It fully written out:
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
JOSEPH PHELAN, JUAN FINCH, JR.; and
RYAN PHELAN, INVIDUALLY AND
DERIVATIVELY ON BEHALF OF UNION
CITY HOLDING, LLC and UNION CITY
PRODUCTIONS, LLC,
Plaintiffs,
vs.
NUMED PARTNERS, LLC; NUMED
MANAGERS INCORPORATED; NUERA
NEW BUFFALO, LLC; NUMED
PARTNERS MICHIGAN, LLC; NE MI,
LLC; NUERA EAST PEORIA, LLC;
NUERA PEKIN, LLC; NUERA URBANA,
LLC; NUERA AURORA, LLC; NUERA
CHICAGO, LLC; NUERA ACQUISTIONS,
LLC; IESO, LLC; TB NUERA JV LLC;
ROBERT V. FITZSIMMONS; ROBERT
FITZSIMMONS, JR.; SHEILA
FITZSIMMONS; PATRICK BRADY;
LAURA JARAMILLO BERNAL; PATRICK
COATS; DIVINA CAPELLUPO; THOMAS
VANCE; ANDY DAMICO and KENNETH
SLEPICKA.
Defendants.
Case No.:
PLAINTIFFS DEMAND A TRIAL
BY JURY
COMPLAINT AT LAW
JOSEPH PHELAN, JUAN FINCH, JR.; and RYAN PHELAN, INVIDUALLY AND
DERIVATIVELY ON BEHALF OF UNION CITY HOLDING, LLC and UNION CITY
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PRODUCTIONS, LLC, by and through their attorneys, Morrisroe & Associates, Ltd., and
for their Complaint, complaining of the Defendants, NUMED PARTNERS, LLC; NUMED
MANAGERS INCORPORATED; NUERA NEW BUFFALO, LLC; NUMED PARTNERS
MICHIGAN, LLC; NE MI, LLC; NUERA EAST PEORIA, LLC; NUERA PEKIN, LLC;
NUERA URBANA, LLC; NUERA AURORA, LLC; NUERA CHICAGO, LLC; NUERA
ACQUISTIONS, LLC; IESO, LLC; TB NUERA JV, LLC; ROBERT V. FITZSIMMONS;
ROBERT FITZSIMMONS, JR.; SHEILA FITZSIMMONS; PATRICK BRADY; LAURA
JARAMILLO BERNAL; PATRICK COATS; DIVINA CAPELLUPO; THOMAS VANCE;
ANDY DAMICO and KENNETH SLEPICKA, and pleading hypothetically and in the
alternative, states as follows:
PARTIES
1. Plaintiff, JOSEPH PHELAN, (hereinafter sometimes referred to as “JP”) is an
individual residing in Chicago, County of Cook, and State of Illinois.
2. Plaintiff, JUAN FINCH, JR, (hereinafter sometimes referred to as “JF” or
“Juan”) is an individual residing in Florida. JF is an African American, permanently
disabled Navy veteran.
3. Plaintiff, RYAN PHELAN, (hereinafter sometimes referred to as “RP”) is an
individual residing in Chicago, Cook County, Illinois. RP owns thirty-three and one-third
(33 1⁄2) of the issued and outstanding membership interests in UC Holding and UC
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Production.
4. Plaintiff, UNION CITY HOLDING, LLC, (hereinafter sometimes referred to
as “UC Holding”) is a Michigan limited liability company.
5. Plaintiff, UNION CITY PRODUCTION, LLC, (hereinafter sometimes
referred to as “UC Production”) is a Michigan limited liability company.
6. Defendant NUMED PARTNERS, LLC (hereinafter sometimes referred to as
“NMP”) and, upon information and belief, is an Illinois limited liability company.
7. Defendant NUMED MANAGERS, INCORPORATED (hereinafter
sometimes referred to as “NMM”) and, upon information and belief, is an Illinois
corporation.
