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Complaint-Verified

CCM N008-50M-2/25/05(

(This form replaces CCMD-8A)

)

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

536 Kirkwood LLC

_______________________________________________
Plaintiff(s)

v.
Proco Joseph Moreno III, Friends of Proco Joe Moreno

_______________________________________________
Defendant(s)

}

No. _____________________________________

Contract _________________________________

_________________________
Amount Claimed $ 6,497.54
Return Date ______________________________

COMPLAINT
The Plaintiff(s) claim(s) as follows:

1) Plaintiff is a limited liability company registered in the State of Illinois. Defendants are an alderman for the City
of Chicago and his election committee.
2) On July 15, 2011, the defendant entered into a Commerical Lease Agreement with Rockwell Partners (Exhibit
A). Plaintiff became successor to the lease agreement when plainiff purchased the property at a sheriff's sale.
3) The lease terminated on July 31, 2015 and defendant moved out sometime in August.
4) After defendant vacated the premises, upon inspection of the property, the plaintiff discovered the following
unrepaired damages: broken bathroom vanity drawer, 2 damaged hollowcore doors, damage to a wall, damage to all
carpeting. The plaintiff obtained an estimate to replace the carpeting for $6,497.54.
5) Paragraph 5 of the lease provides "During the Lease term, Tenant shall make, at Tenant's expense, all necessary
repairs to the Leased Premises damaged or worn through normal occupancy, except for major mechanical systems
or the roof..."
6) On September 10, 2015, plaintiff sent notification to defendant of the damages and demanded payment.
Defendant failed to respond.
7) On November 2, 2015, plaintiff again sent notification to defendant via Fed Ex. Defendant failed to respond.
8) Defendant requests judgment in the amount of $6,497.54 plus costs and attorney's fees against the defendant
Proco Joseph Moreno III.

Brian Freiman
I, _______________________________________
, certify that I am the attorney
________________________________________
(Name)

(Name of Attorney if applicable)

plaintiff in the above entitled action. The allegations in this complaint are true.
Atty. No.: 45806
______________

Pro Se 99500

Dated:____________________________, ________

Atty. (or Pro Se Plaintiff):

Freiman
Name: Brian
__________________________________________

_______________________________________

N. Elston Ave.
Address: 2260
________________________________________

Signature

IL 60614
City/State/Zip:Chicago,
___________________________________ 

Under penalties as provided by law pursuant to 735 ILCS 5/1-109

Telephone: 847-903-1470
______________________________________

the abovesigned certifies that the statements set forth herein
are true and correct.

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
ORIGINAL COURT FILE