ELECTRONICALLY FILED 9/28/2016 5:17 PM 2016-L-009607 CALENDAR: E PAGE 1 of 8 CIRCUIT COURT OF COOK COUNTY, ILLINOIS LAW DIVISION CLERK DOROTHY BROWN PAGE 2 of 8 ELECTRONICALLY FILED 9/28/2016 5:17 PM 10. 11. 12 Plaintiff? YVONNE VAZQUEZ, in the following ways: a. Unwanted and non-consensual touching of her breasts; b. Unwanted and non-consensual touching of her shoulders; c. Unwanted and non-consensual exposure of his penis That at all relevant times Defendant, CHARLES DEHAAN, saw the Plaintiff, YVONNE VAZQUEZ, under the guise of treating certain medical conditions. That at all relevant times Defendant, CHARLES sexual assault of Plaintiff, YVONNE VAZQUEZ, was an intentional and willful touching of the Plaintiff YVONNE VAZQUEZ. That at all relevant times Plaintiff, YVONNE VAZQUEZ, did not consent to the intentional and willful touching by the Defendant, CHARLES DEHAAN. That at all relevant times Defendant, CHARLES DEHAAN, was both providing medical treatment and sexually assaulting the Plaintiff, YVONNE VAZQUEZ. That at all relevant times Defendant, CHARLES DEHAAN, used his position of power as a licensed medical doctor and the person in control of her physical well- being, over the Plaintiff, YVONNE VAZQUEZ to sexually assault her. That the elements contained in Paragraphs 1-10 were acts of violence or physical aggression satisfying the elements of battery that were committed, at least in part, on the basis of YVONNE sex in violation of 740 ILCS 82/5, the Illinois Gender Violence Act. . That the allegations contained in Paragraphs 1-10 constitute a physical intrusion or physical invasion of a sexual nature by Defendant, CHARLES DEHAAN, under coercive conditions against Plaintiff, YVONNE VAZQUEZ, in violation of 740 ILCS PAGE 3 0f 8 ELECTRONICALLY FILED 9/28/2016 5:17 PM 82/5, the Illinois Gender Violence Act. 13. That the allegations contained in Paragraphs 1 through 10 caused a realistic apprehension that Defendant, CHARLES DEHAAN, would commit that act on Plaintiff, YVONNE VAZQUEZ, in violation of 740 ILCS 82/5, the Illinois Gender Violence Act. 14. That as a direct and proximate result of the gender-related violence of Defendant, CHARLES DEHAAN, Plaintiff, YVONNE VAZQUEZ, suffered serious personal injuries to her body that resulted in conscious pain and suffering; that said injuries are permanent in nature and that the Plaintiff YVONNE VAZQUEZ has and in the future will be caused to endure great pain and suffering; that the Plaintiff, YVONNE VAZQUEZ, has and in the future will be caused to expend great sums of money endeavoring to be cured of her said injuries; all as a result of the injuries sustained herein. WHEREFORE, Plaintiff, YVONNE VAZQUEZ, prays for an entry of Judgment in her favor and against the Defendant, CHARLES DEHAAN, in a sum in excess of the minimum jurisdictional limit, damages for emotional distress, punitive damages, plus the cost of this suit plus attorney?s fees and costs related to bringing this action. COUNT II - GENDER RELATED VIOLENCE AGAINST HOUSECALL PHYSICIANS GROUP OF ROCKFORD. S.C. 15. Plaintiff, YVONNE VAZQUEZ, re-states and re-alleges Paragraphs 1 through 13 contained in Count I as if fully stated herein. 16. Plaintiff, YVONNE VAZQUEZ, was subjected to an act of gender related violence within the meaning provided in 740 ILCS 82/5, the Illinois Gender Violence Act. PAGE 4 0f 8 ELECTRONICALLY FILED 9/28/2016 5:17 PM 17. Plaintiff, YVONNE VAZQUEZ, was subjected to acts of physical aggression 18. 19. 20. 21. 