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: 9/4/2024 10:00 AM FILED
6/11/2024 12:21 PM
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ
COUNTY DEPARTMENT, LAW DIVISION CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 6/11/2024 12:21 PM 2024L006419
2024L006419
DEL GALDO LAW GROUP ) Calendar, A
) 28062963
Plaintiff, )
)
v. )
)
BURT ODELSON, )
)
Defendant. )
)
Plaintiff, DEL GALDO LAW GROUP, by its undersigned attorneys, LOEVY & LOEVY,
complains of Defendant BURT ODELSON as follows:
Introduction
1. Plaintiff Del Galdo Law Group is a law firm that provides legal representation to
municipalities throughout the Chicago area.
2. Established in 1998, the firm employs dozens of lawyers and has hundreds of
clients. It is one of the top, if not the top, law firms in Chicagoland practicing in the areas of
municipal law and public finance.
3. From May 2021 until April 2024, Plaintiff represented the Village of Dolton as
prosecutor and special counsel.
4. Dolton is an Illinois municipality located in Cook County, Illinois.
5. Defendant Burt Odelson is a partner at the law firm known as Odelson, Murphy,
Frazier, and McGrath Ltd., which also provides legal services to Chicago-area municipalities.
6. Defendant Odelson has a history of attempting to revoke power from mayors and
other elected officials in an effort to force out competing law firms providing municipal legal
services.
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7. In the Village of Dolton, Defendant Odelson defamed Plaintiff and sabotaged
Plaintiff’s legal representation agreement with the Village of Dolton in an effort to improperly
FILED DATE: 6/11/2024 12:21 PM 2024L006419
benefit his own firm.
Jurisdiction and Venue
8. This Court has jurisdiction over Defendant, who resides and transacts business in
this State.
9. Venue is proper in this Court because the parties reside in this County.
Background
10. Tiffany Henyard was elected to a four-year term as the Village of Dolton’s mayor
in 2021.
11. Illinois law authorizes mayors to retain legal counsel for the City.
12. After Mayor Henyard’s election, Defendant Odelson unsuccessfully sought to
have his firm appointed as Dolton’s village attorney.
13. Mayor Henyard, however, retained Plaintiff as the Village’s prosecutor and
special counsel in May 2021.
14. As special counsel, Plaintiff provided legal services in the fields of labor and
employment law and other projects assigned by the mayor.
15. The terms of engagement between the Village of Dolton and Plaintiff granted
Plaintiff broad authority in handling legal matters for the Village of Dolton.
16. At all times, Plaintiff abided by the agreed upon terms of engagement with the
Village of Dolton.
17. Defendant Odelson was aware that a valid contract existed between the Plaintiff
and the Village of Dolton.
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18. After Mayor Henyard spurned Defendant Odelson and appointed Plaintiff as
prosecutor and special counsel, Defendant Odelson assisted Dolton’s Board of Trustees in
FILED DATE: 6/11/2024 12:21 PM 2024L006419
passing a legislative counsel ordinance in 2021.
19. This ordinance authorized the Board to hire Defendant Odelson’s law firm as
legislative counsel.
20. As legislative counsel, Defendant Odelson and his firm were limited under Illinois
law to providing the Board of Trustees with advice about its legislative duties, including drafting
ordinances and providing opinions about Board’s legislative powers.
Defendant Odelson Defames Plaintiff at
Village of Dolton Special Board Meeting
21. Defendant Odelson’s improper campaign to force out Plaintiff as legal counsel for
the Village of Dolton culminated in Dolton’s Board of Trustees meeting on February 22, 2024.
22. Attendees at that February 22, 2024 meeting included the Dolton Board of
Trustees, Defendant Odelson and two other members of his law firm, and members of the public.
23. During that meeting, Defendant Odelson defamed Plaintiff.
24. First, Defendant Odelson informed meeting attendees, falsely, that Plaintiff had a
conflict of interest in representing the Village of Dolton.
25. Defendant Odelson threatened that he would immediately refer Plaintiff to the
Illinois Attorney Registration and Discipline Committee (“ARDC”) for investigation into this
purported conflict.
26. In fact, Plaintiff has never had a conflict of interest in representing the Village of
Dolton.
