Civil Action Cover Sheet - HERBALIFE INTERNATIC INT Case Initiation .OF AMERICA, INC. TWITTER, INC. CIVIL ACTION COVER SHEET - CASE INITIATION A Civil Action Cover Sheet - Case plaint in all civil actions. The infor FUL DEATH 027 040 047 048 064 065 078 199 TAX MISCELLANEOUS RE Motor Vehicle Medical Malpractice Asbestos Dram Shop Product Liability Construction Injuries (including Structural ll Construction Injuriesi Railroad/FELA 1 Tot and negligence) Vork? Act, Road Pediatric Lead Exposare Other Personal Injury/Wrongful Death Intentional Tort Miscellaneous Statutor Action (Please Speci?i Below Premises Liability Fen-phen/Redux Litige Silicone Implant lthI?l MEDIES CASE TYPES: I Confessions ofJudgme Replevin Tax Condemnation Detinue Unemployment Compe Foreign Transcript nt *nsation Administrative Review Action Petition to Register for All Other Extraordinalr eign Judgment Remedies Initiation shall be ?led with the com- ?mation contained herein is for adminis- trative purposes only and cannot he introduced into evidence. Please check the box in front of the appropriate case type which best characterizes your action. Only one (I) case type may be checked with this cover sheet. Jury Demand Yes IE No PERSONAL CASE TYPES: (11/06/13) CCL 0520 HE CIRCUIT COURT OF COOK COUNTY, ILLINOIS . COUNTY DEPARTMENT, LAW DIVISION No. I. I "f?l :1 g, :31 $.22 -. ea I . 3 tail m: Lil still at 1:3 0 a! lin"rip 0? DJ 1? q, I inns: i"I ?can ??02 Li ild 02 Si 3.61 5w"! fl l2 (FILE 3. mm COMMERCIAL LITIGATION CASE TYPES: El 002 Breach of Contract 070 Professional Malpractice (other than legal or medical) 071 Fraud (other than legal or medical) El 072 Consumer Fraud El 073 Breach of Warranty [3 074 Statutory Action 075 (Please speci?/ below. ?7 076 a i: Other Commercial Litigation (Please speci?l below?) Retaliatory Discharge OTHER ACTIONS CASE TYPES: 062 Property Damage 066 Legal Malpractice El 077 Libel/Slander. I: 079 Petition for Quali?ed Orders El 084 Petition to Issue Subpoena 100 Petition for Discovery int! Service via email from opposing party/counsel will be accepted at: I(Attorney) Pro Se Only: '3 have read and ag from the Clerk?s of?ce for this case DOROTHY BROWN We) - 0 at this email address: 7Pro Se) by consent pursuant to Ill. Sup. Court Rules 11 and 13]. "cc to the terms of the Clerk?s Of?ce Electronic Notice Policy and choose to'opt in to electronic notice CLERK. OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION 11 HERBALIFE INTERNATIONAL OF AMERICA, INC., 1 a Nevada Corporation, :39 1 50,1333 "33: 4 Petitioner, Case No. my?? V. IN 5 TWITTER, INC., a Delaware Corpo ation, Respondent. VERIFIED PETITION FOR DISCOVERY UIT PURSUANT TO ILLINOIS SUPREME COURT RULE 224 BEFORE Petitioner Herbalife International of America, Inc. (?Herbalife?), by its undersigned counsel, ?les this Veri?ed Petition pursuant to Illinois Supreme Court Rule 224 and states as follows: NATURE OF THE PETITION 1. Petitioner Herbalife brings this action for expedited discovery before suit to determine identiti of user(s) posting disparaging and false posts about Herbalife and its products on the so ial_ networking site Twitter using the handle ?@AfueraHerbaLIES.? 2. The Ti itter feed of @AfueraHerbaLIES contains not only defamatory, disparaging, and deceptive posii offensive statements about Herbalife?s management team, its members, and even federal 3 about Herbalife and its products, but also contains numerous insulting and regulators. 3. For example, in a post dated June 20, 2015, @AfueraHerbaLIES accuses Pamela Jones Harbour, all African-American woman who is the former commissioner of the Federal Trade Commissi and the current Senior Vice President, Global Member Compliance and Privacy for Herbalife statement: ?Former preserving a modern @AfueraHerbaLIES throughout the @Afu of perpetuating a ?modern day slave industry? by posting the following TC Chair has no respect 4 others sold herself2 that has her day slave industry 4 In another post dated June 15, 2015, likens a Herbalife distributor to a member of the ?HerbaKlan.? Moreover, eraHerbaLIES Twitter feed, Herbalife and its management are vili?ed as ?thieves, ?pill pushing frauds,? and ?bullies?? among the many other offensive and denigrating terms used by @Afur I meaning in Spanish a L. 4. Petition the identities of the :raHerbaLIES. Indeed, even the Twitter handle @AfueraHerbaLIES, ?out with is'disparaging to Herbalife. brings this action to identify and uncover information that would lead to lser(s) posting under the Twitter handle ?