Preview
FILED
7/15/2020 3:37 PM
DOROTHY BROWN
CIRCUIT CLERK
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COOK COUNTY, IL
COUNTY DEPARTMENT, LAW DIVISION
FILED DATE: 7/15/2020 3:37 PM 2020L007509
9779877
SUSAN STURGIS ) 2020L007509
) Case No. ______________________
)
Plaintiff, )
v. )
) Calendar: ___
CARDENAS CONSTRUCTION, INC.; )
MASTER-HOME-INSPECTORS, INC.; )
SU FAMILIA REAL ESTATE INC.; ANGEL ) Ad Damnum: $184,548.00 + costs
CARDENAS; GASPAR FLORES; TRINIDAD )
GALLEGOS; and DAVID MCMASTERS; )
) Property: 2925 W. Walnut St.
) Chicago, Illinois, 60612
Defendants. )
VERIFIED COMPLAINT AT LAW
NOW COMES the Plaintiff, Susan Sturgis, by and through her attorney, James Sethna of
Ashen Law Group, and for her Complaint against Defendants, Cardenas Construction, Inc.; Master-
Home-Inspectors, Inc.; Su Familia Real Estate Inc.; Gaspar Flores; Trinidad Gallegos; David
McMasters; and states as follows:
PARTIES
1. At all times relevant, Plaintiff, Susan Sturgis (“Plaintiff-Purchaser”) is a resident of
the State of Illinois and current owner of the real property commonly known as 2925 W. Walnut
Street, Chicago, Illinois 60612 (the “Property”).
2. Cardenas Construction, Inc. (“Cardenas Construction”) is an Illinois corporation
with its principal place of business in Cook County, Illinois and is engaged in the business of home
construction.
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3. Master-Home-Inspectors, Inc. (“Master-Inspectors”) is an Illinois corporation with
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its principal place of business in Cook County, Illinois, and is engaged in the business conducting
home inspections.
4. Su Familia Real Estate Inc. (“Su Familia”) is an Illinois corporation with its principal
place of business in Cook County, Illinois, and is engaged in the business of real estate sales
brokerage.
5. Angel Cardenas is a resident of the state of Illinois and President of Cardenas
Construction. At all times relevant, Cardenas was acting individually, and in his capacity as President
of Cardenas Construction.
6. Gaspar Flores is a real estate agent and employee of Su Familia. At all times relevant,
Flores was acting individually, and in his capacity as an employee of Su Familia and as an agent for
Trinidad Gallegos (referred to herein collectively with Su Familia as the “Seller’s Agent”).
7. Trinidad Gallegos (“Defendant-Seller”) is the previous owner of the Property and a
resident of the state of Illinois.
8. David McMasters is a resident of the state of Illinois and President of Master-Home-
Inspectors. At all times relevant, the Inspector was acting individually, and in his capacity as
President of Master-Inspectors (referred to herein collectively with Master-Inspectors as the
“Inspector”).
JURISDICTION AND VENUE
9. This Court has personal jurisdiction over the Defendants pursuant to 735 ILCS 5/2-
209 because the Defendants conduct business in Cook County, Illinois and because the transactions
out of which the cause of action arose took place in Cook County, Illinois.
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10. Venue lies in this Court pursuant to 735 ILCS 5/2-103 because the transactions out
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of which this cause of action arose took place in Cook County, Illinois, and all Defendants are
residents of and conduct business in Cook County.
FACTS COMMON TO ALL COUNTS
11. Plaintiff-Purchaser restates, realleges, and incorporates Paragraphs 1-10 as fully set
forth herein as Paragraph 12.
12. On or about July 05, 2018, Plaintiff-Purchaser and Defendant-Seller entered into a
contract for the purchase and sale of the Property (the “Contract”). A true and correct copy of the
Contract is attached hereto as Exhibit A.
13. Defendant-Seller was represented by attorney Ricardo Correa (the “Seller’s
Attorney”) for the duration of the transaction.
14. Pursuant to the Contract, Defendant-Seller had a duty to act in good faith, and to
make certain disclosures concerning the Property.
