ELECTRONICALLY FILED 12/20/2017 9:45 AM. 2017-M1-135441 ROOM: i112 PAGE 1 of 10. IN THE CIRCUIT COURT OF COOK COUNTY, ILLINO BE COUNTS Ie LOIS MUNICIPAL DEPARTMENT - FIRST DISTRICT_ MUNICIPAL DIVISION CLERK DOROTHY BROWN SPEEDY CHECK CASHERS, INC., an Illinois corporation, Plaintiff, vs. Case No. THE BOEING COMPANY, a Delaware Amount claimed: $157.12, plus corporation, crest, treble damages, costs of suit, and attorneys’ fees Defendant(s) Return Date: January 29. 2018 VERIFIED COMPLAINT. Plaintiff. SPEEDY CHECK CASHERS. INC.. an Illinois corporation (“Currency Exchange"), by its attomeys, SORMAN & FRANKEL, LTD., for its Verified Complaint (the Complaint”) against Defendant, THE BOEING COMPANY. a Delaware corporation, (“Defendant”), states as follows: 1. Currency Exchange is a duly registered Iliinois corporation with its principal place of business located at 425 Huehl Road. Building 3. Northbrook, Cook County, Ilinois. Currency Exchange is a currency exchange regulated by the Illinois Department of incial and Professional Regulation and its principal business activities include. among, other things, providing check-cashing services to members of the general public for a fee. 2. Defendant is, upon information and belief. a duly registered Delaware corporation with its principal place of business located 100 N. Riverside, Chicago. Ilinois, Venue is proper in this Court pursuant to Section 5/2-101 of the Illinois Code of Civil Procedure, which provides that an action may be commenced “in the county in which the transaction or some part thereof occurred out of which the cause of action arose.” ILCS 5/2-101 (West 2017). A portion of the parties’ business dealings. as well as prior2017-MI-135441 PAGE 2 of 10 6. 10. and subsequent acts and a vities alleged and complained of herein. took place in Cook County. Iinois. On or about July 1, 2017. Defendant issued one cheek. n the amount of $132.12. payable to J.W, Pryor (“Payee”) and drawn on De jant’s bank account (the “Check”), a copy of Which is attached as Exhibit The Check is « negotiable instrument in that it is an unconditional promise 0 pay a definite amount of money. upon demand. payable to order. without any restriction on the face of the instrument. After the Check was issued. it was tendered to and negotiated by Currency Exchange in exchange for cash paid to the Payee. Within thirty (30) days thereafter. Currency Exchange presented the Check for payment and the Check was dis jonored by reason of “refer to maker.” Currency Exchange was charged “return check” fees by its bank. totaling $25.00, dishonored due to same. ion and belief, at the time of issuance of the Cheek, Defendant knew or Upon inform should have known that the Check would be dishonored upon presentment. ‘Alternatively. upon information and belief. upon issuance of the Cheek and placing same in the stream of commerce, Defendant took an affirmative action to ensure that the Check, ‘would be dishonored upon presentment. Pursuant to 810 ILCS 5/3-301, ev seg. (West 2017). Currency Exchange is a holder in due course entitled to enforce the Cheek against Defendant. Additionally. pursuant 10 720 ICS 5/17-1(8) (West 2017), Currency Exchange is entitled to a judgment against Defendant for an amount “in addition to the amount owing upon such check or order. damages of treble the amount so owing, but in no case lessthan $100 nor more than $1.500, plus attorneys’ fe, court costs”. 720 ILC 18) (West 2017). Despite demand, Defendant has failed and refused to pay the balance due to Curreney Exchange as identified in Currency Exchange's demand letter, (See Ex. “B"). Defendant has reimbursed Currency Exchange none of the $157.12 due. Curreney Exchange has performed all conditions to be perlormed by it, Curreney Exchange has sufered damages as a direct and proximate result of the actions or inaetions of Defendant WHEREFORE. Plaintif?. SPEEDY CHECK CASHERS, INC., an Illinois corporation, respectilly requests this Court to enter Judgment in its favor and against Defendant. ‘THE =2j< SESS A gaze geen E85! Ego ZF B, c dD. BOEING COMPANY. a Delaware corporation, as follows: Awarding Currency