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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
AMY PHILLIPS,
Plaintiff,
vs.
EXXONMOBIL CORPORATION,
Defendant.

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Case No. 17 CV 7703
JURY TRIAL DEMANDED

COMPLAINT
Plaintiff AMY PHILLIPS, by and through her counsel, Salvatore
Prescott & Porter, PLLC, brings this complaint against her employer,
Defendant EXXONMOBIL CORPORATION, and states as follows:
I.

INTRODUCTION
AMY PHILLIPS is one of very few women or openly gay

people working as process operators at EXXONMOBIL’s Joliet Refinery. For
years, PHILLIPS’s supervisors and coworkers have treated her horribly—
excluding her from necessary training, restricting her opportunities to
progress, constantly belittling her, repeatedly referring to her as a “bitch”
and a “cunt” and a “rat,” writing hateful graffiti about her on walls and
equipment all over the refinery, even threatening her physically and
assaulting her. PHILLIPS’s complaints to her supervisors and Human
Resources only made matters worse. Not only did EXXONMOBIL fail to help
PHILLIPS, but the company has actively retaliated against her.
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PHILLIPS now brings this action for damages and
injunctive relief. She does so because she has been seriously harmed, and
because she does not want what happened to her to happen to anyone else.
II.

JURISDICTION AND VENUE
This Court has subject-matter jurisdiction over plaintiff’s

federal claims, arising under the laws of the United States, pursuant to 28
U.S.C. § 1331, and has supplemental jurisdiction over plaintiff’s state-law
claims pursuant to 28 U.S.C. § 1367, because they are related to the federal
claims and form part of the same case or controversy.
Venue is proper in this district pursuant to 28 U.S.C. §
1391(b), because the events giving rise to the claims occurred in this district.
On or about August 10, 2017, PHILLIPS filed a charge of
discrimination and retaliation with the Equal Employment Opportunity
Commission and the Illinois Department of Human Rights. On or about
October 13, 2017, PHILLIPS received Notice of Right to Sue from the EEOC,
authorizing her to commence this lawsuit.

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III.

THE PARTIES
Plaintiff AMY PHILLIPS resides in the Northern District

of Illinois. She has been an EXXONMOBIL employee since in or around 2013.
Defendant EXXONMOBIL is a corporation doing business
in the Northern District of Illinois. EXXONMOBIL operates a refinery at
Arsenal Road and I-55, Channahon, IL 60410, approximately 40 miles
southwest of Chicago, known as the Joliet Refinery. At all times relevant to
this action, EXXONMOBIL has employed more than 15 individuals.
IV.

FACTUAL ALLEGATIONS
PHILLIPS started working for EXXONMOBIL as a process

operator at the Joliet Refinery in 2013. As a process operator, PHILLIPS is
responsible for monitoring equipment used in the processing of crude oil and
responding when there are problems with the equipment. Her position is
physically demanding, and she typically works twelve-hour shifts.
The Joliet Refinery is a massive facility and one of the
largest operated by EXXONMOBIL. It can be a dangerous workplace, and it
has been listed as one of the most dangerous chemical facilities in the
country. PHILLIPS risks her life day in and day out to serve EXXONMOBIL.
PHILLIPS takes her work and training seriously, both
because she cares about doing a good job and because she understands the
critical importance of knowing and following safe practices at the facility.
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PHILLIPS has always been the only woman on her crew.
Overall, there are few women working as process operators at the Joliet
Refinery.
PHILLIPS Was Demeaned and Denied Essential Training
When PHILLIPS first began working at EXXONMOBIL,
she—like all employees new to the Joliet Refinery—received classroom
training relevant to her job as a process operator. PHILLIPS did not perceive
any discrimination against her in this setting.
Classroom training is only the first part of a process
operator’s training, however. Training in the field is essential to the process
operator’s development, and to her qualifications for more lucrative positions
at the Joliet Refinery. Such training is also critical for maintaining safety at
the facility.
Once PHILLIPS finished the classroom training and began
working in the field, she quickly noticed that her unit’s culture was negative
toward women.
For example, PHILLIPS’s supervisors, multiple times,
made comments to her to the effect of, “You should just stay at home like
most women.” Another frequent refrain: “A woman’s place is in the home.”
Multiple coworkers referred to PHILLIPS as a “cunt” and
“bitch,” regularly. Males made statements to each other that were degrading
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to women, along the lines of, “Are you going to cry like a little bitch?” They
also made repeated references to violence towards women, including showing
each other videos that depict women being assaulted. In or about June 2017,
PHILLIPS was present for a discussion in which one male coworker told
another male coworker that he would “slap the fucking shit out of that bitch,”
referring to a female employee. When PHILLIPS confronted the man who
made the statement, he claimed it was a joke and expressed irritation that
PHILLIPS complained.
PHILLIPS, who also is openly gay, was offended, hurt, and
nervous about this behavior. She stood up for herself and objected to
coworkers and supervisors who treated her this way. This did not go over
well.
Once it became clear that PHILLIPS was not tolerant of
their harassing behavior, and that she did not conform to their views of how a
woman should appear and behave, PHILLIPS’s male coworkers and
supervisors excluded and isolated her, refusing to include her in the unit’s
activities or provide critical field training.
The training PHILLIPS sought was highly relevant to her
position, and to the safety of herself and others at the Joliet Refinery.
Instead of training her, her coworkers mocked her. In fact,
PHILLIPS’s requests to observe and assist became a running joke at the
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facility, with her male coworkers openly mocking her and mimicking her
requests.
Because of her lack of support and training, PHILLIPS
trained herself on key tasks, even watching YouTube videos to learn how to
do things that her supervisors refused to teach her.
PHILLIPS’s