@AfueraHerbaLIES,? including relevant Internet Protocol addresses, account information, and the user information submitted to Twitter products. 5. Petition Angeles, California 3 nutrition company tl products available than 90 countries. 6. Twitter business in San Fra Twitter operates a by those who published the injurious statements about Petitioner and its PARTIES, JURISDICTION AND VENUE er Herbalife is a Nevada corporation with its headquarters located in Los and which does business within the State of Illinois. Herbalife is a global mat offers nutrition, weight-management, energy, ?tness, and personal care xclusively to and through dedicated independent Herbalife Members in more Inc. (?Twitter?) is a Delaware corporation with its principal place of ncisco, California, and which does business within the State of Illinois. ocial networking platform and micro?blogging website at Twitter enables users to post, send and read ?tweets?, which are real time messages limited to 140 characters. Th ese tweets can include photos, text, videos, and/or links to other websites. 7. Venue is Court in which the ac which the respondent THE DEFA The May 11, 2015 proper pursuant to Illinois Supreme Court Rule 224(a)(ii) because this is a tion or proceeding might be brought; moreover, Cook County is a county in from whom discovery is sought?Le. Twitter?transacts business. MATORY, DECEPTIVE, AND DISPARAGING TWEETS BY @AfueraHerbaLIES weet 8. On or ab @AfueraHerbaLIES copy of the May 11 9. In the recalled because the ?Blog Post?). The out May 11, 2015, an anonymous Twitter user posting as published false statements about Herbalife and its products on Twitter. A 2015 tweet is attached hereto as Exhibit A (the ?May 11 Tweet?). ay 11 Tweet, @AfueraHerbaLIES states that products will be are toxic.? That Tweet contained a link to a blog post at entes.net/2013/1 (the ext of the Blog Post is attached hereto as Exhibit B. A certi?ed English translation of the t6) 10. The Ma New York Stock Ex generated search tei preceded by a poun (t of the Blog Post is attached hereto as Exhibit C. .y 11 Tweet is about Herbalife. HLF is the stock symbol for Petitioner on the change. The tweet includes the hashtag ?Hashtags? are user ms that aggregate posts that also contain the same hashtag. While typically sign ?nancial hashtags have emerged on Twitter by preceding a company?s stock symbol with a dollar sign Accordingly, when a Twitter reader clicks on the link created by concerning Herbali Herbalife Twitter 3 on the hash 11. More? L4 fact that the vast the ?nancial hashtag within the May 11 Tweet, content on Twitter fe and its products is immediately presented and accessible, with the of?cial appearing as the top result. A copy of content available when clicking Iiag as of the date of this ?ling is attached hereto as Exhibit D. ver, that the May 11 Tweet is of and concerning Herbalife is evidenced by the 1ajority of the @AfueraHerbaLIES Twitter feed concerns Herbalife?s products 3 and management tea and as previously noted, even the Twitter handle itself disparages Herbalife by incorporating the term The July 5, 2015 Tweet 12. On or about July 5, 2015, the Twitter user @AfueraHerbaLIES published another false tweet: ?People [sic] being Poisoned around the world by TOXIC unregulated products! AFUERA (The phrase CON means WITH A copy of the July 5, 2015 tweet is attached hereto as Exhibit (the ?July 5 Tweet?). As with the May 11 Tweet, the hashtag in the July 5 tweet also links to content concerning Herbalife and its products. The Tweets are Defamatory Per Se 13. The May 11 Tweet and the Blog Post contain false and defamatory statements of fact about Herbalife. For example, the May 11 Tweet contains the false statement of fact that Herbalife ?products will be recalled because they are toxic.? No Herbalife product has been recalled due to toxicity, nor is there any recall announced or scheduled due to toxicity. 