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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
-.-. .-. COU'ITY DEPARTWNT, LAW DIVISION
1ren.e Jefferson, As Special Administrator of the >
Estate of Daniellc L&rice Greene, Dcceassed, ) . :
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Plaintiff,
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Epitome Restaurant and Night Cl.ub d/b/a E2, >
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Dwain Kyles, Calvin Hollins, Le Mirage Studio )
Ltd. a/k/a Le Mirage Inc., Leslcy Mot&s, Inc., )
Leslcy Benodin, Envy Entertainment a/k/a, Envy )
Productions, Marco Fl,ores, Team 1 Security, 1
Raph.ael Pellet and the City of Chicago,
a Municipal Corporation, RI" 6022Q2
Defendants;
NOW COMES the Plaintiff, Irene Jefferson, As Special Administrator of the Estate of
I Danitlle L&ice Greene, Deceaxd, by and through her attorneys, Cochran, Cherry, Givens,
Smith & Montgomery3 LLC, and complaining of the Defendants, Epitome Restaurant and
SNIPPETS:
Raph.ael Pellet and the City of Chicago,
NOW COMES the Plaintiff, Irene Jefferson, As Special Administrator of the Estate of
I Danitlle L&ice Greene, Deceaxd, by and through her attorneys, Cochran, Cherry, Givens,
I Nightclub d/b/a E2, Dwain Kyl.es and Calvin
Lesley Benodin, Envy Entertainment a/k/a Envy Pr0ductio.q Marco Flares, Team I Security,
leased, operated, managed, maintained *nd controlled a building at 2347 South Michigan Avenue
known as the Epitome Restaurant and E2 Nightclub in the City of Chicago, COW@ o:l'Cook,
mace an.d/or pepper spray on the patrons present at the aforerhentioned location.
As a result of unknoown security guards spraying mace and/or pcppcr spray on the
The exit doors of Epitome and E2 were locked, blocked and/or barricaded, and, the
result of crushing injuries and/or suffocation during this incideaf at Epitome and.
Al,lowed, permitted and encouraged patrons to enter and gather on the
Nightclub, Drain Kylcs and Calvin HoIlins', negligent acts and/or om.isSions,,
of the Estate of Danielle l&r& Greene, Dcccased,, and pursuant to the 1llinai.s
As a direct and proximate resu.lt of Decedent, Danielle Latrice Greene's death, the
(Defendant Le Mirage Studio Ltd. - Wrongful Death)
Michigan Avenue known as the Epitome Restaurant and E2 Nightclu,b in tb.e Ci,ly of Ch@o,
with over I,100 patrons whw a minor disturbance broke out and unknown security guards used
guilty of one or more of the following careless and negligent acts and/or omissions:
On md prior to February 17,2003, Defendants Lesley Motors, Inc. owned,
Wrongful Death Act, 740 ILCS 1 SO/.01 et sq.
Productions and Marcos Flares - Wrongful Death)
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