8. Defendant NUERA NEW BUFFALO, LLC (hereinafter sometimes referred
to as “NEB”) and, upon information and belief, is a Michigan limited liability company.
9. Defendant NUMED PARTNERS MICHIGAN, LLC (hereinafter sometimes
referred to as “NMPM”) and, upon information and belief, is an Illinois limited liability
company.
10. Defendant NE MI, LLC (hereinafter sometimes referred to a “NEMI”) and ,
upon information and belief, is a Michigan limited liability company.
11. Defendant NUERA EAST PEORIA, LLC (hereinafter sometimes referred to
as “NEEP”) and, upon information and belief, is an Illinois limited liability company.
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12. Defendant NUERA PEKIN, LLC (hereinafter sometimes referred to as
“NEPEKIN”) and, upon information and belief, is an Illinois limited liability company.
13. Defendant NUERA URBANA, LLC (hereinafter sometimes referred to as
“NEU”) and, upon information and belief, is an Illinois limited liability company.
14. Defendant NUERA AURORA, LLC (hereinafter sometimes referred to as
“NEA”) and, upon information and belief, is an Illinois limited liability company.
15. Defendant NUERA CHICAGO, LLC (hereinafter sometimes referred to as
“NEC”) and, upon information and belief, is an Illinois limited liability company.
16. Defendant NUERA ACQUSIITIONS, INC. (hereinafter sometimes referred
to as “NEAI”) and, upon information and belief, is an Illinois limited liability company.
17. Defendant IESO, LLC (hereinafter sometimes referred to as “IESO”) and,
upon information and belief, is an Illinois limited liability company.
18. Defendant TB NUERA JV LLC (hereinafter sometimes referred to as “TB”)
and, upon information and belief, is an Illinois limited liability company.
19. Defendant ROBERT V. FITZSIMMONS (hereinafter sometimes referred to as
“Fitzsimmons”), is an individual and, upon information and belief, a resident of the State
of Illinois.
20. Fitzsimmons is the CEO of NMP.
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21. Defendant ROBERT V. FITZSIMMONS, JR. (hereinafter sometimes referred
to as “Robb”), is an individual and, upon information and belief, a resident of the State of
Illinois.
22. Defendant SHELIA FITZSIMMONS (hereinafter sometimes referred to as
“Sheila”), is an individual and, upon information and belief, a resident of the State of
Illinois.
23. Defendant LAURA JARAMILLO BERNAL (hereinafter sometimes referred
to as “Bernal”), is an individual and, upon information and belief, a resident of the State of
Illinois.
24. Defendant PATRICK COATS (hereinafter sometimes referred to as “Coats),
is an individual and, upon information and belief, a resident of the State of Utah.
25. Defendant DIVINA CAPELLUPO (hereinafter sometimes referred to as
“Capellupo”), is an individual and, upon information and belief, a resident of the State of
Illinois.
26. Defendant THOMAS VANCE (hereinafter sometimes referred to as
“Vance”), is an individual and, upon information and belief, a resident of the State of
Illinois.
27. Defendant ANDY DAMICO (hereinafter sometimes referred to as
“Damico”), is an individual and, upon information and belief, a resident of the State of
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California.
28. Defendant KENNETH SLEPICKA (hereinafter sometimes referred to as
“Slepicka”), is an individual and, upon information and belief, a resident of the State of
Illinois.
VENUE
29. Venue is proper in this Court pursuant to Section 2-101 of the Illinois Code
of Civil Procedure because several the individual defendants resides in this county,
because defendants NuMed and NuEra are located in this county and transacts business
in this county, and because the events giving rise to the claims in this action occurred in
this county.
FACTS COMMON TO ALL COUNTS
30. The Defendants are collectively engaged in the recreational marijuana
business in both Illinois and Michigan.
31. The recreational marijuana business is comprised of three primary business
segments: the grow facility, the processing facility and the retail establishments where the
processed marijuana products are sold.