supervisor

also

erected

other

kinds

of

roadblocks to her progression at the Joliet Refinery, including by repeatedly
delaying her taking a test that would enable her to achieve higher pay. As
another example, PHILLIPS’s supervisor required her perform one key test—
a walkthrough of the facility, demonstrating proficiency at certain tasks—
backwards, which was unnecessary and made the test much more difficult.
Although PHILLIPS still passed the test, it was clear that the supervisor was
treating her differently than others in an effort to cause her to fail.
PHILLIPS’s male coworkers were not stymied in this way.

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PHILLIPS Discovers Hateful Graffiti
Over at least the past year, PHILLIPS has observed hateful
graffiti directed at her throughout the facility, oftentimes openly mocking her
sex and sexual orientation.
Just a few examples of the graffiti include:
a.

b.

AMY LAZY GAY BITCH

AMY FAGGET LAZY RAT BITCH

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c.

DIE AMY FAG RAT BITCH

d. AMY LAZY FAG BITCH

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e. AMY LAZY CUNT LICK FAG

There was also a drawing of what appears to be a penis
ejaculating on a person, with the name “AMY” next to the person.

These are just some examples. There were dozens of
separate instances of slurs about PHILLIPS being scrawled on refinery walls
and equipment, where not only PHILLIPS but all who worked in the complex
could see. Even when the words and images were painted over, they often
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reappeared. This was and continues to be embarrassing and degrading to
PHILLIPS. One male coworker told PHILLIPS that although he did not write
the graffiti, he thought it was “hilarious.”
PHILLIPS Was Subjected to Physical Violence and Intimidation
In addition to the mental and emotional distress from the
harassment, PHILLIPS has suffered and continues to suffer physical violence
and threats of physical violence from her male coworkers.
In late 2016, one particularly aggressive individual whom
PHILLIPS suspected was responsible for some of the graffiti was working
with her when PHILLIPS feared there might be a problem with one of the
refinery’s valve lineups. PHILLIPS asked the individual if he was sure that
both of the valves off of the splitter tower were open.
The male coworker responded with words to the effect of,
“If you’re so concerned about it, climb up there yourself, bitch. I fucking
looked already and checked that they’re open.”
PHILLIPS then climbed to the top of one of the towers,
found that one of the valves was blocked, and notified her coworkers via the
radio. Her male coworker then climbed up the tower, and PHILLIPS showed
him the problem.
Her coworker then said, “Why don’t you mind your own
business, bitch. I don’t need you up here, you cunt.” Then he said, “You know,
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people can fall off towers, and no one would know anything other than that it
was an accident.”
This was frightening to PHILLIPS, as she was alone with
him on a high tower, well above the ground. She understood her coworker to
be threatening her.
Later in the day, the same individual shoulder checked
PHILLIPS, purposefully thrusting his shoulder into her body.
PHILLIPS approached him to try to discuss his conduct
toward her. When PHILLIPS said, “We need to talk,” he pushed past her,
again hitting her body.
PHILLIPS followed him, trying to initiate a discussion, and
finally said, “Ok, then let’s go to the zone,” referring to upper management.
He stopped and said, “Of course you would you stupid bitch. No one wants to
talk to you; everyone knows you’re a cunt rat.”
In addition to the verbal and physical harassment,
PHILLIPS’s male coworkers also sought to interfere with her ability to do her
job. Because the Joliet Refinery is so large, employees use bikes to traverse
the grounds. PHILLIPS has discovered her bike with flattened tires, stolen
seats, and chained with a heavy-duty lock.
On at least one occasion when PHILLIPS found her bike
disabled with a heavy-duty lock, in or around March 2017, she went to use
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her backup bike. It too was chained with a heavy-duty lock not used on other
bikes in the facility.
A female coworker reported the matter to Human
Resources, with PHILLIPS’s knowledge and permission, but no one from the
Human Resources department ever contacted PHILLIPS to rectify the
situation. PHILLIPS also approached her working foreman and another top
supervisor, and received no response. PHILLIPS was forced to go to plant
security in order to try to remove the locks, but they too refused to offer
assistance.
It was only after PHILLIPS contacted corporate security in
order to request videotape of who had locked her bikes that anyone from the
Joliet Refinery responded to her requests for help. Even then, the Human
Resources department and managers were upset with PHILLIPS, rather
than the perpetrators of the harassment.
This harassment has not been limited to the workplace.
PHILLIPS has witnessed a coworker driving by her house slowly, which has
also drawn the concern of her neighbors.
These actions appear to be part of the ongoing effort to
make PHILLIPS feel physically threatened and intimidated in order to drive
her out of her position.

