IN THE CIRCUIT COURT OF THE NTH JUDICIAL CIRCUIT, Personnel Staffing Grouo. LLC. et al. VS. Rosa Ceia. an individual LAKE COUNTY, lLLIi?-pls i it. 4 2015 General No.1 5 3 CERTIFICATE OF ATTORNEY CIVIL DIVISION 1) Pursuant to Local Rule 301(0), I hereby certify that: [El There has been no previous Voluntary or involuntary Dismissal of the subject matter of this litigation. There has been a previous Voluntary or involuntary Dismissal of the subject matter of this litigation and at the time of dismissal that Case No. was assigned to the Honorable 2) Are you seeking any injunctive relief? CIRCUIT CLERK IE There is no other litigation presently pending in the county involving these parties. There is other litigation presently pending in the county involving the parties to or subject matter to this lawsuit and that case(s) is/are assigned Case No.(s) which isfare assigned to the Honorable Yes Select the appropriate case subtype under the Chancery-CH heading below. IEI No - Select the appropriate non-Chancery case subtype below. This data is being gathered for administrative purposes and will not be used for any other purpose. Arbitration - AR ArbitrationiTort Arbitration/Contract Chancery - CH Residential Mortgage Foreclosure Residential Mortgage Foreclosure w/Mechanios Lien El Non?Residentiai Mortgage Foreclosure El Injunction El Specific Performance Mechanics Lien Foreclosure El Complaint for Rescission El Partition El Quiet Title Class Action Miscellaneous Eminent Domain ED Eminent Domain El Condemnation Law Magistrate LM Forcibie Entry and Detainer Replevin Detinue Distress for Rent Enroll Judgment El Confirm Arbitrator's Award Confession of Judgment Law Tort CI Contract El Product Liability El Medical Malpractice Legal Malpractice Forcible Entry and Detainer CI Replevin Accounting Malpractice Enroll Judgment Confirm Arbitrator?s Award Municipal Corporation MC Annexation Disconnection Miscellaneous Remedy? MR Declaratory Judgment Corporation Dissolution Election Contest Mandamus El Habeas Corpus Review of Administrative Proceeding/Statutory Review of Administrative Proceeding/Certiorari I: Quo Warranto Change of Name Forfeiture Fugitive from Justice Search Warrant [3 Application for Eavesdropping Device Registration of Foreign Judgment El Request for Subpoena! Foreign Jurisdiction El Miscellaneous Print Name Britney L. Zilz Signature 0E @0930 Probate DecedenUTestate $15,000 Decedentilntestate $15,000 DecedentiTestate $15,000 or less Decedentilntestate $15,000 or less Guardianship of Person! Disabled Person I:l Guardianship of Estate! Disabled Person I:l Guardianship of a Person and EstateiDisabied Person Guardianship of Person! Minor El Guardianship oi EstateiMinor El Guardianship of Person and EstateiMinor Proof of Heirship Alone lax?_TX Deeds Objections - Disposition of Collections of Judgment of Settlement El Pro?se 171-366 (Rev 10H3) IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL 4 21315 LAKE COUNTY, ILLINOIS CIVIL DIVISION PERSONNEL STAFFING GROUP, LLC, cilaaciug??g??g a Florida limited liability company d/bfa, MOST VALUABLE PERSONNEL, PlaintiffCaseNO. it: ROSA CEJA, an individual, is: . Defendant. COMPLAINT AT LAW NOW COMES Plaintiff, PERSONNEL STAFFING GROUP, LLC dz?bXa MOST VALUABLE PERSONNEL (?Plaintiff? and/or by and through its attorneys, KOREY RICHARDSON LLC, and for its Complaint at Law against Defendant, ROSA CEJ A (?Ceje? or ?Defendant?), state as follows: PARTIES, JURISDICTION, AND VENUE 1. Plaintiff MVP is a Florida limited liability company with its principal place Of business in the Village of County of Cook, and State of Illinois. 2. Upon information and belief, Ceja is an individual residing in the City of Waukegan, County of Lake, and State of Illinois. 3. Venue is proper in the Circuit Court of Lake County, Illinois, as the events giving rise to the causes of action asserted herein primarily occurred within Cook County, Illinois. STATEMENT OF FACTS 4. MVP is a temporary labor service agency that provides pe143011n?etl?s$yicae?Eto third Party client 00111132111168. BY Limit-mgr $131; 3E 12 THIS CASE Ir; warez-cs: not: ?jam-mnpi . Scott . tan: STREET, WAU REGAN, lumen. acute 31a: to MAY RESULT IN THE case Satan ca AR cease OFBEFAULT BEING ENTERED. 5. In or about March 2014, Ceja commenced employment with MVP, working as a third-shift dispatcher in one of of?ces. 6. In or about September 2014, Ceja was provided the opportunity to work in one of third-party client companies as an onsite supervisor. 7. However, in October 2014, after repeated complaints regarding Ceja?s job performance as an onsite supervisor, MVP offered to transfer Ceja back to a position as a dispatcher. 8. Ceja accepted the offer and was supposed to report to of?ce on October 16, 2014. 9. Ceja failed to report to work on October 16, 2014, and stopped responding to emails to her from management. 10. On or about October 20, 2014, after failing to report to work for ?ve consecutive days, MVP management deemed Ceja to have abandoned her position and considered her employment at MVP terminated. 