Defendant, Night Before, Inc. d/b/a/Touche, for an amount in excess of
$50,000.00 and costs of this suit and for any other relief this Court deems equitable and just.
COUNT III – CHARLES RODOCKER
19. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein;
20. At the aforementioned time and place the Defendant, Charles Rodocker, individually and
by and through his agents and servants of Touche, owed a duty to exercise reasonable care in the
operation and control of its premises, including the supervision, training, and employment of its
staff, agents and servants so that they would not cause serious injury to lawful patrons and invitees
such as Plaintiff;
21. In violation of said duty, Defendant, Charles Rodocker, individually and by and through
his agents and servants of Touche, was guilty of one or more of the following careless and negligent
acts and omissions:
a. Carelessly and negligently failed to supervise its agents and servants, and
employees including but not limited to security and hospitality personnel so that
they would not push, trip or shove or take violent physical acts against Plaintiff as
he was leaving the premises thereby causing Plaintiff serious injury;
b. Carelessly and negligently failed to train its agents and servants, and employees
including but not limited to it’s security and hospitality personnel so that they would
not push, trip or shove or take violent physical acts against Plaintiff as he was
FILED DATE: 5/16/2024 4:23 PM 2024L005478
leaving the premises thereby causing Plaintiff serious injury;
c. Failed to insure that once Defendant requested a lawful and paying patron such as
Plaintiff to leave the premises, that an individual such as Plaintiff would be allow
to peacefully leave without being tripped, pushed or shoved or have violent action
taken against Plaintiff as he was leaving the premises thereby causing Plaintiff
serious injury;
d. Was otherwise careless and negligent.
22. As a direct and proximate cause of one or more of the aforementioned negligent acts and
omissions by Defendant, Charles Rodocker, individually and by and through his agents and
servants of Touche, the Plaintiff was violently attacked by agents and servants of Defendant
causing him to strike his head on the pavement outside of the front door to Touche;
23. As further direct and proximate result of the aforementioned careless and negligent acts
and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred
medical expenses in relation to the same, lost time from work, and sustained a loss of a normal
life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose
time from work, and sustain a loss of a normal life in the future.
WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in
his favor and against the Defendant, Charles Rodocker, for an amount in excess of $50,000.00 and
costs of this suit and for any other relief this Court deems equitable and just.
COUNT IV – KEVIN LEE HEINDORF
24. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein;
25. At the aforementioned time and place the Defendant, Kevin Lee Heindorf, individually and
by and through his agents and servants of Touche, owed a duty to exercise reasonable care in the
operation and control of its premises, including the supervision, training, and employment of its
staff, agents and servants so that they would not cause serious injury to lawful patrons and invitees
FILED DATE: 5/16/2024 4:23 PM 2024L005478
such as Plaintiff;
26. In violation of said duty, Defendant, Kevin Lee Heindorf, individually and by and through
his agents and servants of Touche, was guilty of one or more of the following careless and negligent
acts and omissions:
a. Carelessly and negligently failed to supervise its agents and servants, and
employees including but not limited to security and hospitality personnel so that
they would not push, trip or shove or take violent physical acts against Plaintiff as
he was leaving the premises thereby causing Plaintiff serious injury;
b. Carelessly and negligently failed to train its agents and servants, and employees
including but not limited to it’s security and hospitality personnel so that they would
not push, trip or shove or take violent physical acts against Plaintiff as he was
leaving the premises thereby causing Plaintiff serious injury;
c. Failed to insure that once Defendant requested a lawful and paying patron such as
Plaintiff to leave the premises, that an individual such as Plaintiff would be allow
to peacefully leave without being tripped, pushed or shoved or have violent action
taken against Plaintiff as he was leaving the premises thereby causing Plaintiff
serious injury;
d. Was otherwise careless and negligent.