14. Additionally, the Blog Post that @AfueraHerbaLIES republished through the May 1 Tweet contains other false statements of fact, including that Herbalife products ?will be withdrawn from the market because of their toxicity.? That statement is false because Herbalife products are not, and never have been proven to be, toxic. Further, none of Herbalife?s products have ever? been withdrawn in Colombia as a result of a governmental mandate. 15. The July 5 Tweet also contains false statements of fact, including that people around the world are being poisoned by Herbalife?s ?toxic? and ?unregulated? products. These statements are falje because again, Herbalife?s products have never been proven to be poisonous, toxic or unregula ed. 16. Each of false statements in the May 11 Tweet and Blog Post, as well as the July 5 Tweet, is defamatory per se of Herbalife. By stating that Herbalife produces ?toxic? products that are pulled off the market because of a government mandate, that Herbalife is ?poisoniingf? people around the world, and that the products are ?unregulated,? statements in the Tweets and the Blog Post directly impute to Herbalife both the inability to perform capably as a business and a want of integrity in its business?operations. These false statements prejudice Herbalife in its trade and are materi lly harmful to Petitioner such that injury to its reputation must be presumed. 17. On infoqmation and belief, the user posting the May 11 Tweet with the Blog Post and the July 5 TweT! did so with knowledge of their falsity and/or reckless disregard of whether the statements there'n were true or false. Upon revelation of the identity of the user who posted the May 11 Tweet July 5 Tweet, further facts may be uncovered to allow Petitioner to allege additional'facts demonstrating that the statements in the May 11 Tweet, including the republication of the Blog Post, and the July 5 Tweet, were made with ?actual malice?, that is, with actual, subj ect've, awareness of their probable falsity. The Tweets Coulcf Also Violate the Illinois Deceptive Trade Practices Act 18. The May 11 Tweet, the Blog Post, and the July 5 Tweet are also false and misleading repres tations of fact that disparage Herbalife?s goods and business, and could violate the Illinois Deceptive Trade Praetices Act, 815 ILCS 510/1 et seq, in the event that user(s) of the ueraHerbaLIES made each of these statements in the course of their business, vocation, or occupation with knowledge of the statements? deceptive character. Upon obtaining the identity of the user who posted the May 11 Tweet with the Blog Post and the July 5 Tweet, further facts may be uncovered to allow Petitioner to allege additional facts demonstrating that the user posting the Tweets did so with knowledge of the statements? deceptive character. DISCOVERY SOUGHT 19. The purpose of Rule 224 is to allow discovery before ?ling suit to ascertain ?the identity of one who may be responsible in damages.? Ill. Sup. Ct. Rule 224. Rule 224 ?provides a tool by which a person or entity may, with leave of court, compel limited discovery before ?ling a lawsuit in an effort to determine the identity of one who may be responsible.? 134 R. 224, Committee lomments, at 188. Pursuant to Rule 224, discovery is allowed to either: (I) discover the identities of persons with a connection to the petitioner?s injury; or (2) discover sufficient facts about a known person?s connection to an injury to further re?ne the universe of defendants having potential liability. 