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PHILLIPS Repeatedly Put EXXONMOBIL on Notice
PHILLIPS

raised

these

issues

with

multiple

EXXONMOBIL supervisors and Human Resources, to no avail.
Her attempts to find help from management have been
complicated by the fact that PHILLIPS’s supervisors have openly expressed
disdain for having a woman and gay person on the crew. In PHILLIPS’s
presence, at least two supervisors have made comments to men about
“keeping your woman in her place at home” and “any man who doesn’t wear
the pants in his relationship is a little bitch.” Multiple supervisors also have
referred to people, in PHILLIPS’s presence, as “fags” and “homos,” which
PHILLIPS understood to be derogatory references to gay people.
In or about March 2017, PHILLIPS appealed to other
supervisors. PHILLIPS specifically addressed how she had been harassed
based on her sex and sexual orientation, the use of physical violence against
her, and how unsafe she felt.
In April 2017, PHILLIPS met with Scott Carpenter and
Sergio Moreno, both in the Human Resources department, who told her that
they had investigated and found her claims substantiated.
They also said that even though PHILLIPS’s claims were
correct, she would be required to continue to work alongside the coworker
who had threatened and assaulted her. When PHILLIPS asked if he would be
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held accountable for his conduct, they told her that their understanding was
that EXXONMOBIL had already required the male coworker to apologize to
PHILLIPS for locking her bike and that he would be on his “best behavior.”
With the apparent objective of causing PHILLIPS to believe she did not have
it so bad, Carpenter told her that things at the refinery were not as bad for
women now as they had been in the 1970s.
PHILLIPS was stunned and frightened. She told Carpenter
and Moreno, in two separate meetings, that she was in a toxic environment
and felt totally unsafe. The company did nothing whatsoever to help
PHILLIPS. The graffiti continued to appear, becoming more threatening,
including the chilling message, “DIE AMY RAT BITCH,” which PHILLIPS
observed in or around late May 2017.
She followed-up with Human Resources again in or around
June 2017, telling Carpenter that she was still being harassed, intimidated,
and singled out for being a gay woman in her complex, and informing him
that the name calling, graffiti, isolation, and other mistreatment was
continuing. She also specifically advised him that she was being left alone to
take equipment out of service, which is unsafe, and that she was frightened.
Nothing was done to assist PHILLIPS.