22 amounting to battery committed in part on the basis of her sex, and was subjected to a physical invasion of a sexual nature under coercive conditions. That at all relevant times CHARLES DEHAAN was employed by and acting in the scope of his employment of HOUSECALL PHYSICIANS GROUP OF ROCKFORD, S.C. That at all relevant times Defendant, HOUSECALL PHYSICIANS GROUP OF ROCKFORD, S.C. directly supervised and controlled Defendant, CHARLES DEHAAN. That at all relevant times HOUSECALL PHYSICIANS GROUP OF ROCKFORD, S.C. was a corporation organized under the law of the State of Illinois. Defendant, HOUSECALL PHYSICIANS GROUP OF ROCKFORD, S.C., encouraged and assisted the act of gender related violence through their failure to supervise and control Defendant, CHARLES DEHAAN, and protect YVONNE VAZQUEZ from harassment and sexual battery. . That as a direct and proximate result of the gender-related violence of Defendant, HOUSECALL PHYSICIANS GROUP OF ROCKFORD, S.C., Plaintiff YVONNE VAZQUEZ suffered serious personal injuries to her body that resulted in conscious pain and suffering; that said injuries are permanent in nature and that the Plaintiff YVONNE VAZQUEZ has and in the future will be caused to endure great pain and suffering; that the Plaintiff YVONNE VAZQUEZ has and in the future will be caused to expend great sums of money endeavoring to be cured of her said injuries; all as a result of the injuries sustained herein. PAGE 5 of 8 ELECTRONICALLY FILED 9/28/2016 5:17 PM WHEREFORE, Plaintiff, YVONNE VAZQUEZ, prays for an entry of Judgment in her favor and against the Defendant, HOUSECALL PHYSICIANS GROUP OF ROCKFORD, S.C., in a sum in excess of the minimum jurisdictional limit, damages for emotional distress, punitive damages, plus the cost of this suit plus attorney?s fees and costs related to bringing this action. COUNT - GENDER RELATED VIOLENCE AGAINST EDEN HOME 23. 24. 25. 26. 27. 28. I-IEALTHCARE, LLC. Plaintiff, YVONNE VAZQUEZ, re-states and re-alleges Paragraphs 1 through 13 contained in Count I as if fully stated herein. Plaintiff, YVONNE VAZQUEZ, was subjected to an act of gender related violence within the meaning provided in 740 ILCS 82/5, the Illinois Gender Violence Act. Plaintiff, YVONNE VAZQUEZ, was subjected to acts of physical aggression amounting to battery committed in part on the basis of her sex, and was subjected to a physical invasion of a sexual nature under coercive conditions. That at all relevant times Defendant, CHARLES DEHAAN, was employed by and acting in the scope of his employment of EDEN HOME HEALTHCARE, LLC. That at all relevant times Defendant, EDEN HOME HEALTHCARE, LLC directly supervised and controlled Defendant, CHARLES DEHAAN. That had Defendant, EDEN HOME HEALTHCARE, LLC, properly supervised and controlled Defendant, CHARLES DEHAAN, it would have discovered: a. That the Rockford Police department had written reports of complaints from at least twenty one (21) women accusing Defendant CHARLES DEHAAN of sexual misconduct and abuse during medical visits. b. That the dates of these police reports range from November 10, 2009 through February 28, 2014, seven of which occurred before 2012. c. That the dates of abuse which were described in these complaints range from 1993 through 2014. (1. That Assistant State?s Attorney K. Kurtz was noti?ed of the allegations in August of 2012, however did not pursue any criminal charges. e. That a patient grievance was ?led against Defendant CHARLES DEHAAN with another medical entity, Converge Home Health Care, in September of 2013, which