15. Pursuant to Contract, Defendant-Seller provided Plaintiff-Purchaser with a
Residential Real Property Disclosure Report (the “Disclosure”) and warranted and represented that
they had no knowledge or notice of issues affecting the Property; such warranties and
representations were to expressly survive closing in this matter. A true and correct copy of the
Disclosure is attached hereto as Exhibit B.
16. Specifically, within the Disclosure, Defendant-Seller warranted and represented that
he was not aware of any “current infestations of termites or other wood boring insects.”
17. Also within the Disclosure, Defendant-Seller warranted and represented that he was
not “aware of any structural defect caused by previous infestations of termites or other wood boring
insects.”
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18. Also within the Disclosure, Defendant-Seller warranted and represented that he was
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not aware of any “material defects in the basement or foundation.”
19. Also within the Disclosure, Defendant-Seller warranted and represented that he was
not aware of any “material defects in the walls, windows, doors, or floors.”
20. Pursuant to the Contract, on July 09, 2020 Plaintiff-Purchaser hired a licensed home
inspector to conduct an inspection of the Premises, which revealed suspected termite damaged areas
and termite tubes throughout the crawlspace, including the joists and floors, and recommended
further evaluation as shown on Pages 2 and 9 of the report. A copy of Plaintiff-Purchaser’s
inspection report is attached hereto as Exhibit C.
21. During the attorney-review period of the Contract, on July 11, 2018, Plaintiff-
Purchaser provided Seller-Attorney a copy of the Inspection Report and proposed the following:
“16(d) – Floor joists show insect damage and deterioration throughout the crawl space. Seller is to
have the crawl space evaluated/treated by a termite remediation specialist and all damaged areas
repaired by a licensed contractor.” (emphasis added). A true and correct copy of the addendum to
the Contract produced during Attorney-Review is attached hereto as Exhibit D.
22. In response, the Seller-Attorney replied, “Seller has ordered a termite inspection and
agrees to treating any affected area. Damage will be evaluated by the general contractor and Seller
will repair any affected areas that need to be repaired.” A true and correct copy of the e-mail
correspondence between Seller-Attorney and Plaintiff-Purchaser’s attorney is attached hereto as
Exhibit E.
23. In response, on July 17, 2020 Purchaser’s attorney further amended the request to
state, “The termite remediation is to be completed by a licensed termite exterminating company,
with said company to provide written certification that the termite treatment has been completed
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and that all evidence of termites and termite activity has been eliminated (Seller previously agreed
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that damage to be evaluated by the general contractor and Seller will repair any affected areas that
need to be repaired). See Exhibit E.
24. In response, on July 17, 2020 Seller-Attorney stated, “Agreed. Will forward termite
inspection as soon as I receive it.” See Exhibit E.
25. Pursuant to the Contract addendum, Defendant-Seller was to provide an inspection
from a licensed termite exterminating company.
26. On July 20, 2018, Seller-Attorney provided Plaintiff-Purchaser’s Attorney a termite
inspection report on Form NPMA-33 dated July 18, 2018, prepared by Master-Inspectors and
signed by David McMasters (the “First Report”). A true and correct copy of the First Report is
attached hereto as Exhibit F.
27. The Form NPMA-33 is produced by the National Pest Management Association
(“NPMA”), and is a form commonly used by licensed pest inspection professionals.
28. The Form NPMA-33 has specific guidelines for the use and proper completion of
the form which must be adhered to.
29. The Form NPMA-33 is a copyrighted document that may not be reproduced or
distributed, in whole or in part, without prior written consent of the NPMA.
30. In January 2020 Purchaser-Plaintiff learned that Defendant-Inspector is not a
licensed termite exterminating company, but rather a licensed home inspector.
31. In a deliberate effort to misrepresent himself as a licensed pest inspector, and/or
termite remediation specialist, the Inspector recreated and doctored the Form NPMA-33 as
evidenced by irregularities between the official Form NPMA-33, and the doctored form utilized by
the Inspector.
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32. The First Report indicated “NO visible evidence of wood destroying insects was
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observed,” but also noted the Inspector had ‘no access’ to the crawlspace.
33. After Plaintiff-Purchaser’s attorney informed the Seller’s Attorney that no inspection
of the crawlspace had been performed, Seller’s Attorney indicated he was “not satisfied” with First
Report and would request a complete inspection. See Exhibit E.