20. Petitioner believes that Twitter has in its possession identifying information for the user(s) of @AfueraHerbaLlES, who have engaged in publishing actionable statements about Herbalife. The basis for Herbalife?s belief is that Twitter?s registration process requires a user to provide a name and address before he or she can post a tweet. Further, on information and belief, Twitter also records the user?s Twitter account information and IP address every time he or she logs into Twitter and posts a tweet. Petitioner requests that this Court enter an order under Rule 224 allowing it to serve discovery upon Twitter, including interrogatories and document production requests, and to initiate such other discovery as may be appropriate, to obtain information regarding the identity of who might be liable to Herbalife in damages for defamation, and who may be subj ect to an injunction under the Illinois Deceptive Trade Practices Act. Further, Petitioner requests that this Court enter an order directing Twitter to preserve all information relating to this subject matter . pending further order of the Court. 22. The (Tiscovery sought is necessary because the identity of the Twitter user(s) responsible for posts on @AfueraHerbaLIES is unknown to Herbalife, as the user(s) of the @AfueraHerbaLIES handle are and remain intentionally anonymous. Additionally, Twitter?s Privacy Policy requires a court order prior to releasing personal information about its users, and therefore the informaJion regarding the anonymous user(s) of the @AfueraHerbaLIES handle is unavailable to Herbalife by any other means. 23. Vasilios H. Frankos M.S., Senior Vice President, Global Regulatory Compliance and Product Safety for Herbalife, has veri?ed the matters set forth herein pursuant to Rule 224. Petitioner Herbalife respectfully requests that the Court enter the attached order authorizing it to take the requested discovery from Twitter. Dated: July 20, 2015 Respectfully submitted, Dentons US LLP QM OneVof the Attorneys for Petffib?eir Stephen Senderow tz Samuel ifer Kristen C. Rodrigl ez DENTONS US LLP 233 S: Wacker Df'lve Suite 5900 Chicago, IL 6060 Telephone: Facsimile: 312?8 6-7934 Firm No. 56309 >41! 0 a- av"-I- I?d. '0 >0 uL-m?fh: .. - Qatar:25. .331? u- T. :30 Lg?? 3 "leih?ia 3:393 a :1 ?no-gu?-lggac? a 2 I ?3:3 .. ml at?: 2.79: If?! a. 5:2. an v.5 3:33 Eu 53- .- n. wmamww .55, :53 -- .43. rutwwm? wm 155-1 En r? E, flat": 21.1?; '9 :1 II h? 1" um. no? Is'lj 733.; :13! I331 and: <13. IN TH CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION HERBALIFE INTER-NATIONAL OF AMERICA, INC., a Nevada Corporation, Petitioner, Case No. v. TWITTER, INC., a Delaware Corporation, Respondent. games This matter co} Inc. Court Rule 224, prope premises, it is 1 . 1 upon respondent Twi initiate such other dis information regarding be subject to an injun 2. The Con] documents produced discovery described ENTERED: Date: Petitioner ning before the Court on Petitioner Herbalife International of America, eri?ed Petition for Discovery Before Suit Pursuant to Illinois Supreme notice having been given, and the Court being full advised in the BY ORDERED: Herbalife is given leave to serve interrogatories and document requests ter, Inc. (?Twitter?) pursuant to the Illinois Supreme Court Rules, and to covery and enter such further orders as may be appropriate, to obtain who may be liable to Herbalife in damages for defamation, and who may ction under the Illinois Deceptive Trade Practices Act. directs respondent Twitter to preserve any and all information or in the prior litigation set forth in the Petition pending issuance of the above. Circuit Judge AFUERA HERBALIES on Twitter: products will be recalled because they are Page 1 of 2 New to Twitter? Sign up Search TW?tt6f 3' Have an account? Log in IERA VHERBALIES Follow eraHerbaLlES .. . w, products will be recalled because they are toxic. FAVORITE I 1 May2015 9 Los Angeles, CA i: . Na ?Wuur._~ ?Mamamum ?2015Twitter About Help Adsinfo AFUERA HERBALIES on Twitter: products will be recalled because they are Page 2 of 2 New to Twitter? . Sign up I SearCh TWitter I Have an account? Log in 598007482443 694080 Nueva Mentes: Los pro ductos dc Herbalife ser?n fetirados del mercado por t?xicos Page 1 of 2 P?gina principai domingo, 17 de noviembre de 2013 Los produc mercado I . . Hos de Herbahfe seran retlrados del arr t?xicos En estos dias el Instituto Nacional de Vigilancia de Medicamentos Alimentos? I En cuanto a IasI colombiano nelg su algunos de Is autorizaci?r) de que algunos de? Al parecer se 0 provocarian del de