alleged inappropriate sexual touching by Defendant CHARLES DEHAAN. f. That Cora J. Threadgill, Director of Nursing at Heritage Woods of Rockford, was noti?ed of an allegation of sexual misconduct against Defendant CHARLES DEHAAN by an unknown employee of Converge Home Health Care on June 13, 2011. PAGE 6 0f 8 ELECTRONICALLY FILED 9/28/2016 5:17 PM g. That the administrator of Heritage Woods of Rockford contacted the Rockford Police Department regarding Defendant CHARLES sexually inappropriate conduct on several occasions between 2009 and 2011. h. That the Rockford Police Department was in touch with the Illinois Department of Professional Regulations Medical Division) in June of 2011 regarding allegations of sexual misconduct against Defendant CHARLES DEHAAN. 29. That Plaintiff, YVONNE VAZQUEZ, informed an employee of EDEN HOME HEALTHCARE, LLC. that Defendant, CHARLES DEHAAN, was acting inappropriately and touching himself while he was supposed to be providing treatment to Plaintiff at her home. PAGE 7 of 8 ELECTRONICALLY FILED 9/28/2016 5:17 PM 30. That Defendant, EDEN HOME HEALTHCARE, LLC., encouraged and assisted the act of gender related violence through their failure to supervise and control Defendant, CHARLES DEHAAN, and protect YVONNE VAZQUEZ from harassment and sexual battery. 31. That as a direct and proximate result of the gender-related violence of Defendant, EDEN HOME HEALTHCARE, LLC., Plaintiff, YVONNE VAZQUEZ, suffered serious personal injuries to her body that resulted in conscious pain and suffering; that said injuries are permanent in nature and that the Plaintiff, YVONNE VAZQUEZ, has and in the ?iture will be caused to endure great pain and suffering; that the Plaintiff, YVONNE VAZQUEZ, has and in the future will be caused to expend great sums of money endeavoring to be cured of her said injuries; all as a result of the injuries sustained herein. WHEREFORE, Plaintiff, YVONNE VAZQUEZ, prays for an entry of Judgment in her favor and against the Defendant, EDEN HOME HEALTHCARE, LLC, in a sum in excess of the minimum jurisdictional limit, damages for emotional distress, punitive damages, plus the cost of this suit plus attorney?s fees and costs related to bringing this action. Respectfu/ll Sub MIC 1?3 J. GRAVLIN A rney for Plaintiff LAW OFFICES OF MICHAEL J. GRAVLIN, LLC. 134 N. LASALLE STREET, SUITE 2020 CHICAGO, IL 60602 (312) 201-9961 Attorney NO: 42760 PAGE 8 0f 8 ELECTRONICALLY FILED 9/28/2016 5:17 PM IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION YVONNE VAZQUEZ, Plaintiff, v. CHARLES DEHAAN, HOUSECALL PHYSICIANS GROUP OF ROCKFORD, S.C., EDEN HOME HEALTHCARE, LLC. No: Defendants. AFFIDAVIT PURSUANT TO SUPREME COURT RULE 222th) MICHAEL J. GRAVLIN, on oath, deposes and states as follows: 1. I am an attorney assigned to the case on behalf of the Plaintiff, YVONNE VAZQUEZ. 2. I have personally discussed the circumstances of this occurrence with the Plaintiff and have learned the nature and extent of the injuries. 3. Based upon information presently available regarding the nature and extent of the Plaintiff?s injuries, I believe that her case total damages exceed FIFTY THOUSAND and no/ 100 DOLLARS FURTHER, YOUR AFFIANT SAYETH NAUGHT, MI J. GRAVLIN Attorney for Plaintiff Subscribed and sworn to before me this eigenday of Se p3; - 2016. (W, Mai? ?otary Public LAW OFFICES OF MICHAEL J. GRAVLIN, LLC. 134 N. LASALLE STREET, SUITE 2020 CHICAGO, IL 60602 ?it (312) 201-9961 rm ummoo Attorney NO: 42760 WIN MIC STATE OF ILLINOIS Ir Communion Expires Jun 20. 2020