27. As a direct and proximate cause of one or more of the aforementioned negligent acts and
omissions by Defendant, Kevin Lee Heindorf, individually and by and through his agents and
servants of Touche, the Plaintiff was violently attacked by agents and servants of Defendant
causing him to strike his head on the pavement outside of the front door to Touche;
28. As further direct and proximate result of the aforementioned careless and negligent acts
and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred
medical expenses in relation to the same, lost time from work, and sustained a loss of a normal
life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose
time from work, and sustain a loss of a normal life in the future.
FILED DATE: 5/16/2024 4:23 PM 2024L005478
WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in
his favor and against the Defendant, Kevin Lee Heindorf, for an amount in excess of $50,000.00
and costs of this suit and for any other relief this Court deems equitable and just.
Respectfully submitted,
Seidman, Margulis & Fairman
by: /s/Sean M. Baker
One of the attorneys for Plaintiff
Sean M. Baker
Seidman, Margulis & Fairman
Two First National Plaza
20 South Clark Street, Suite 700
Chicago, IL 60603
(312) 781-1977
sbaker@seidmanlaw.net
Preview
Law Division Motion Section Initial Case Management Dates for CALENDARS (A,B,C,D,E,F,H,R,X,Z) will be heard In Person. All other Law Division Initial Case Management Dates will be heard via Zoom For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12 Court Date: 7/17/2024 11:00 AM FILED 5/16/2024 4:23 PM IN THE CIRCUIT COURT OF COOK COUNTY – ILLINOIS IRIS Y. MARTINEZ CIRCUIT CLERK COUNTY DEPARTMENT – LAW DIVISION COOK COUNTY, IL FILED DATE: 5/16/2024 4:23 PM 2024L005478 2024L005478 EDWARD SOCORRO, ) Calendar, B Plaintiff, ) 27731304 ) 2024L005478 v. ) No.: _________________ ) TOUCHE, and ) NIGHT BEFORE, INC. d/b/a ) TOUCHE, and CHARLES ) RODOCKER, and KEVIN ) LEE HEINDORF, ) Defendants. ) COMPLAINT NOW COMES the Plaintiff, Edward Socorro by and through his attorneys, Seidman, Margulis & Fairman and for his Complaint against the Defendants, Touche, and Night Before, Inc. d/b/a/ Touche, and Charles Rodocker, and Kevin Lee Heindorf states as follows: FACTS COMMON TO ALL COUNTS: 1. At all times relevant to this Complaint, the Plaintiff, Edward Socorro, was a resident of Chicago, Cook County, Illinois 2. At all times relevant to this Complaint, the Defendant, Touche, was a business licensed and operating under the laws of the State of Illinois with a common address of 6412 North Clark Street, Chicago, Illinois; 3. At all times relevant to this Complaint, the Defendant, Night Before, Inc. d/b/a Touche, was a business licensed and operating under the laws of the State of Illinois with a common address of 6412 North Clark Street, Chicago, Illinois; 4. At all times relevant to this Complaint, the Defendant, Charles Rodocker, owned, operated, maintained and controlled the business Touche and/or Night Before, Inc. d/b/a Touche, licensed and operating under the laws of the State of Illinois with a common address of 6412 North Clark Street, Chicago, Illinois; FILED DATE: 5/16/2024 4:23 PM 2024L005478 5. At all times relevant to this Complaint, the Defendant, Kevin Lee Heindorf, owned, operated, maintained and controlled the business Touche and/or Night Before, Inc. d/b/a Touche, licensed and operating under the laws of the State of Illinois with a common address of 6412 North Clark Street, Chicago, Illinois; 6. On or about May 19, 2022, the Plaintiff, Edward Socorro, was a invitee and paying customer of the aforementioned business, Touche and/or Night Before, Inc. d/b/a Touche, and was inside of the establishment when he was asked to leave the premises by the agents and staff of Touche and/or Night Before, Inc. d/b/a Touche. 7. At the aforementioned place and time, Plaintiff, Edward Socorro, was inside of the establishment when he was asked by the agents and staff of Touche and/or Night Before, Inc. d/b/a Touche to leave the premises; 8. Plaintiff, after being asked to leave the premises, was on his way out of the front door to the establishment when one of the agents and servants of Defendant, Touche and/or Night Before, Inc. d/b/a Touche, physically attacked Plaintiff, striking him, shoving him and ultimately causing Plaintiff to violently fall and strike his head on the pavement outside of the front door to Touche and/or Night Before, Inc. d/b/a Touche; COUNT I - TOUCHE 9. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein; 10. At the aforementioned time and place the Defendant, Touche, owed a duty to exercise reasonable care in the operation and control of its premises, including the supervision, training, and employment of its staff, agents and servants so that they would not cause serious injury to lawful patrons and invitees such as Plaintiff; FILED DATE: 5/16/2024 4:23 PM 2024L005478 11. In violation of said duty, Defendant, Touche, individually and by and through it agents and servants was guilty of one or more of the following careless and negligent acts and omissions: a. Carelessly and negligently failed to supervise its agents and servants, and employees including but not limited to security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; b. Carelessly and negligently failed to train its agents and servants, and employees including but not limited to it’s security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; c. Failed to insure that once Defendant requested a lawful and paying patron such as Plaintiff to leave the premises, that an individual such as Plaintiff would be allow to peacefully leave without being tripped, pushed or shoved or have violent action taken against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; d. Was otherwise careless and negligent. 12. As a direct and proximate cause of one or more of the aforementioned negligent acts and omissions by Defendant, Touche, the Plaintiff was violently attacked by agents and servants of Touche causing him to strike his head on the pavement outside of the front door of Touche; 13. As further direct and proximate result of the aforementioned careless and negligent acts and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred medical expenses in relation to the same, lost time from work, and sustained a loss of a normal life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose time from work, and sustain a loss of a normal life in the future. WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in his favor and against the Defendant, Touche, for an amount in excess of $50,000.00 and costs of FILED DATE: 5/16/2024 4:23 PM 2024L005478 this suit and for any other relief this Court deems equitable and just. COUNT II – NIGHT BEFORE, INC. 14. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein; 15. At the aforementioned time and place the Defendant, Night Before, Inc. d/b/a/Touche, owed a duty to exercise reasonable care in the operation and control of its premises, including the supervision, training, and employment of its staff, agents and servants so that they would not cause serious injury to lawful patrons and invitees such as Plaintiff; 16. In violation of said duty, Defendant, Night Before, Inc. d/b/a/Touche, individually and by and through it agents and servants was guilty of one or more of the following careless and negligent acts and omissions: a. Carelessly and negligently failed to supervise its agents and servants, and employees including but not limited to security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; b. Carelessly and negligently failed to train its agents and servants, and employees including but not limited to it’s security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; c. Failed to insure that once Defendant requested a lawful and paying patron such as Plaintiff to leave the premises, that an individual such as Plaintiff would be allow to peacefully leave without being tripped, pushed or shoved or have violent action taken against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; d. Was otherwise careless and negligent. 17. As a direct and proximate cause of one or more of the aforementioned negligent acts and omissions by Defendant, Night Before, Inc. d/b/a/Touche, the Plaintiff was violently attacked by agents and servants of Touche causing him to strike his head on the pavement outside of the front door of Touche; FILED DATE: 5/16/2024 4:23 PM 2024L005478 18. As further direct and proximate result of the aforementioned careless and negligent acts and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred medical expenses in relation to the same, lost time from work, and sustained a loss of a normal life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose time from work, and sustain a loss of a normal life in the future. WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in his favor and against the Defendant, Night Before, Inc. d/b/a/Touche, for an amount in excess of $50,000.00 and costs of this suit and for any other relief this Court deems equitable and just. COUNT III – CHARLES RODOCKER 19. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein; 20. At the aforementioned time and place the Defendant, Charles Rodocker, individually and by and through his agents and servants of Touche, owed a duty to exercise reasonable care in the operation and control of its premises, including the supervision, training, and employment of its staff, agents and servants so that they would not cause serious injury to lawful patrons and invitees such as Plaintiff; 21. In violation of said duty, Defendant, Charles Rodocker, individually and by and through his agents and servants of Touche, was guilty of one or more of the following careless and negligent acts and omissions: a. Carelessly and negligently failed to supervise its agents and servants, and employees including but not limited to security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; b. Carelessly and negligently failed to train its agents and servants, and employees including but not limited to it’s security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was FILED DATE: 5/16/2024 4:23 PM 2024L005478 leaving the premises thereby causing Plaintiff serious injury; c. Failed to insure that once Defendant requested a lawful and paying patron such as Plaintiff to leave the premises, that an individual such as Plaintiff would be allow to peacefully leave without being tripped, pushed or shoved or have violent action taken against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; d. Was otherwise careless and negligent. 22. As a direct and proximate cause of one or more of the aforementioned negligent acts and omissions by Defendant, Charles Rodocker, individually and by and through his agents and servants of Touche, the Plaintiff was violently attacked by agents and servants of Defendant causing him to strike his head on the pavement outside of the front door to Touche; 23. As further direct and proximate result of the aforementioned careless and negligent acts and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred medical expenses in relation to the same, lost time from work, and sustained a loss of a normal life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose time from work, and sustain a loss of a normal life in the future. WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in his favor and against the Defendant, Charles Rodocker, for an amount in excess of $50,000.00 and costs of this suit and for any other relief this Court deems equitable and just. COUNT IV – KEVIN LEE HEINDORF 24. Plaintiff repeats and re-alleges Paragraphs one (1) through nine (9) as if fully stated herein; 25. At the aforementioned time and place the Defendant, Kevin Lee Heindorf, individually and by and through his agents and servants of Touche, owed a duty to exercise reasonable care in the operation and control of its premises, including the supervision, training, and employment of its staff, agents and servants so that they would not cause serious injury to lawful patrons and invitees FILED DATE: 5/16/2024 4:23 PM 2024L005478 such as Plaintiff; 26. In violation of said duty, Defendant, Kevin Lee Heindorf, individually and by and through his agents and servants of Touche, was guilty of one or more of the following careless and negligent acts and omissions: a. Carelessly and negligently failed to supervise its agents and servants, and employees including but not limited to security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; b. Carelessly and negligently failed to train its agents and servants, and employees including but not limited to it’s security and hospitality personnel so that they would not push, trip or shove or take violent physical acts against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; c. Failed to insure that once Defendant requested a lawful and paying patron such as Plaintiff to leave the premises, that an individual such as Plaintiff would be allow to peacefully leave without being tripped, pushed or shoved or have violent action taken against Plaintiff as he was leaving the premises thereby causing Plaintiff serious injury; d. Was otherwise careless and negligent. 27. As a direct and proximate cause of one or more of the aforementioned negligent acts and omissions by Defendant, Kevin Lee Heindorf, individually and by and through his agents and servants of Touche, the Plaintiff was violently attacked by agents and servants of Defendant causing him to strike his head on the pavement outside of the front door to Touche; 28. As further direct and proximate result of the aforementioned careless and negligent acts and omissions, Plaintiff sustained serious, painful and permanent personal injuries, incurred medical expenses in relation to the same, lost time from work, and sustained a loss of a normal life. Plaintiff, Edward Socorro, will continue to suffer said injuries, incur medical expenses, lose time from work, and sustain a loss of a normal life in the future. FILED DATE: 5/16/2024 4:23 PM 2024L005478 WHEREFORE the Plaintiff, Edward Socorro, requests that this Court enter judgment in his favor and against the Defendant, Kevin Lee Heindorf, for an amount in excess of $50,000.00 and costs of this suit and for any other relief this Court deems equitable and just. Respectfully submitted, Seidman, Margulis & Fairman by: /s/Sean M. Baker One of the attorneys for Plaintiff Sean M. Baker Seidman, Margulis & Fairman Two First National Plaza 20 South Clark Street, Suite 700 Chicago, IL 60603 (312) 781-1977 sbaker@seidmanlaw.net