Colombiane_ f?rmacos no produce p?rdilcl 6 la autorizaci?n de 3 productos de Herbalife, asegurando Ias sustancias que Ios componen son considerados como ueden ser considerados como suplementos alimenticios. bebidas Bulk Muscle Health 8. Fitness, el organismo 6 SU autorizaci?n como suplemento alimenticio al considerar que us componentes tienen efectos fa?rmacos. Tambi?n se neg? lay producto Chew Slim Gum(ChicIe goma de mascar) amprob? que entre sus componentes incluu?a zinziber, que a de apetito mareo por locomocic?m. En el chicle tambi?n ?detect? garcinia, cuyas oleoresinas tendrl'an un efecto laxante tambi?n or de est?mago v?mito, segL'm el organismo colombiano. 1/ Nueva Mentes?: Los productos de Herbalife ser?n retirados del mercado por t?xicos Page 2 of 2 I En cuanto a Esp el Ministerio de Sanidad Consumo ha informado hoy ?3 algunos casos de toxicidad hep?tica. Algunos consumidores de Herbalife A presentaron este uadro, dolencias en el hl?gado con manifestaciones diversas. Clompar?r ,i Manama bismum P?gina principal Ver versi?n web ?awry Shop Affordable, Modern Sofas for "Your Living Roomtecnologia de Biogger. nentes.net/2013/ 1 1/ Homepage Sunday, November 1 2013 The Herbali products will be withdrawnfrom the market because of their toxicity. Recently, the C'lilombia National Institute of Food and Drug Monitoring denied the authorization of 3 Herbalife products, ensuring that some of the substances included are considered drugs and cannot be considered dietary supplements. As for the Bulk Muscle and Health 8. Fitness drinks, the Colombian agency refused their authorization as a dietary supplements since some of their components have pharmaceutic effects. The agency also did not authorize the Chew Slim Gum product (chewing gum or bubblejum). Apparently, it as confirmed that its components included Zingiber, .which produces loss of appetite and motion sickness. According to the Colombian agency, the gum also contains garcinia, whose oleoresins have a laxative effect and would cause stomach pain and vomiting. As for Spain, the Ministry of Health and Consumer Affairs has today reported some cases of liver toxicity. Some consumers of Herbalife showed of liver ailments with varied manifestations. IN THE CIRCUITCOURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION HERBALIFE INTERNATIONAL OF AMERICA, {No.1 3 Nevada Corporation, Petitioner, v. TWITTER, INC., . a Delaware Corpu ration, Case No. Respondent. VERIFIED CERTIFICATION OF TRANSLATION I, JfMartin Balaguer, hereby state under oath as follows: 1. I a the Director of Productions for LingPerfect Translations, Inc. 2. Lin Perfect Translations, Inc. is an ISO 9001:2008 certi?ed company authorized to trai slate documents from Spanish into English. 3. gPerfect Translations, Inc. certi?es that this English translation is an accurate represen ation of the blog post titled ?Los productos de Herbalife scrim retirados del mercado por toxicos? originally written in Spanish and available at . http: /w'ww. nuevamentes.net/ 2013 seran.html?spref =tb8tm=1 (last accessed July 16th, 2015). Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the undersigned certi?es that the statements set forth in this af?davit are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certi?es as aforesaidth he verily believes the same to be true. . A, '5 . J. Martin Balaguer Director of Production - 06?: 7//g . I . ?0&0th LingPerfect Translations, Inc. wwomxvm Mum 125 Maiden Lane, Sulte 509 New York, NY 10038 Twitter Search Page 1 of 4 New to Twitter? Sign up Have an account? Log in Toj 5 Live Accounts Photos Videos More option3v New to View all Icahn, Ackman? among heavyweights in store at Delivering Alpha MM mums fSiunI ET Human .1 Sign up now to get your own personalized timeline! Sign up Trends Ashley Madison #1 Dlndosiar #MondayMotivation Jordan Spieth Lee Nelson Bronson Masquerade #GrowingUpWithAnxiety Geraint Thomas re a a l'indnut ?2015Twitter About Help dsinfo Accounts View all Follow Follow Herbalife 0 Ben Greener @Herbalife @BenGreenerHLF Herbalife, nutrition for a better life. Heritage, regeneration. economic Leading nutrition direct-selling