32. Union City Holdings, LLC is a licensed marijuana grow facility located in
Union City, Michigan.
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33. Ryan Phelan and Fitzsimmons are the sole members of Union City Holdings.
Ryan Phelan has a 33.33% membership interest and Fitzsimmons has a 66.66% membership
interest.
34. Union City Holding was formed in the State of Michigan on July 25, 2019,
and the members entered into an Amended and Restated Operating Agreement governing
the operations of the limited liability company on December 18, 2020. A true and correct
copy of the Amended and Restated Operating Agreement is attached hereto as Exhibit No.
1.
35. Union City Productions is a licensed marijuana processing facility located in
Union City, Michigan.
36. Ryan Phelan and Fitzsimmons are the sole members of Union City
Productions. Ryan Phelan has a 33.33% membership interest and Fitzsimmons has a
66.66% membership interest.
37. Union City Productions was formed in the State of Michigan on July 25, 2019,
and the members entered into an Amended and Restated Operating Agreement governing
the operations of the limited liability company on December 18, 2020. A true and correct
copy of the Amended and Restated Operating Agreement is attached hereto as Exhibit No.
2.
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38. Further, in October 2019, Union City Holdings, Union City Productions and
NuMed Partners Michigan entered into a Letter of Intent which included exclusivity
provisions requiring that future transactions be referred to NPM. A true and correct copy
of the Letter of Intent is attached hereto as Exhibit No. 3.
39. Ryan Phelan, Fitzsimmons and Sheila are each licensed by the State of
Michigan to operate Union City Holding and Union City Productions and remain subject
to the strict licensing requirements and rules promulgated by the State of Michigan as the
Medical Marihuana Licensing Facilities Act, 2106 PA 281.
40. Upon information and belief, each of the individual defendants has an
ownership interest in the various NuMed or NuEra entities.
COUNT I
BREACH OF CONTRACT (UNION CITY HOLDING)
41-81. Plaintiff RYAN PHELAN adopts and realleges the allegations of paragraphs
1 through 40 of Complaint as though fully set forth herein as its paragraphs 41 through 81
of this Count I.
81. Fitzsimmons is the Manager of Union City Productions as such manager has
control of the financial books, records and accounts of Union City Productions, including
tax returns.
82. Since 2019 through the date of this filing, Fitzsimmons has failed and refused
to provide Ryan with financial records regarding the operation of Union City Holding,
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including the failure to provide copies of the corporate tax returns and any associated K-1
statements.
83. Since 2019 through the date of this filing, Ryan has demanded the
aforementioned financial records.
84. Fitzsimmons is the Manager of Union City Productions as such manager has
control of the financial books, records and accounts of Union City Productions, including
tax returns.
85. Since 2019 through the date of this filing, Fitzsimmons has failed and refused
to provide Ryan with financial records regarding the operation of Union City Holding,
including the failure to provide copies of the corporate tax returns and any associated K-1
statements.
86. Since 2019 through the date of this filing, Ryan has demanded the
aforementioned financial records.
87. Upon information and belief, Fitzsimmons has diverted profits or losses from
the business operations of Union City Holding for his personal benefit to the detriment of
Ryan.
88. In 2023, Fitzsimmons hired Andy Damico without Ryan’s consent and over
his specific objection.
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89. In 2023, Fitzsimmons transferred over $1,000,000 in product belonging to
Union City Productions without Ryan’s consent. Said actions were to the detriment of both
Ryan and the Union City entities.
WHEREFORE, Plaintiff RYAN PHELAN prays for Judgment against Defendant
ROBERT V. FITZSIMMONS in an amount in excess of $100,000.00, or such amount to be
proven at trial, plus prejudgment interest and costs of this suit.
COUNT II
COMMON LAW FRAUD (UNION CITY PRODUCTIONS)
90-179. Plaintiff RYAN PHELAN adopts and realleges the allegations of
paragraphs 1 through 89 of Count I as though fully set forth herein as its paragraphs90
through 179 of this Count II.