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The Retaliation Increases
Having already experienced retaliation based on her
complaints to supervisors and Human Resources, on or about July 6, 2017,
PHILLIPS

notified

EXXONMOBIL’s

Law

Department

about

the

discrimination and retaliation she was experiencing. About a month later, on
or about August 10, 2017, PHILLIPS filed a charge of discrimination and
retaliation with the Equal Employment Opportunity Commission and the
Illinois Department of Human Rights.
Rather than protecting PHILLIPS, the company increased
its discriminatory and retaliatory treatment toward PHILLIPS.
For example, in or about August 2017, PHILLIPS was in a
training meeting with approximately 20 other employees from the pretreater
facility. EXXONMOBIL—knowing that PHILLIPS was already being
retaliated against and referred to as a “rat” for going to Human Resources
with complaints—sent supervisors to take PHILLIPS from the meeting, in
front of all of her coworkers, to be interviewed by Human Resources.
EXXONMOBIL also continued to assign PHILLIPS to work
alongside people who EXXONMOBIL knew physically threatened and
assaulted PHILLIPS. EXXONMOBIL employees at the Joliet Refinery work
in shifts. At the end of a shift, one employee “makes relief” with another who
has been on duty. The employee going off duty is required to update the
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employee coming on duty about what has happened during the shift. Multiple
times, and as recently as August and September 2017, EXXONMOBIL
scheduled PHILLIPS to make relief with the same man described above in
paragraphs 28 to 35, who repeatedly physically assaulted PHILLIPS and
implicitly threatened to kill her.
Likewise, on or about August 9, 2017, another coworker
verbally attacked PHILLIPS. PHILLIPS had asked the coworker about why
he was consistently relieving her late, and he told her specifically and in front
of other male coworkers that he was doing so because she made complaints to
Human Resources. The male coworker became enraged at PHILLIPS and
screamed at her, with words to the effect of “Go the fuck home and get the
fuck out of here bitch!” He also stated that no one at the company supported
PHILLIPS and that she should just leave.
PHILLIPS

reported

this

incident,

including

to

EXXONMOBIL’s Law Department. EXXONMOBIL nevertheless continued
to schedule PHILLIPS to make relief with this individual, including as
recently as September 2017.
This

was

extremely

stressful

and

frightening

for

PHILLIPS. Multiple times, when PHILLIPS saw that she was scheduled to
make relief with men who had threatened and harmed her, she contacted
Human Resources. Human Resources initially declined to intervene, stating
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that PHILLIPS would have a better chance at getting the schedule changed if
she asked on her own. PHILLIPS had to reach out directly to the scheduler
and plead for a favor, to get the schedule changed.
Instead

of

disciplining

PHILLIPS’s

male

coworkers,

EXXONMOBIL took steps to intimidate and harass PHILLIPS. When
PHILLIPS started at EXXONMOBIL five years ago, she had a small side
remodeling business. Although she spends little time on the business, it
continues to exist and has been known to EXXONMOBIL since PHILLIPS
came on board. On or about October 4, 2017, PHILLIPS was called into a
meeting and asked questions about whether she was violating the company’s
conflict-of-interest rules.
Although PHILLIPS’s tiny remodeling business is clearly
not in conflict with the business interests of a global oil company,
EXXONMOBIL employees asked her a number of questions about the
business. It was clear to PHILLIPS that EXXONMOBIL was looking for an
excuse to terminate her.
PHILLIPS Is Seriously Injured
PHILLIPS’s fear of further physical injury from the
systemic harassment and retaliation by her male coworkers was realized in
the early morning hours of October 13, 2017.