34. On July 20, 2018 Seller-Attorney provided Purchaser’s attorney with an email sent by
Defendant-Agent to Defendant-Inspector stating “…the attorney wants the crawl space to be
inspected…” to which Defendant-McMasters replied “The access was screwed at the time of the
inspection I need permission in writing from the seller so that I can remove the screws and access
the crawlspace.” Id.
35. On July 25, 2018, the Seller’s Agent provided Seller’s Attorney with a second
NPMA-33 Wood Destroying Insect Inspection Report, also dated July 18, 2018, and prepared by
Master-Inspector’s and signed by David McMasters (the “Second Report”). A true and correct copy
of the Second Report is attached hereto as Exhibit G.
36. The Second Report, also on a Form NPMA-33 indicated “NO visible evidence of
wood destroying insects was observed” and “no treatment recommended”. See Exhibit G.
37. The Second Report indicated Defendant-Inspector had ‘limited access’ to the
crawlspace. However, when Purchaser’s Attorney inquired as to why limited access was granted,
Seller’s-Attorney represented the Inspector was given “complete access.” See Exhibits G and E,
respectively.
38. On July 25, 2018, Seller’s Attorney also represented that “Seller will proceed to
complete the repairs including any repairs that may be required with respect to the wood beams
located in the front he [sic] crawl space.” See Exhibit E.
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39. On August 17, 2018, Seller-Attorney supplied Plaintiff-Purchaser with an invoice
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from Cardenas Construction representing, inter alia, that a vapor barrier and missing installation had
been installed in the crawl space, and all damaged joists were repaired. A true and correct copy of
the Cardenas Construction Repair invoice dated August 17, 2018 is attached hereto as Exhibit H.
40. Plaintiff-Purchaser performed all of her duties and obligations as provided for in the
Contract.
41. On or about August 28, 2018, the transaction closed, and Plaintiff-Buyer took
possession of the Property.
42. On December 31, 2019, Plaintiff-Purchaser became aware of extensive damage
throughout the Property she believed may have been the result of an extensive and ongoing termite
infestation.
43. Plaintiff-Purchaser subsequently contacted Terminix for a termite inspection and
estimate for remediation.
44. At the request of Plaintiff-Purchaser, on January 4, 2020, Terminix inspected the
Property and discovered extensive termite damage and termite tubes throughout the crawlspace,
extensive termite damage throughout the interior of the Premises extending through the stairway
and into the second story. Further, upon inspection of the crawlspace Terminix discovered there
was no insulation in the crawlspace, a proper vapor barrier had not been installed, and damaged
joists were not sistered. A copy of the Terminix report is attached hereto as Exhibit I.
45. Terminix further reported to Plaintiff-Purchaser that it would take multiple years of
active infestation for termites to reach the second story of a home.
46. In coordination with and at the behest of Defendant-Seller and Seller’s-Agent,
Cardenas Construction misrepresented to Plaintiff-Purchasers that it completed the vapor barrier
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and insulation installation, and repaired the damaged joists; all work that Cardenas Construction in
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fact had not performed.
47. Terminix performed termite remediation, insulated the crawl space, and installed the
vapor barrier, at a cost to Plaintiff-Purchaser of $8,548.00. True and correct copies of Plaintiff-
Purchaser’s payments to Terminix are collectively attached hereto as Exhibit J.
48. Terminix further related to Plaintiff-Purchaser that Terminix had previously
inspected the Property on June 18, 2018, which was less than one month prior to the formation of
the Contract, but no remediation or treatment was completed.
49. Furthermore, in January 2020 Plaintiff-Purchaser learned the Defendant-Seller had
entered into a Purchase and Sale contract for the Premises between June 14, 2020 and June 27, 2020,
at which time the purchasers had a professional inspection conducted on the Premises. That
inspection revealed termite damage and termite tubes and recommended further evaluation and
remediation. Due to the fact that Defendant-Seller, through Defendant-Agent and/or Defendant-
Attorney, refused to address the termite findings, the purchasers terminated the contract.
50. In the prior terminated contract, Defendant-Seller was represented by Seller’s-
Attorney and Seller’s-Agent.
51. Defendant-Seller, Seller’s-Attorney, and Seller’s-Agent were each aware of the
termite infestation at the Property and failed to disclose the infestation to Plaintiff-Purchaser.