180. Upon information and belief, Defendant Fitzsimmons has diverted profits or
losses due to Ryan for his own personal benefit.
181 Upon information and belief, Defendant Fitzsimmons has made both state
and federal tax filings which do not properly reflect Ryan’s ownership interest in Union
City Productions.
182 Upon information and belief, Defendant Fitzsimmons has filed reports with
the State of Michigan which do not properly reflect Ryan’s ownership interest in Union
City Holding and Union City Productions.
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183. In 2023, Fitzsimmons hired Andy Damico without Ryan’s consent and over
his specific objection.
184. In 2023, Fitzsimmons transferred over $1,000,000 in product belonging to
Union City Productions without Ryan’s consent. Said actions were to the detriment of both
Ryan and the Union City entities.
WHEREFORE, Plaintiff RYAN PHELAN prays for Judgment against Defendant
ROBERT V. FITZSIMMONS in an amount in excess of $100,000.00, or such amount to be
proven at trial, plus prejudgment interest and costs of this suit.
COUNT III
DERIVATIVE CLAIMS (UNION CITY HOLDING)
185-225. Plaintiff RYAN PHELAN ON BEHALF OF UNION CITY
HOLDING adopts and realleges the allegations of paragraphs 41 through 81 of Count I of
the Complaint as though fully set forth herein as its paragraphs 185 through 225 of this
Count III.
226. Fitzsimmons is the Manager of Union City Productions and as such manager
has control of the financial books, records and accounts of Union City Productions,
including tax returns.
227 . Since 2019 through the date of this filing, Fitzsimmons has failed and refused
to provide Ryan with financial records regarding the operation of Union City Holding,
including the failure to provide copies of the corporate tax returns and any associated K-1
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statements.
228. Since 2019 through the date of this filing, Ryan has demanded the
aforementioned financial records.
229. Fitzsimmons is the Manager of Union City Productions and as such manager
has control of the financial books, records and accounts of Union City Productions,
including tax returns.
230. Since 2019 through the date of this filing, Fitzsimmons has failed and refused
to provide Ryan with financial records regarding the operation of Union City Holding,
including the failure to provide copies of the corporate tax returns and any associated K-1
statements.
231. Since 2019 through the date of this filing, Ryan has demanded the
aforementioned financial records.
232. Upon information and belief, Fitzsimmons has diverted profits or losses from
the business operations of Union City Holding and Union City Productions for his personal
benefit to the detriment of Union City Holding.
233. In 2023, Fitzsimmons hired Andy Damico without Ryan’s consent and over
his specific objection.
234. In 2023, Fitzsimmons transferred over $1,000,000 in product belonging to
Union City Productions without Ryan’s consent. Said actions were to the detriment of both
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Ryan and the Union City entities.
WHEREFORE, Plaintiff RYAN PHELAN ON BEHALF OF UNION CITY
HOLDING for Judgment against Defendant ROBERT V. FITZSIMMONS in an amount
in excess of $100,000.00, or such amount to be proven at trial, plus prejudgment interest
and costs of this suit.
COUNT IV
DERIVATIVE CLAIMS (UNION CITY PRODUCTIONS)
235-275. Plaintiff RYAN PHELAN ON BEHALF OF UNION CITY
PRODUCTIONS adopts and realleges the allegations of paragraphs 41 through 81 of
Count I of the Complaint as though fully set forth herein as its paragraphs 235 through 275
of this Count IV.
276. Upon information and belief, Defendant Fitzsimmons has diverted profits or
losses due to Ryan for his own personal benefit.
277 Upon information and belief, Defendant Fitzsimmons has made both state
and federal tax filings which do not properly reflect Ryan’s ownership interest in Union
City Holding and Union City Productions.
278 Upon information and belief, Defendant Fitzsimmons has filed reports with
the State of Michigan which do not properly reflect Ryan’s ownership interest in Union
City Holding and Union City Productions.