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PHILLIPS was using ropes to tow heavy, twenty-foot long
hoses from the ground, up multiple flights, to the top level of a deck. Though
she had repeatedly requested support from her team, her supervisor told her
that no one was available to help her. PHILLIPS spent nearly twelve hours
hauling and connecting the hoses, retrieving and connecting fittings, and
preparing large equipment so that it was safe for other crews to handle—all
without sufficient support.
Near the end of her shift, PHILLIPS, exhausted and
working alone, twisted her ankle in a hole and tripped over the uneven heavy
metal grating.
She fell so hard that her hardhat and wrenches flew, she
broke her radio, and she struck her head on the ground, temporarily blacking
out. When she came to, one of her few female coworkers was standing above
her and tried to help PHILLIPS get back to her feet. When PHILLIPS stood
up, her knee gave out, and she had to be carried down five flights of stairs.
PHILLIPS was taken to the medical complex at the Joliet
Refinery, which is operated by EXXONMOBIL. After a brief examination,
PHILLIPS was told by the EXXONMOBIL nurses that she should not go to
the emergency room or see her own doctor, but instead, go home and come
back to work later that same day for further evaluation by EXXONMOBIL’s
doctor. The EXXONMOBIL nurse sought, in particular, to discourage
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PHILLIPS from going to the emergency room, stating that it would be a long
wait, would not be covered by insurance, and would be unnecessary.
After speaking with her mother, a medical professional,
PHILLIPS went to the emergency room. There, she was examined, informed
that she had a concussion, told she should have gone to the emergency room
immediately, and instructed not to return to work that day.
The following day, PHILLIPS saw her own primary-care
doctor, who said that she should rest and should not return to work in light of
her condition. When PHILLIPS informed the EXXONMOBIL nurse that on
her doctor’s advice, she was resting, in a lot of pain, and would not be in that
day, the nurse questioned PHILLIPS’s professionalism.
PHILLIPS fears that her requests for assistance from her
male coworkers will continue to be ignored going forward, and she will be at
risk of future serious physical injury. This well-founded fear, along with the
other matters described above, causes her significant anxiety and distress
when she has to go to work.

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COUNT I
Discrimination Based on Sex
Title VII
PHILLIPS incorporates the foregoing allegations here.
PHILLIPS is one of the few women working in the
pretreater unit at the Joliet Refinery, and she is the only woman in her crew.
Moreover, she is the only openly gay member of her crew.
Title VII provides that employers may not discriminate
against any individual with respect to her compensation, terms, conditions,
or privileges of employment because of the individual’s sex.
PHILLIPS is an employee of EXXONMOBIL as defined by
Title VII.
EXXONMOBIL is an employer as defined by Title VII.
PHILLIPS has been targeted and harassed because she is a
woman and did not conform to stereotypes about how women should appear
and behave. She has also been targeted and harassed because she is a
lesbian. The discriminatory conduct includes, but is not limited to: verbal
harassment and slurs; explicit and hostile graffiti of a sexual nature; physical
harassment and threats of violence; and denial of opportunities for training,
promotion, and additional compensation.
The actions of EXXONMOBIL were intentional, willful, in
deliberate disregard of, and with reckless indifference to PHILLIPS’s rights.
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As a direct and proximate result of those actions, the terms,
conditions, and privileges of PHILLIPS’s employment were adversely
affected.
As
EXXONMOBIL’s

a

further

unlawful

direct

actions

and

against

proximate

PHILLIPS

result

as

of

described,

PHILLIPS has sustained injuries and damages, including but not limited to
the loss of earnings and earning capacity; physical harm; and mental and
emotional distress, including anxiety, mental anguish, humiliation, and
embarrassment.
COUNT II
Retaliation
Title VII
PHILLIPS incorporates the foregoing allegations here.
PHILLIPS engaged in protected activity when she made
complaints to EXXONMOBIL, including to supervisors and Human
Resources, about harassment and discrimination by her coworkers.
PHILLIPS engaged in protected activity when she filed her
charge of discrimination and retaliation with the EEOC and IDHR.
EXXONMOBIL retaliated against PHILLIPS by the
conduct described above, including but not limited to: repeatedly ignoring her
requests for help; failing to discipline her male coworkers who harassed her;
continuing to assign her to work alongside men who had harassed and
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harmed her; and conducting an unnecessary investigation into her small
remodeling business.
EXXONMOBIL’s actions were intentional, willful, in
deliberate disregard of, and with reckless indifference to PHILLIPS’s rights.
As a direct and proximate result of those actions, the terms,
conditions, and privileges of PHILLIPS’s employment were adversely
affected.
As
EXXONMOBIL’s

a

further

unlawful

direct

actions

and

against

proximate

PHILLIPS

as

result

of

described,

PHILLIPS has sustained injuries and damages, including but not limited to
the loss of earnings and earning capacity; physical harm; and mental and
emotional distress, including anxiety, mental anguish, humiliation, and
embarrassment.
COUNT III
Intentional Infliction of Emotional Distress
PHILLIPS incorporates the foregoing allegations here.
EXXONMOBIL engaged in conduct that was extreme and
outrageous, including but not limited to: assigning PHILLIPS to work in a
blatantly

sexist

and

hostile

work

environment;