27. Defendant Odelson knew that Plaintiff had no conflict of interest representing the
Village of Dolton.
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28. Defendant Odelson’s statement was designed to intimidate Plaintiff from
providing representation to the Village of Dolton, and to convince members of the Board of
FILED DATE: 6/11/2024 12:21 PM 2024L006419
Trustees and the public that his firm was better suited than Plaintiff to provide all legal
representation for the Village.
29. Defendant Odelson also stated falsely that the Del Galdo Law Group served only
as the Village of Dolton’s prosecutor, not as Village attorney.
30. Defendant Odelson added that Plaintiff had billed the Village of Dolton tens of
thousands of dollars in violation of Dolton’s corporate authorities.
31. The Defendants’ statements referenced in the preceding two paragraphs are false.
32. Plaintiff had authorization from the mayor to serve as both prosecutor and special
counsel for the Village.
33. Plaintiff represented and billed the Village of Dolton consistent with its contract.
34. Defendant Odelson also stated that his law firm would request case files from
Plaintiff, and that no cases would go to default judgment, which Oldelson falsely claimed had
happened when Plaintiff represented the Village.
35. These statements are false.
36. No default judgments have been entered against the Village of Dolton in any case
where Plaintiff represented the Village.
37. Defendant Odelson knew these statements were false.
38. Defendant Odelson’s law firm has never requested Dolton’s case files from
Plaintiff.
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Defendant Odelson Further Defames Plaintiff
in Chicago Tribune Article and on WGN Radio
FILED DATE: 6/11/2024 12:21 PM 2024L006419
39. The Chicago Tribune published an article on February 23, 2024, about political
unrest in the Village of Dolton.
40. Defendant Odelson is quoted in the articles as stating that the Village of Dolton
“isn’t getting the representation it should” from Plaintiff.
41. In a WGN Radio interview on February 23, 2024, Defendant Odelson stated that
Plaintiff was representing the Village without authority from the Board of Trustees.
42. The statements referenced in preceding two paragraphs are false, and Defendant
Odelson knew that these statements were false.
43. Plaintiff has represented the Village as prosecutor and special counsel consistent
with the terms of its contract.
44. Under Illinois law, the Mayor has authority under Illinois law to appoint legal
counsel.
45. The Board of Trustees lacks authority to hire the Village’s legal counsel.
46. Defendant Odelson is an experienced municipal law attorney who understands the
authority and limitations of the municipal elected officials and trustees.
47. Defendant Odelson’s defamatory remarks about Plaintiff caused the relationship
between the Village of Dolton Board of Trustees and Plaintiff to deteriorate.
48. In April 2024, Plaintiff withdrew as the Village of Dolton’s legal counsel because
of Defendant Odelson’s interference in the relationship between Plaintiff and the Village.
49. Because of Defendant Odelson’s conduct, the Village of Dolton stopped paying
Plaintiff’s legal bills, causing Dolton to breach its contract with Plaintiff.
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Damages
50. Defendant Odelson’s false and misleading comments about Plaintiff were
FILED DATE: 6/11/2024 12:21 PM 2024L006419
designed to induce the Village of Dolton to push out Plaintiff and hire the Odelson Law Firm as
its sole legal counsel.
51. Defendant Odelson is an experienced municipal legal services attorney who
understood that his statements about Plaintiff were false.
52. Defendant Odelson’s conduct caused Plaintiff personal and professional
reputational damage.
53. Specifically, Defendant Odelson’s defamatory comments were designed to deter
other municipalities from hiring Plaintiff.
54. Defendant Odelson’s false and misleading statements and threats of initiating an
ARDC investigation caused attorneys working for Plaintiff emotional distress and humiliation.
COUNT I
Defamation
55. In the manner set forth above, Defendant Odelson published and caused to be
published intentionally false statements about or concerning Plaintiff that he knew to be false.
56. By engaging in the misconduct described in this Count, Defendant Odelson made
demonstrably false statements about and concerning Plaintiff to third parties. The things
Defendant Odelson said about Plaintiff were malicious, and Defendant Odelson made these
statements knowing they were entirely false.
57. Defendant Odelson acted with actual malice, reckless intent and gross
indifference to the false and misleading nature of his statements about and concerning Plaintiff
when he made them to third parties.