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279. Upon information and belief, Fitzsimmons has diverted profits or losses from
the business operations of Union City Holding and Union City Productions for his personal
benefit to the detriment of Union City Productions.
280. In 2023, Fitzsimmons hired Andy Damico without Ryan’s consent and over
his specific objection.
281. In 2023, Fitzsimmons transferred over $1,000,000 in product belonging to
Union City Productions without Ryan’s consent. Said actions were to the detriment of both
Ryan and the Union City entities.
WHEREFORE, Plaintiff RYAN PHELAN ON BEHALF OF UNION CITY
PRODUCTIONS prays for Judgment against Defendant ROBERT V. FITZSIMMONS in
an amount in excess of $100,000.00, or such amount to be proven at trial, plus prejudgment
interest and costs of this suit.
COUNT V
BREACH OF CONTRACT - THE IESO TRANSACTION
282-322. Plaintiff JOSEPH PHELAN adopts and realleges the allegations of
paragraphs 1 through 40 of the Complaint as though fully set forth herein as its paragraphs
282 through 322 of this Count V.
323. As part of Joseph Phelan’s business agreement with Fitzsimmons and the
NuMed and NuEra entities, he was to locate and secure other medical and recreational
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marijuana businesses entities for the entities and, in exchange for which, he would retain a
one-third ownership interest.
324. On March 7, 2023, Joseph secured a verbal agreement to negotiate to acquire
IESO LLC from a broker in Niles, Michigan. Based upon his agreements with Fitzsimmons
and the NuMed and NuEra entities, Joseph advised Fitzsimmons of the opportunity and
Fitzsimmons indicated he wanted to pursue it for NuMed and/or NuEra upon the same
terms as their prior transactions with Joseph to retain a one-third ownership interest in the
business.
325 Fitzsimmons then negotiated for the acquisition for IESO and NuEra began
operating the IESO facilities pursuant to a management agreement, pending formal
approval by the State of Illinois and the closing.
326. On March 7, 2022, Robb texted Joseph inquiring as to how Joseph learned of
the opportunity and instructing Joseph not to discuss the transaction with the broker as
NuEra wanted to avoid paying any broker fees.
327. In March 2023, Coats called Joseph and informed him that Robb was going
to try and screw Joseph over and to confirm his deal with Fitzsimmons as Robb and the
other shareholders did not want Joseph to retain the equity position in IESO.
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328. On March 16, 2023, Joseph and Fitzsimmons met at the offices of American
Community Bank in Chicago, Illinois to discuss the IESO transaction as well as the other
businesses. Two independent witnesses also attended this meeting.
329. During the meeting Fitzsimmons said the cost of Joseph retaining the agreed
one-third ownership in IESO was too costly and wanted to reach an alternative
arrangement with Joseph. Fitzsimmons offered that in exchange for waiving the
ownership interest in IESO, Phelan would receive a three (3%) percent ownership interests
in all of the NuMed / NuEra entities and a salary of $500,000 per year. The Phelans would
retain their current ownership interest in Union City Holding and Union City Productions
and Joseph would continue to seek new business opportunities for the NuMed / NuEra
businesses.
330. Joseph agreed to the terms offered by Fitzsimmons and Fitzsimmons stated
that Brady, who also serves as NuMed / NuEra’s counsel) would prepare the contracts.
Phelan confirmed his agreement later that same day in a text message to Fitzsimmons.
331. On May 11, 2023, Fitzsimmons sent an article to Joeseph regarding the IESO
transaction and was reminded by Joseph to send the contract documents.
332. In the intervening months, Joseph and his counsel have repeatedly reached
out to NuMed / NuEra to finalize the contracts. Absent anything to the contrary, Joseph
would own one-third of the IESO transaction.
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333. IESO is believed to be a transaction in the range of $45,000,000.