condoning

constant

mistreatment of PHILLIPS in the pretreater unit, including by supervisors;
allowing the proliferation of hateful, offensive graffiti throughout the Joliet
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Refinery that targeted PHILLIPS; repeatedly ignoring PHILLIPS’s claims of
harassment and discrimination; failing to discipline those engaging in
misconduct toward PHILLIPS; refusing to take steps to ensure that
PHILLIPS would be safe at the Joliet Refinery; and retaliating against
PHILLIPS.
EXXONMOBIL engaged in this extreme and outrageous
conduct knowing that there was a high probability, or with reckless disregard
of the probability, of causing physical harm, severe emotional distress, and
mental anguish to PHILLIPS.
EXXONMOBIL’s conduct caused severe emotional distress
and physical harm to PHILLIPS.
As a direct and proximate result of EXXONMOBIL’s
conduct, PHILLIPS was harmed and continues to experience physical harm,
severe emotional distress, and mental anguish.
COUNT IV
Negligent Infliction of Emotional Distress
PHILLIPS incorporates the foregoing allegations here.
EXXONMOBIL owed PHILLIPS a duty of care as its
employee. Moreover, EXXONMOBIL knew or should have known that there
was a likelihood of harm to PHILLIPS as a result of the discriminatory,
harassing, and retaliatory treatment by her supervisors and coworkers.
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EXXONMOBIL breached that duty of care by assigning
PHILLIPS to work in a blatantly sexist and hostile work environment;
condoning constant mistreatment of PHILLIPS in the pretreater unit,
including by supervisors; allowing the proliferation of hateful, offensive
graffiti throughout the Joliet Refinery that targeted PHILLIPS; repeatedly
ignoring PHILLIPS’s claims of harassment and discrimination; failing to
discipline those engaging in misconduct toward PHILLIPS; refusing to take
steps to ensure that PHILLIPS would be safe at the Joliet Refinery; and
retaliating against PHILLIPS.
As a direct and proximate result of EXXONMOBIL’s
conduct, PHILLIPS was harmed and continues to experience physical harm,
severe emotional distress, and mental anguish.
COUNT V
Negligent Retention and Supervision
PHILLIPS incorporates the foregoing allegations here.
As

set

forth

above,

PHILLIPS

repeatedly

told

EXXONMOBIL that her male coworkers and supervisors were engaged in
discriminatory and retaliatory conduct, including but not limited to: verbal
harassment and slurs; explicit and hostile graffiti of a sexual nature; physical
harassment and threats of violence; and denial of opportunities for training,
promotion, and additional compensation.
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EXXONMOBIL knew or should have known that the male
coworkers and supervisors were unfit for the positions that they occupied and
created a danger to PHILLIPS and others.
EXXONMOBIL also had a duty to supervise its employees
and did so negligently when EXXONMOBIL allowed PHILLIPS to continue
to be harassed and retaliated against by her male coworkers and supervisors.
As a direct and proximate result of EXXONMOBIL’s
conduct and the retention and supervision of the unfit employees, PHILLIPS
was harmed and continues to experience physical harm, severe emotional
distress, and mental anguish.
WHEREFORE, Plaintiff AMY PHILLIPS requests judgment in her
favor and against EXXONMOBIL, as follows:
a.

Declaratory relief, including but not limited to a declaration that
EXXONMOBIL violated Title VII;

b.

Injunctive

relief,

including

but

not

limited

to

requiring

EXXONMOBIL to enact and implement policies and procedures
to eliminate harassment based on sex and sexual orientation at
the EXXONMOBIL Joliet Refinery;
c.

Compensatory damages in an amount to be determined at trial;

d.

Punitive damages;

e.

Attorneys’ fees, costs, and expenses;
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f.

Pre-judgment and post-judgment interest; and

g.

To grant further relief as this Court should find just and proper.
DEMAND FOR JURY TRIAL

NOW COMES Plaintiff, AMY PHILLIPS, by and through her
attorneys, Salvatore Prescott & Porter, PLLC, and hereby demands a jury
trial in the above-captioned matter.

Dated: October 25, 2017

By:

s/ Julie B. Porter
JULIE B. PORTER
KYLE A. PALAZZOLO
Salvatore Prescott & Porter, PLLC
1010 Davis Street
Evanston, IL 60201
P: (312) 283-5711
F: (312) 724-8353
porter@spplawyers.com
palazzolo@spplawyers.com
Attorneys for Plaintiff

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