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58. These defamatory falsehoods were made with actual malice by Defendant
Odelson inasmuch as he knew of their falsity or recklessly disregarded their truth or falsity.
FILED DATE: 6/11/2024 12:21 PM 2024L006419
59. As a result of Defendant Odelson’s misconduct described in this Count, Plaintiff
suffered injuries, including reputational damage and humiliation.
60. In particular, Defendant Odelson’s per se defamatory comments have injured and
continue to injure Plaintiff by damaging his personal and professional reputation in the
community, deterring third persons from associating with him.
61. The actions and omissions of Defendant Odelson set forth in this Count
demonstrate malice, defamation, and insult. Defendant Odelson’s actions and omissions were
undertaken either with malice, spite, ill will, vengeance, or deliberate intent to harm Plaintiff, or
with reckless disregard to the falsity of the speech and its effect on Plaintiff. Accordingly,
Plaintiff is entitled to punitive damages and attorneys’ fees beyond those damages, described
above, that will compensate Plaintiff for injuries resulting from Defendant Odelson’s conduct.
Count II
Tortious Interference
62. Plaintiff and the Village of Dolton had a valid and enforceable contract for legal
services.
63. Defendant Odelson was aware that this contract existed, and intentionally
engaged in the conduct described above in an effort induce the Village of Dolton to breach that
contract.
64. As a result of Defendant’s misconduct, Plaintiff experienced reputational damage,
and attorneys working Plaintiff’s firm experienced emotional distress, humiliation, and
reputational damage.
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WHEREFORE, Plaintiff DEL GALDO LAW FIRM, respectfully requests that this Court
enter judgment in his favor and against BURT ODELSON awarding compensatory and punitive
FILED DATE: 6/11/2024 12:21 PM 2024L006419
damages and any other appropriate relief.
Jury Demand
Plaintiff, DEL GALDO LAW GROUP, hereby demands a trial by jury on all issues so
triable.
Respectfully submitted,
/s/ Jon Loevy
One of Plaintiff’s Attorneys
Jon Loevy
Gianna Gizzi
LOEVY & LOEVY
311 N. Aberdeen, 3rd
Floor Chicago, IL 60607
(312) 243-5900
Fax: (312) 243-5902
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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: 9/4/2024 10:00 AM FILED 6/11/2024 12:21 PM IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ COUNTY DEPARTMENT, LAW DIVISION CIRCUIT CLERK COOK COUNTY, IL FILED DATE: 6/11/2024 12:21 PM 2024L006419 2024L006419 DEL GALDO LAW GROUP ) Calendar, A ) 28062963 Plaintiff, ) ) v. ) ) BURT ODELSON, ) ) Defendant. ) ) Plaintiff, DEL GALDO LAW GROUP, by its undersigned attorneys, LOEVY & LOEVY, complains of Defendant BURT ODELSON as follows: Introduction 1. Plaintiff Del Galdo Law Group is a law firm that provides legal representation to municipalities throughout the Chicago area. 2. Established in 1998, the firm employs dozens of lawyers and has hundreds of clients. It is one of the top, if not the top, law firms in Chicagoland practicing in the areas of municipal law and public finance. 3. From May 2021 until April 2024, Plaintiff represented the Village of Dolton as prosecutor and special counsel. 4. Dolton is an Illinois municipality located in Cook County, Illinois. 5. Defendant Burt Odelson is a partner at the law firm known as Odelson, Murphy, Frazier, and McGrath Ltd., which also provides legal services to Chicago-area municipalities. 6. Defendant Odelson has a history of attempting to revoke power from mayors and other elected officials in an effort to force out competing law firms providing municipal legal services. 1 7. In the Village of Dolton, Defendant Odelson defamed Plaintiff and sabotaged Plaintiff’s legal representation agreement with the Village of Dolton in an effort to improperly FILED DATE: 6/11/2024 12:21 PM 2024L006419 benefit his own firm. Jurisdiction and Venue 8. This Court has jurisdiction over Defendant, who resides and transacts business in this State. 9. Venue is proper in this Court because the parties reside in this County. Background 10. Tiffany Henyard was elected to a four-year term as the Village of Dolton’s mayor in 2021. 11. Illinois law authorizes mayors to retain legal counsel for the City. 12. After Mayor Henyard’s election, Defendant Odelson unsuccessfully sought to have his firm appointed as Dolton’s village attorney. 