11. On or about December 16, 2014, Ceja published disparaging remarks regarding MVP on her Facebook profile page. Said Facebook post, in Spanish, reads: ?Si MVP (03 Valuable Personal) les debe hora han sido victimasDe abuzo por favor mandenmen un mensage hay personas interesadas en parar las injusticias que acen. Por favor compartan.? (A true and correct copy of Ceja?s December 16, 2014, Facebook publication is attached hereto and incorporated herein as Exhibit 12. In English, Ceja?s Facebook post reads: ?If any MVP (Most Valuable Personal [sic]) are owed hours, have been victims of abuse, please send me a message. There are people interested in ending the injustices they are doing. Please share.? (A copy of the certified translation of Ceja?s Facebook publication is attached hereto and incorporated herein as Exhibit B). 13. Furthermore, in the comments section, on or about December 17, 2014, Ceja further defames MVP when inquiries were made regarding the content of her message. Ceja clari?es, ?People sometimes don?t get paid or if they report that they have been sexually abused they don?t (See Ex. EX. B). 14. Ceja then ?shared? her post with twenty?nine other individuals. 15. Ceja has disparaged business and business acumen to multiple third parties in an attempt to discredit MVP within its industry, to discourage employees to join workforce, and to solicit business away from MVP. 16. Ceja?s statements imply that MVP has engaged in illegal conduct for failing to pay its employees? wages, that it lacks integrity in its business operations, and that it generally lacks integrity in the discharge of its duties as a company. Further, Ceja?s statements impugn reputation within the community where it operates and provides services. COUNT I Defamation 17. Plaintiff re-incorporates and re~a11eges the allegations of Paragraphs 1 through 16 as if fully set forth herein. 18. Ceja?s statements to third parties are words that impute that MVP is unable to perform its duties and that they lack integrity in performing those duties, words that impute the commission of a criminal offense and words that prejudice MVP in their business. 19. The above-referenced statements were and are false. 20. Ceja?s public posting of said statements constitutes defamation per so, as the statements impugn business practices and integrity, accuse MVP of engaging in illegal activities, and generally harm and prejudice reputation and goodwill within the community regarding business operations. 21. Ceja?s statements further prejudice ability to work in the labor services industry, as Ceja has disparaged MVP as a company to potential employees/laborers. industry, the temporary labor service industry, is a quick-paced industry, which demands MVP have a high volume of available and quali?ed laborers to assign to their third?party clients when requested. Cej a?s statements discourage employment with MVP and disparage MVP to potential employeesflaborers, current employees? laborers as well as potential and current clients. 22. Ceja?s statements have damaged reputation in the industry and the community wherein it provides services. 23. Ceja made those statements with deliberate malice or with reckless indifference to rights and reputation. WHEREFORE, Plaintiff, PERSONNEL STAFFING GROUP, LLC d/b?a MOST VALUABLE PERSONNEL, respectfully requests that this Honorable Court: enter judgment in favor of Plaintiff and against Defendant, award Plaintiff. its actual and compensatory damages in an amount to be determined at trial not less than $50,000.00; award Plaintiff punitive damages; and award Plaintiff such further relief as this Court deems equitable and just. Respectfully submitted, PERSONNEL STAFFING GROUP, LLC dfbfa MOST VALUABLE PERSONNEL By: CQue of??jtorneys Carter A. Korey Elliot Richardson Britney L. Zilz KOREY RICHARDSON LLC Affomeysfor Pfaz'mij?? 20 S. Clark St, Suite 500 Chicago, Illinois 60603 P: (312) 372.7075 ARDC No: 6256231 ARDC No.: 6256982 ARDC No.16314340 ?Hoanummh?mw?q?nmm anguwum?mw. mm?mmw . . .33awaymmmgm?mmn ma?a mam mm a. . mamas . . . . . . . . 23Ewa:wmamamumm??nn?wumwmm ..H. .. . . . Flatt?muwcu?hmxm?mm36m 3.3m mm. gum mm mumm 0am . wmnma?wlm m?qmg.gn$93.va . mwm.?? . ?393.: momwmn?m?udmonm?m un?gammum? . H. 9.83me mam ?mam yam. - mue?mm. . 33.3 n. .HH u. H. ?Mammu?m??mRaga. . Mug 3mm magma Rosa Ceja shared her post -- with Tinlta Matias Robles and 28 others. December 16 at 6:23pm Rosa Ceja If any MVPs (Most Valuable Personnel) are owed hours, have been victims of abuse;r please send me a message. There are people interested in ending the injustices they are doing. Please share Comments [sick Jorge Pelaez Rosa Ceja Alin Coffin I Rosa Ceja Jorge Albarran What?s this about Rosa Ceja Private message (inbox) Jorge Pelaez Whats all about? People sometimes don?t get paid or if they report that they have been sexually abused they don?t care. Rosy I?m still here don?t forget about me - - . . 12%; - I 1 s. im? Exhibit Cartlficata of Accuracy certify that this documant was translated tram i '5 to i by a translator working for Multilingual Connection-5.. i believe the English translation to ba an accurate and complete translation 0f the original. - a, . Mai/rear Stet glar Datef Se or Translation anagar Multilingual Connectiona. LLC Subscribed and awer?n to bafare ma thi$ day of 20 it? at Chicaga, County of Cook, State of tiling-ta. mam. SEAL KAYLEE WYANT Notary Pabttc nvSt'ate- oi itiinois a My Commisa?ion Expires Mm: 1B. 2016 1. Notary Public-H -