52. Defendant-Seller, Seller’s-Attorney, and Seller’s Agent worked in concert to actively
conceal the termite infestation at the Property in order to induce Plaintiff-Purchaser into acquiring
the Property.
53. Plaintiff-Purchaser has also discovered further evidence of recent cursory “repairs”
conducted with the intent of concealing extensive termite damage to the floors, drywall, beams, and
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studs. Said “repairs” include, but are not limited to, patching and refinishing of termite-damaged
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hardwood floors, stair treads, and subfloor, and new trim and drywall installed over heavily damaged
beams and studs.
54. These “repairs” are further evidence of a scheme and artifice to defraud Plaintiff-
Purchaser into buying the Property.
55. Plaintiff-Purchaser has obtained estimates to repair and replace termite damaged
joists, studs, posts, frames, drywall, stairway, floors, and subfloors throughout the home at an
estimated cost of $176,000.00. A true and correct copy of the estimate of repair by Smart
Construction & Design Co. is attached hereto as Exhibit K.
56. Defendant-Seller, Seller’s-Agent, Cardenas Construction, and the Inspector engaged
in a deliberate scheme and artifice to conceal, mislead, and misrepresent this material fact in an
effort to defraud Plaintiff-Purchaser into buying the Property.
COUNT I
FRAUD
(Against all Defendants)
57. Plaintiff-purchaser restates, realleges, and reincorporates paragraphs 1-55 as if fully
set forth herein as Paragraph 57 of Count I.
58. Given the significant extent and duration of the termite infestation, the resulting
damage caused to the Property, the “repairs” conducted to conceal the infestation and damage, and
the prior terminated contract, Defendant-Seller, Seller’s-Agent, Seller’s-Attorney, and the Inspector
were aware of the termite infestation, and the damage caused to the Property by it.
59. Despite a duty to disclose the termite infestation, Defendants, working in
conjunction, did not disclose this material fact, and rather actively concealed the same by performing
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cosmetic “repairs” to conceal the damage, fabricating a false inspection report, and deliberately
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withholding this information from Plaintiff-Purchaser.
60. Defendants worked in concert to actively conceal the termite infestation at the
Property in order to induce Plaintiff-Purchaser into acquiring the Property.
61. Cardenas Construction and Angel Cardenas, in an effort to induce Plaintiff-
Purchaser into buying the Property, misrepresented that it had performed repairs that it did not
perform.
62. At no time herein relevant did Defendants disclose issues with termites as pled
herein.
63. Instead, Defendants, at all times herein relevant, maintained and represented to
Plaintiff-Purchaser that the Property was without known issue or defect.
64. This presence of termites is an adverse condition that is, without question, a material
fact in the sale of the Property.
65. Defendants failed to disclose the termite infestation to Plaintiff-Purchase in order to
deceive and induce Plaintiff-Purchaser into buying the Property.
66. Defendants did not disclose the existence of termites because Defendants knew the
existence of such conditions would substantially decrease the value of the Property and ultimately
affect Plaintiff-Purchaser’s decision to buy the Property, and the sale price.
67. Plaintiff-Purchaser relied upon Defendant’s misrepresentations and purchased the
Property for a price well in excess of the actual value of the property.
68. Plaintiff has sustained money damages in excess of $184,548.00 in necessary repairs
to the Property as a result of the damage caused by termites, which Defendants misrepresented and
concealed.
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WHEREFORE, Plaintiff Susan Sturgis, prays that this Court enters Judgment in her favor
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and against Defendants Cardenas Construction, Inc., Master-Home-Inspectors, Inc., Su Familia Real
Estate Inc., Angel Cardenas, Gaspar Flores, Trinidad Gallegos, and David McMasters, and for an
entry of monetary damages to be proven at trial in the amount of no less than $184,548.00, plus
court costs and attorney’s fees, in an amount to be determined at trial, and for such other and
further relief that this Court deems just, equitable and proper.
COUNT II
BREACH OF CONTRACT
Against Defendant Gallegos
69. Plaintiff-purchaser restates, realleges, and reincorporates paragraphs 1-68 as if fully
set forth herein as Paragraph 67 of Count II.