13. Mayor Henyard, however, retained Plaintiff as the Village’s prosecutor and special counsel in May 2021. 14. As special counsel, Plaintiff provided legal services in the fields of labor and employment law and other projects assigned by the mayor. 15. The terms of engagement between the Village of Dolton and Plaintiff granted Plaintiff broad authority in handling legal matters for the Village of Dolton. 16. At all times, Plaintiff abided by the agreed upon terms of engagement with the Village of Dolton. 17. Defendant Odelson was aware that a valid contract existed between the Plaintiff and the Village of Dolton. 2 18. After Mayor Henyard spurned Defendant Odelson and appointed Plaintiff as prosecutor and special counsel, Defendant Odelson assisted Dolton’s Board of Trustees in FILED DATE: 6/11/2024 12:21 PM 2024L006419 passing a legislative counsel ordinance in 2021. 19. This ordinance authorized the Board to hire Defendant Odelson’s law firm as legislative counsel. 20. As legislative counsel, Defendant Odelson and his firm were limited under Illinois law to providing the Board of Trustees with advice about its legislative duties, including drafting ordinances and providing opinions about Board’s legislative powers. Defendant Odelson Defames Plaintiff at Village of Dolton Special Board Meeting 21. Defendant Odelson’s improper campaign to force out Plaintiff as legal counsel for the Village of Dolton culminated in Dolton’s Board of Trustees meeting on February 22, 2024. 22. Attendees at that February 22, 2024 meeting included the Dolton Board of Trustees, Defendant Odelson and two other members of his law firm, and members of the public. 23. During that meeting, Defendant Odelson defamed Plaintiff. 24. First, Defendant Odelson informed meeting attendees, falsely, that Plaintiff had a conflict of interest in representing the Village of Dolton. 25. Defendant Odelson threatened that he would immediately refer Plaintiff to the Illinois Attorney Registration and Discipline Committee (“ARDC”) for investigation into this purported conflict. 26. In fact, Plaintiff has never had a conflict of interest in representing the Village of Dolton. 27. Defendant Odelson knew that Plaintiff had no conflict of interest representing the Village of Dolton. 3 28. Defendant Odelson’s statement was designed to intimidate Plaintiff from providing representation to the Village of Dolton, and to convince members of the Board of FILED DATE: 6/11/2024 12:21 PM 2024L006419 Trustees and the public that his firm was better suited than Plaintiff to provide all legal representation for the Village. 29. Defendant Odelson also stated falsely that the Del Galdo Law Group served only as the Village of Dolton’s prosecutor, not as Village attorney. 30. Defendant Odelson added that Plaintiff had billed the Village of Dolton tens of thousands of dollars in violation of Dolton’s corporate authorities. 31. The Defendants’ statements referenced in the preceding two paragraphs are false. 32. Plaintiff had authorization from the mayor to serve as both prosecutor and special counsel for the Village. 33. Plaintiff represented and billed the Village of Dolton consistent with its contract. 34. Defendant Odelson also stated that his law firm would request case files from Plaintiff, and that no cases would go to default judgment, which Oldelson falsely claimed had happened when Plaintiff represented the Village. 35. These statements are false. 36. No default judgments have been entered against the Village of Dolton in any case where Plaintiff represented the Village. 37. Defendant Odelson knew these statements were false. 38. Defendant Odelson’s law firm has never requested Dolton’s case files from Plaintiff. 4 Defendant Odelson Further Defames Plaintiff in Chicago Tribune Article and on WGN Radio FILED DATE: 6/11/2024 12:21 PM 2024L006419 39. The Chicago Tribune published an article on February 23, 2024, about political unrest in the Village of Dolton. 40. Defendant Odelson is quoted in the articles as stating that the Village of Dolton “isn’t getting the representation it should” from Plaintiff. 41. In a WGN Radio interview on February 23, 2024, Defendant Odelson stated that Plaintiff was representing the Village without authority from the Board of Trustees. 42. The statements referenced in preceding two paragraphs are false, and Defendant Odelson knew that these statements were false. 43. Plaintiff has represented the Village as prosecutor and special counsel consistent with the terms of its contract. 