334. After the March 2023 meeting, Joseph learned that Robb and the other
shareholders were objecting to his ownership and compensation agreement and were in a
dispute with Fitzsimmons regarding those issues. Fitzsimmons had full power and
authority to enter into such agreements with Joseph.
335. By virtue of the agreements reached with Fitzsimmons in March of 2023,
Joseph and/or the Phelan Plaintiffs have a three (3%) percent non-dilutable equity
ownership interest in each of the NuMed and NuEra defendants, including IESO and TB
NUERA JV, LLC.
WHEREFORE, Plaintiff JOSEPH PHELAN prays for Judgment against Defendants,
NUMED PARTNERS, LLC; NUMED MANAGERS INCORPORATED; NUERA NEW
BUFFALO, LLC; NUMED PARTNERS MICHIGAN, LLC; NE MI, LLC; NUERA EAST
PEORIA, LLC; NUERA PEKIN, LLC; NUERA URBANA, LLC; NUERA AURORA, LLC;
NUERA CHICAGO, LLC; NUERA ACQUISTIONS, LLC; IESO, LLC; ROBERT V.
FITZSIMMONS; ROBERT FITZSIMMONS, JR.; SHEILA FITZSIMMONS; PATRICK
BRADY; LAURA JARAMILLO BERNAL; PATRICK COATS; DIVINA CAPELLUPO;
THOMAS VANCE; ANDY DAMICO and KENNETH SLEPICKA, in an amount in excess
of $100,000.00, or such amount to be proven at trial, plus prejudgment interest and costs of
this suit.
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COUNT VI
CIVIL CONSPIRACY TO COMMIT FRAUD - THE IESO TRANSACTION
336-387. Plaintiff JOSEPH PHELAN adopts and realleges the allegations of
paragraphs 282 through 335 of Count V of the Complaint as though fully set forth herein
as its paragraphs 336 through 387 of this Count VI.
387. Pursuant to an agreement between t h e Defendants, and through
their concerted actions, a scheme, in breach of contractual, state-law and federal-law
obligations, was perpetrated to defraud the Phelan Plaintiffs and obtain monetary and
other benefits.
388. In furtherance of the conspiracy, and in an effort to obtain significant
monetary and other benefits, Defendants misrepresented and concealed their intentions
regarding honoring their agreements with the Phelan Plaintiffs, failed to report to the
State of Illinois the ownership interests of the Phelan Plaintiff in the IESO transaction; and
acted in a scheme to deprive the business broker of compensation due.
389. As co-conspirators in the scheme, Defendants are jointly and severally
liable for any and all damages the Phelan Plaintiffs incurred as a result.
390. As a direct and proximate result of Defendants' conduct and
malfeasance, the Phelan Plaintiffs suffered damages.
391. As a direct and proximate result of Defendants' conduct, the Phelan
Plaintiffs have suffered injury for which compensation is sought in the form of monetary
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damages, in the amount that will be established at trial by jury.
WHEREFORE, Plaintiff JOSEPH PHELAN prays for Judgment against Defendants,
NUMED PARTNERS, LLC; NUMED MANAGERS INCORPORATED; NUERA NEW
BUFFALO, LLC; NUMED PARTNERS MICHIGAN, LLC; NUERA EAST PEORIA, LLC;
NUERA PEKIN, LLC; NUERA URBANA, LLC; NE MI, LLC; NUERA AURORA, LLC;
NUERA CHICAGO, LLC; NUERA ACQUISTIONS, LLC; IESO, LLC; ROBERT V.
FITZSIMMONS; ROBERT FITZSIMMONS, JR.; SHEILA FITZSIMMONS; PATRICK
BRADY; LAURA JARAMILLO BERNAL; PATRICK COATS; DIVINA CAPELLUPO;
THOMAS VANCE; ANDY DAMICO and KENNETH SLEPICKA, in an amount in excess
of $100,000.00, or such amount to be proven at trial, plus prejudgment interest and costs of
this suit.