70. Plaintiff-Purchaser and Defendant-Seller entered into a valid and enforceable real
estate purchase and sale agreement on July 05, 2018, for the sale of the Property.
71. Pursuant to the Contract, Defendant-Seller had a duty to act in good faith, in
addition to making certain disclosures concerning the Property.
72. Defendant-Seller, as a part of the Contract provided the aforementioned Disclosure
and warranted and represented Defendant-Seller had no knowledge or notice of issues affecting the
Property, and such warranties and representations were to expressly survive closing. See Exhibit B.
73. Defendant-Seller failed to disclose the existence of the termite infestation, in material
breach of his contractual obligation to act in good faith with Plaintiff-Purchaser.
74. In addition, Defendant-Seller failed to install the vapor barrier and insulation in the
crawlspace, and to repair damaged joists, as Defendant-Seller agreed to complete, and represented
it had in fact completed, during the attorney-review of the Contract.
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75. As a result of Defendant-Seller’s failure to disclose, Plaintiff-Purchaser has incurred
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$8,548.00 in costs, and must incur further significant costs to remediate the termites, and to repair
the damage caused by the ongoing termite infestation.
WHEREFORE, Plaintiff Susan Sturgis, prays that this Court enters Judgment in her favor
and against Defendant Trinidad Gallegos, and for an entry of monetary damages to be proven at
trial in the amount of no less than $184,548.00, plus attorney’s fees and court costs, in an amount to
be determined at trial, and for such other and further relief that this Court deems just, equitable and
proper.
COUNT III
Violation of Illinois Consumer Fraud and Deceptive Businesses Practices Act, 815 ILCS 505/1 et seq.
(Against Defendants Master-Inspectors and McMasters)
76. Plaintiff-purchaser restates, realleges, and reincorporates paragraphs 1-75 as if fully
set forth herein as Paragraph 74 of Count III.
77. In an effort to deceive Plaintiff-Purchaser, Inspector misrepresented himself as a
termite remediation specialist.
78. Without the authorization of the NPMA, the Inspector provided Plaintiff-Purchaser
with a completed Form NPMA-33; this was intended for the Plaintiff-Purchaser to rely on the
Inspector’s report that there was “NO visible evidence of wood destroying insects was observed”
during the Inspector’s inspection of the Property.
79. The Inspector is not licensed in pest remediation; nor is he a termite remediation
specialist.
80. The Inspector’s misrepresentation of himself as a termite remediation specialist
occurred in the conduct involving trade or commerce.
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81. As a proximate cause of this misrepresentation, Plaintiff-Purchaser completed her
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purchase of the Property, and subsequently incurred damages including $8,548.00, and must incur
further significant costs to remediate the termites, and to repair the damage caused by the termites.
WHEREFORE, Plaintiff Susan Sturgis, prays that this Court enters Judgment in her favor
and against Defendants Master-Home-Inspectors, Inc. and David McMasters, and for an entry of
monetary damages to be proven at trial in the amount of no less than $184,548.00, plus attorney’s
fees and court costs, in an amount to be determined at trial, and for such other and further relief
that this Court deems just, equitable and proper.
COUNT IV
Violation of Illinois Consumer Fraud and Deceptive Businesses Practices Act, 815 ILCS 505/1 et seq.
(Against Defendants Cardenas Construction and Angel Cardenas)
82. Plaintiff-purchaser restates, realleges, and reincorporates paragraphs 1-81 as if fully
set forth herein as Paragraph 80 of Count IV.
83. In an effort to deceive Plaintiff-Purchaser, Cardenas Construction and Angel
Cardenas supplied Plaintiff-Purchaser with an invoice indicating that insulation and a vapor barrier
had been installed in the crawlspace at the Property, and that all damaged joists had been repaired in
the basement, pursuant to the addendum of the Contract. See Exhibit H.
84. Cardenas Construction and Angel Cardenas had in fact not installed insulation, nor a
vapor barrier in the crawlspace at the Property, nor did they repair the damaged joists.
85. Cardenas Construction and Angel Cardenas intentionally falsified the invoice, and
intentionally misrepresented these material facts to Plaintiff-Purchaser with the intent Plaintiff-
Purchaser would rely on these misrepresentations.