development. historic environment policy company. Find out more: - my views. not HLF's Facebookcom/Herbalife Scott Johnson @ScottTexJohnson 4m @PeterBent @mikeo188 A bit late for MOJ to snitch. meaSurements are now being taken for the orangejump suit and a reservation t3 . . View conversation min 7/20/2015 - Twitter Search Page 2 of 4 @mikeo188 My New PT is $1,001 on (wouldn't want to make that guy unhappy) New tolW'tterf?i? 1 Scott Johnson @ScottTexJohnsen 1h @mikeo188 The diitlble would be more appropriately 819m Enforcing Existing RestrictionsAgainst Network Marketing." . ?5 1 .00 View conversation mikeo188 @mikeo?lBB 2h . I wonder how this will impact - China Increases Restrictions Against Network Marketing 2 .00 Naomi Frances @NaomiFrance51 3h anyone buyin on this dip? diabetes and obesity and aging aint takin no ?5 t1 mikeo188 @mike0188 4h is a pretty obvious complex not sure they'll even need whistleblowers. #squealforadeal 2 no. mikeo188 @mik90188 - 4h "Company insider awarded $3 mil for helping SEC crack a complex fraud; payout is third highest award to date: ?5 2 no. OptionsGod?@WeeklyOptTrader - Jul 18 at 53.89..this reports on 8/5 ..very this will be in (late) 603 after earnings 4-. 1:1 5 i 45 Quoth the Raven @QuoththeRavenSA - Jul 18 Herbalife lobbying trends. "Move along, nothing to see here!" via @HerbalifeVerda upensecrets.ut9 A Annual Lobbying by I Herbalife International - 51.2M Total so ?5 t1 1 5 u. View photo Quoth the Raven @QuoththeRavenSA - Jul 18 Herbalife political spending trend. Sure. we're just a nutrition company! #lobbying (via @HerbalifeVerda) 50 R. 7/20/2015 - Twitter Search Page .3. II. no; SonJDutsm: wv Sign up New to Twitter? Lobbying Totals. 1998-2014 semi??cag in I "??Annual International 1 8 View photo 4-. ?12 michelle celarier @mcelarier - Jul 17 More on that damned video Former $HLF_distributors ask judge to reconsider #classaction suit. bit.lyl1McL37t via @NatProdlnsider 15 1 6 n- Closing thought for the week: regardless of what you think of him, if you think Quoth the Raven @QuoththeRavenSA Jul 17 . Ackman is done w/ SHLF. you clearly do not know him well. ?5 1 3 no. hedgefundclone @hedgefundclone - Jul 16 Ackman was short for years 3 or 4 years and then suddenly the stock dropped from $60 to $3 in months could be the same! ?5 1L1 4 10 hedgefundclone @hedgefundclone - Jul '16 Ackman is short $1 Bn of or almost 7% of his fund and he is down on it so it?s a good time to buy puts on if you believe his thesis ?5 13' 1 ?k 10 "considerable frustration" policing high level distributors ?5 1 7 0.0 michelle celarier @mcelarier - Jul 16 Bostick objectors have ?led a motion to reconsider settlement, citing my @nypost exclusive on Michael Johnson 2005 video 4? 1.1 4 7 on ValueWalk @valuewalk Jul 15 - Peltz, Ackman At Delivering Alpha Conference Updated: ?5 4 7 no. Ackmanscam @Ackmanscam - Jul 14 yours Ackman. Despite your corruption lies about Herbalife, we still had our best year 7/2 0/201 5 - Twitter Search Page 4 of 4 . View photo New to?nNitterg-l' 2 7 Sign up hedgefundclone @hedgefundclone - Jul 14 Bill Ackman presents tomorrow morning around Qam eastern! Before Open! Have an account? Log in 2 ?o?oo 7/20/2015 AF UERA HERBALIES New to Twitter? Search Twitter on Twitter: "People being Poisoned around the world by Page 1 of 2 Sign up Have ah account? Log in AFUERA HERBALIES Follow f- @AfjeraHerbaLiES v? People being Poisoned around the world by TOXIC unregulated preducts! CON //twitter.co 1835136 I . AF UERA HERBALIES on Twitter: "People being Poisoned around the world by Page 2 of 2 FAVORITE 1 4:25 PM - 5 Jul 9 GurneeTwitter? Sign up I Search Twitter Have an accountmm..4. 7 . y. . @2015 Twitter About Help Ads info 183 513 6 VERIFICATION As provided law pursuant to Section 1~109 of the Iliinois Code of Civil Procedure, the undersigned certi?es on behalf of Petitioner that the statements set forth in the foregoing pleading are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certi?es as aforesaid that he verily believes the same to be HUB. . Dated: wk Vasi ios H. Frankos'MS? Senior Vice President Global Regulatory Compliance and Product Safety