COUNT VII
CIVIL CONSPIRACY TO COMMIT FRAUD – THE FINCH, JR. V. TRETO, JR. LITIGATION
392-432. Plaintiff JUAN FINCH, JR. adopts and realleges the allegations of
paragraphs 1 through 39 of the Complaint as though fully set forth herein as its paragraphs
383 through 422 of this Count VII.
433. Juan is an employee of NuEra Michigan. Juan further met with and was
interviewed by Laura with respect to owning and operating a dispensary in Illinois under
the NuEra brand.
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434. Juan wanted to apply for a Conditional Adult Use Dispensing Organization
License pursuant to the Illinois Cannabis Regulation and Tax Act.
435. The Illinois Department of Financial and Professional Regulation barred Juan
from participating, primarily due to his residency status advising there would be no point
to apply.
436. At or about this same time, Fitzsimmons and the NuEra entities devised a
scheme to limit the number of new licensees and therefore the competition to their existing
business operations.
437. Fitzsimmons contacted Joseph seeking a social equity applicant who had
denied a Conditional Adult Use Dispensing Organization License and referenced Juan.
438. Fitzsimmons proposed a scheme whereby NuEra would make Juan the lead
plaintiff in a lawsuit against The Illinois Department of Financial and Professional
Regulation in order to enjoin the Department from issuing 185 conditional licenses to new
licensees.
439. Fitzsimmons and NuEra formed a SPAC or “blank check” company to
secretly underwrite the litigation expenses actually incurred in the litigation.
440. Fitzsimmons and NuEra selected legal counsel for Juan and directed all
aspects of the litigation either personally or via their SPAC.
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441. Based on the actions of Fitzsimmons and NuEra, Juan filed a Complaint for
Injunctive and Declaratory Relief against Mario Treto, Jr., in his official capacity, that
lawsuit is presently on appeal.
442,. Fitzsimmons and NuEra agreed that they would provide Juan with a
dispensary license and facility in exchange for acting as the lead plaintiff.
443. Fitzsimmons and NuEra used Juan as a “schill” in order to advance their
improper business agenda against the State of Illinois seeking to limit and chill the
competition against them. The practical effect of the litigation was that the value of other
licenses decreased enabling defendants to profit on the market.
435. After each substantive court event, Fitzsimmons and/or Robb debriefed Juan
to advise him of the next steps in the litigation using Joseph’s phone as a cut-off to attempt
to avoid direct contact with Juan.
445. Juan and the citizens of the State of Illinois sustained damages as a result of
defendants’ actions.
WHEREFORE, Plaintiff JUAN FINCH, JR. prays for Judgment against Defendants,
NUMED PARTNERS, LLC; NUMED MANAGERS INCORPORATED; NUERA NEW
BUFFALO, LLC; NUMED PARTNERS MICHIGAN, LLC; NE MI, LLC; NUERA EAST
PEORIA, LLC; NUERA PEKIN, LLC; NUERA URBANA, LLC; NUERA AURORA, LLC;
NUERA CHICAGO, LLC; NUERA ACQUISTIONS, LLC; IESO, LLC; ROBERT V.
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FITZSIMMONS; ROBERT FITZSIMMONS, JR.; SHEILA FITZSIMMONS; PATRICK
BRADY; LAURA JARAMILLO BERNAL; PATRICK COATS; DIVINA CAPELLUPO;
THOMAS VANCE; ANDY DAMICO and KENNETH SLEPICKA, in an amount in excess
of $100,000.00, or such amount to be proven at trial, plus prejudgment interest and costs of
this suit.
Respectfully Submitted,
JOSEPH PHELAN, JUAN FINCH, JR.; and
RYAN PHELAN, INVIDUALLY AND
DERIVATIVELY ON BEHALF OF UNION
CITY HOLDING, LLC and UNION CITY
PRODUCTIONS, LLC,
By: /s/ Michael J. Morrisroe __________________
One of Their attorneys