44. Under Illinois law, the Mayor has authority under Illinois law to appoint legal counsel. 45. The Board of Trustees lacks authority to hire the Village’s legal counsel. 46. Defendant Odelson is an experienced municipal law attorney who understands the authority and limitations of the municipal elected officials and trustees. 47. Defendant Odelson’s defamatory remarks about Plaintiff caused the relationship between the Village of Dolton Board of Trustees and Plaintiff to deteriorate. 48. In April 2024, Plaintiff withdrew as the Village of Dolton’s legal counsel because of Defendant Odelson’s interference in the relationship between Plaintiff and the Village. 49. Because of Defendant Odelson’s conduct, the Village of Dolton stopped paying Plaintiff’s legal bills, causing Dolton to breach its contract with Plaintiff. 5 Damages 50. Defendant Odelson’s false and misleading comments about Plaintiff were FILED DATE: 6/11/2024 12:21 PM 2024L006419 designed to induce the Village of Dolton to push out Plaintiff and hire the Odelson Law Firm as its sole legal counsel. 51. Defendant Odelson is an experienced municipal legal services attorney who understood that his statements about Plaintiff were false. 52. Defendant Odelson’s conduct caused Plaintiff personal and professional reputational damage. 53. Specifically, Defendant Odelson’s defamatory comments were designed to deter other municipalities from hiring Plaintiff. 54. Defendant Odelson’s false and misleading statements and threats of initiating an ARDC investigation caused attorneys working for Plaintiff emotional distress and humiliation. COUNT I Defamation 55. In the manner set forth above, Defendant Odelson published and caused to be published intentionally false statements about or concerning Plaintiff that he knew to be false. 56. By engaging in the misconduct described in this Count, Defendant Odelson made demonstrably false statements about and concerning Plaintiff to third parties. The things Defendant Odelson said about Plaintiff were malicious, and Defendant Odelson made these statements knowing they were entirely false. 57. Defendant Odelson acted with actual malice, reckless intent and gross indifference to the false and misleading nature of his statements about and concerning Plaintiff when he made them to third parties. 6 58. These defamatory falsehoods were made with actual malice by Defendant Odelson inasmuch as he knew of their falsity or recklessly disregarded their truth or falsity. FILED DATE: 6/11/2024 12:21 PM 2024L006419 59. As a result of Defendant Odelson’s misconduct described in this Count, Plaintiff suffered injuries, including reputational damage and humiliation. 60. In particular, Defendant Odelson’s per se defamatory comments have injured and continue to injure Plaintiff by damaging his personal and professional reputation in the community, deterring third persons from associating with him. 61. The actions and omissions of Defendant Odelson set forth in this Count demonstrate malice, defamation, and insult. Defendant Odelson’s actions and omissions were undertaken either with malice, spite, ill will, vengeance, or deliberate intent to harm Plaintiff, or with reckless disregard to the falsity of the speech and its effect on Plaintiff. Accordingly, Plaintiff is entitled to punitive damages and attorneys’ fees beyond those damages, described above, that will compensate Plaintiff for injuries resulting from Defendant Odelson’s conduct. Count II Tortious Interference 62. Plaintiff and the Village of Dolton had a valid and enforceable contract for legal services. 63. Defendant Odelson was aware that this contract existed, and intentionally engaged in the conduct described above in an effort induce the Village of Dolton to breach that contract. 64. As a result of Defendant’s misconduct, Plaintiff experienced reputational damage, and attorneys working Plaintiff’s firm experienced emotional distress, humiliation, and reputational damage. 7 WHEREFORE, Plaintiff DEL GALDO LAW FIRM, respectfully requests that this Court enter judgment in his favor and against BURT ODELSON awarding compensatory and punitive FILED DATE: 6/11/2024 12:21 PM 2024L006419 damages and any other appropriate relief. Jury Demand Plaintiff, DEL GALDO LAW GROUP, hereby demands a trial by jury on all issues so triable. Respectfully submitted, /s/ Jon Loevy One of Plaintiff’s Attorneys Jon Loevy Gianna Gizzi LOEVY & LOEVY 311 N. Aberdeen, 3rd Floor Chicago, IL 60607 (312) 243-5900 Fax: (312) 243-5902 8