86. These misrepresentations and deceptions occurred during conduct involving trade or
commerce.
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87. As a proximate cause of this misrepresentation, Plaintiff-Purchaser completed her
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purchase of the Property, and subsequently incurred damages including $8,548.00, and must incur
further significant costs to remediate the termites, and to repair the damage caused by the termites.
WHEREFORE, Plaintiff Susan Sturgis, prays that this Court enters Judgment in her favor
and against Defendants Cardenas Construction, Inc. and Angel Cardenas, and for an entry of
monetary damages to be proven at trial in the amount of no less than $184,548.00, plus attorney’s
fees and court costs, in an amount to be determined at trial, and for such other and further relief
that this Court deems just, equitable and proper.
COUNT V
NEGLIGENT MISREPRESENTATION
(Against Defendant Gallegos, Su Familia Real Estate, Inc., and Gaspar Flores)
88. Plaintiff-purchaser restates, realleges, and reincorporates paragraphs 1-87 as if fully
set forth herein as Paragraph 88 of Count V.
89. Defendant-Seller and Seller’s-Agent failed to disclose the material fact of termite
infestation at the Property.
90. In the alternative, Plaintiff-Purchaser alleges that Defendant-Seller and Seller’s-Agent
were negligent in ascertaining whether the Property was infested by termites.
91. Defendant-Seller and Seller’s-Agent were careless and/or negligent in ascertaining
whether the Property was infested by termites.
92. Defendant-Seller and Seller’s-Agent had a duty to provide an adequate inspection of
the Property that would have accurately determined whether the Property was infested by termites.
93. Defendant-Seller and Seller’s-Agent knew, or should have known, the presence of
termites was a material omission.
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94. Defendant-Seller and Seller’s-Agent intended Plaintiff-Purchaser to rely on the
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accuracy of this omission, and failed to disclose this material fact in order for Plaintiff-Purchaser to
enter the Contract and purchase the Property.
95. As a proximate cause of this material omission, Plaintiff-Purchaser completed her
purchase of the Property, and subsequently incurred damages including $8,548.00, and must incur
further significant costs to remediate the termites, and to repair the damage caused by the termites.
WHEREFORE, Plaintiff Susan Sturgis, prays that this Court enters Judgment in her favor
and against Defendants Trinidad Gallegos, Su Familia Real Estate Inc.; Gaspar Flores, and for an
entry of monetary damages to be proven at trial in the amount of no less than $184,548.00, plus
attorney’s fees and court costs, in an amount to be determined at trial, and for such other and
further relief that this Court deems just, equitable and proper.
Respectfully submitted,
By: /s/ James R. Sethna
Attorney for Plaintiff
James R. Sethna
ASHEN LAW GROUP
217 N. Jefferson St., Ste. 601
Chicago, IL 60661
(312) 655-0800
jrs@ashenlaw.com
Firm No. 39733
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STATE OF ILLINOIS )
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)
COUNTY OF COOK )
VERIFICATION
The undersigned, under penalties as provided by law pursuant to 735 ILCS 5/1-109, depose
and state that he/she has read the foregoing Verified Complaint and the allegations made herein are
true, correct and complete to the best of his/her knowledge and belief.
_______________________________ Date:_______________
Susan Sturgis
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Exhibit List
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Exhibit A: Contract
Exhibit B: Disclosure
Exhibit C: Inspection Report
Exhibit D: Addendum
Exhibit E: Attorney e-mail correspondence
Exhibit F: Inspector’s First Form NPMA-33 Report
Exhibit G: Inspector’s Second Form NPMA-33 Report
Exhibit H: Cardenas Construction Invoice
Exhibit I: Terminix Report
Exhibit J: Terminix Receipts
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Exhibit List
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Exhibit A: Contract
Exhibit B: Disclosure
Exhibit C: Inspection Report
Exhibit D: Addendum
Exhibit E: Attorney e-mail correspondence
Exhibit F: Inspector’s First Form NPMA-33 Report
Exhibit G: Inspector’s Second Form NPMA-33 Report
Exhibit H: Cardenas Construction Invoice
Exhibit I: Terminix Report
Exhibit J: Terminix Receipts
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EXHIBIT A
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EXHIBIT B
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EXHIBIT C
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