Exchange damages in the sum of $157.12. less amounts previously paid to it by Defendant: Treble damages as to the Check, in the total sum of $396.36. as provided by 720 1LCS SAT-ME): Interest as permitted pursuant to 810 ILCS 5/3-806: Atiomeys’ fees in the sum of at least $350.00 as permitted pursuant to 720 LCS 5/17- 1) and 810 ILCS 5/3-806: All reasonable and necessary costs incurred in connection with these proceedings. as permitied pursuant (0 720 ILCS 5/17-1 and 810 ILCS 5/3-806: and,ECTRONICALLY F 12/20/2017 9:45 AM 2017-M1-135441 PAGE 4 of 10 F, For a judgment against Defendant in the sum of $903.48. plus costs. and for such other, further and different reliet as this Court deems just and proper Respectfully submitted. PEEDY CHECK CASHPRS. INC.. an Hlinois corporation, Plaintiff, Paid J Frankel, Ey Kadhleon M. Hagens. Ey rian D. Neve. Es. Sorman & Frankel. Ltd 180 North LaSalle Siret, Suite 2700 Chicazo, Minois sdk S12)832-3835 31298323845 ctacsimiley pleadings sormanteankel com Firm thi 38341ELECTRONICALLY 12/20/2017 9:45 AM ‘2017-MI-135441 PAGE 5 of 10 ve n by. tific Under penalties as provided by law pursuunt 10 Scction 1-109 of the Code of Civil Procedure, the undersigned certifies that they are a duly authorized representative of Plaintilt and that the statements set forth in this Verified Complaint are true and correct, except as 10 matlers therein stated to be on information and belie’ and as to such matters the undersigned certifies as aforesaid that they verily believes the same to be true Steven’Schoenberg,(BATE onavaoTT me BEEING HORT UFCW ETRE MENT FUR GERNOT Ter pay ONE HUNDRED THIRTY-TWO DOLLARS 12 CENTS: wore JWPRYOR OnOuN OF E350 GRUNT CIA APT D112 ERMILLVIILE In 48410 “Auer 5 greet ‘NOT WALD AFTER 38D DAYE QegenNe accouro [STATE STMEEY HOSTOM MASEACHJDETTS €2101 f f *250RLb2N7e Return 1D: EEO eposit 10: Original Scan Date: 08/15/17 10:21 Return Date: 08/18/17 06:00 Return Reason: Refer to Maker 1 ro if in B SSG GAGES He Ht u ae i 3SPEEDY CHECK CASHERS, INC. HAMMOND, GRIFFITH, EAST CHICAGO, GARY, LAKE STATION, MERRILLVILLE*, MICHIGAN CITY 425 HUBHL ROAD, BUILDING 3 Noise 00k, 60062 847-509-6620 Fax 847-509-6593 Email BSchoenberga cfe.com ‘September 11, 2017 Via Certified Mail ~ Return Receipt Requested and U.S. Mail Boeing North American Retirement Fund P.O. Box 3707 Seattle, WA 98124 Attn: Finance Department ~ Accounts Payable Re: Creditor: ‘Speedy Check Cashers, Inc., 71 W. Lincoln Highway, Merrillville, IN Amount claimed: $152.12 + $25.00 fee ($157.12), Check No, 250111247 Date of issuance: 7/1/17 Payee: J. W. Pryor Dear Sir or Madam: Tam writing this lever in regards to Speedy Check Cashers. Inc.’s claims against your company based upon your ‘company’s issuance of the check identified above. That check was cashed by Speedy Check Cashers, Ine. and was returned unpaid due to “refer to maker.” ursuant to IC 26-1-3.1-502.5, as well 5 IC 35-83-5-5, you are put on notice that in the event you fail to remit the face In of the above-described check made payable to the Speedy Check Cashers, Inc. and mailed to the Northbrook 5 shown at the top of this letterhead, along with the “returned check fee” of $25.00 identified above, within thirty $50) leys following this demand, Speedy Check Cashers may file legal action against you and may be awarded by a court impetent jurisdiction the face amount of the check(s), attomeys” fees, court costs incurred and service fees and gibi in triple the amount of each check (in no case less than $100.00 nor more than $1,500.00 per check) and non- iFvation collection expenses. Unless you, the recipient of this notice, within thirty (30) days after receipt, dispute the validity of this debt or any portion thereof, the debt will be assumed to be valid. If you notify the undersigned, in writing within the thirty (30) day period that the debt, or any portion thereof is disputed, the undersigned will obtain verification of the debt or a copy of @ Judgment against you and a copy of such verification or judgment will be maifed to you. Upon written request, within the thirty (30) day period described above, the undersigned will provide you with the name and address of the original itor if different from the Currency Exchange. Absent hearing from you within thirty (30) days after the receipt of this notice, the debt set forth herein will be assumed (o be valid by the Currency Exchange and its lawyers unless you dispute, in writing, the validity of same within the given time period. Nothing requires or obligates the Currency Exchange to wait thirty (30) days from the date of issuance of this letter to commence legal proceedings against you to collect the debt. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. If you have any questions or wish to discuss this matter further, please contact Eric Page at (847) 509-6655. a Boamte J. Schoenberg, General Counsel "In the event the item was returned unpaid due to “duplicate presentment.” contact your financial institution immediately to preserve ‘your warranty and indemnification rights under the Check 21 Act, 12 U.S.C. §§5001 et seq., and Reg. CC, 12 C.F.R. §§229.52, 29.53,Print Label Page | of I Bonnie Schoenberg. Antomey aL av es poraaearee 425 HUEHURO BLDG 2 RST-CLASS. NORTHEROOK I 60082-2523 Sra ‘USPS CERTIFIED MAIL It | iil ll 7 9414 8102 0088 2512 5770 97 ‘Basing North American Retrorsent Fund ‘xin Fmance Deparment Accounts Payable 0 Box a707 SEATTLE WA.98124.2207 ont gy — eee FOLD ALONG THIS LINE ED So By z Z /www.certifiedmaillabels.convprint-label/ 9/11/2017ELECTRONICALLY FILED 2017-M1-135441 12/202017 9:45 AM Certified Mail Tracking Summary Report (Current Year) ~ Certified Mail Labels Page tof 3 Certified Mail Labels. Pant USPS Certified Mail, Priority Mail and Express Mail Labels with PC Postage SHOPPING CART Home Address Letters Reports Management Help Log out Hetio, Eric Balance: $167.14 User # 48615, Certified Mail Tracking Summary Report (Current Year) Q search Agan PAGE 9 of 10, Update & Create Report a Te annie Schoenberg -Atomey atLaw wreemewrecieas SoomueHL ROADS 3 Frscuass. NORIMAROORT. €0062.2525, aa USPS CERTIFIED MAIL Pita: 19414 3102 0088 2542 5770 97 ‘oong Nar Arercan Reirenent Fund ‘antics Bepartnort AcontsPyoba POBox sro? SEATILEWA 91267207 Tue tg eg A hl neterence) Sp. 8 vs. Boeing North American Retirement Fund, JW. Pryor 7 hups://www certifiedmaillabels.com/certified-mail-tracking-summary-repor/appSession=.... 9/20/2017Certified Mail Tracking Summary Report (Current Year) — Certified Mail Labels Page 2 of 3 uses # USPS Mail Class USPS Status USPS History Date Date Verified 2017-M1-135441 PAGE 10 of 10 Electronic Delivery Confirmation ELECTRONICALLY FILED 12/202017 9:45 AM Return Receipt (Gignature) Tranid ToName ToCompanyName Ad Ade? city st 2uP hitps://www.certifiedmaillabels.com/certified-mail-tracking-summary-report/2appSession- 94148 10200862512577037 Cartied with Return Receipt (Signature) ‘Your item was delivered at 12.22 pm on September 19, 2017 m SEATTLE, WA 98124 ‘Avaliable for Pickup, Seplember 18, 2017, 920 am, SEATTLE, WA 98124 Artved at Unit, Sopternber 18, 2017, 9.07 am, SEATTLE, WA 98134 Distrbuton lo PO Box in Progress, Saptombor 18, 2017, 8.48 am, SEATTLE, WA 98124 Sorting Complete, September 18, 2017, 8:38 am, SEATTLE, WA 96124 {In Transit to Destination, September 17, 2017, 9:33 arn, On its way fo IP Code 98124 ‘Departed USPS Regional Destination Facity, September 16,2017, 10:33 pm, ‘SEATTLE WA DISTRIBUTION CENTER. In Transit o Destination, September 16, 2017, 9:34 am, On its way to ZIP Code 98124 ‘Anved at USPS Regional Destination Faciity, September 15, 2017. 10:23 am, [SEATTLE WA DISTRIBUTION CENTER, In Transit lo Destination, September 15, 2017. 9:37 am, On its way fo ZIP Code 98124 Departed USPS Regional Facity, September 14, 2017, 437 am, CAROL STREAM IL, DISTRIBUTION CENTER ‘Arived at USPS Regional Origin Facility, September 13, 2017. 10°02 pm, CAROL ‘STREAM IL DISTRIBUTION CENTER Accepted al USPS Origin Facility, September 13, 2017, 8:47 pm, NORTHBROOK, IL 60062 ‘Shipping Label Created. USPS Awaiting item, September 11, 2017, 2:18 pm, NORTHBROOK, IL 60062 snareo17 9207017 s006sa6 detail 42615 ve 40615, [Atin Finance Department - Accounts Payable ‘Boeing North American Retirement Fund .0. Box 3707 Seattle wa ere. 9/20/2017