{ "id": 4278338, "name": "ABN AMRO SERVICES COMPANY, INC., et al., Plaintiffs-Appellees, v. NAVARRETE INDUSTRIES, INC., d/b/a INS Integrated Security Solutions, Inc., et al., Defendants-Appellants", "name_abbreviation": "Abn Amro Services Co. v. Navarrete Industries, Inc.", "decision_date": "2008-05-01", "docket_number": "Nos. 1-07-0089, 1-07-0606 cons.", "first_page": "138", "last_page": "145", "citations": [ { "type": "official", "cite": "383 Ill. App. 3d 138" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "224 Ill. 2d 182", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3606971 ], "year": 2007, "pin_cites": [ { "page": "211" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/224/0182-01" ] }, { "cite": "214 Ill. 2d 371", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 8451185 ], "year": 2005, "pin_cites": [ { "page": "380" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/214/0371-01" ] }, { "cite": "253 Ill. App. 3d 783", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5425280 ], "year": 1993, "pin_cites": [ { "page": "788" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/253/0783-01" ] }, { "cite": "199 Ill. 2d 325", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 58932 ], "year": 2002, "pin_cites": [ { "page": "341" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/199/0325-01" ] }, { "cite": "102 Ill. App. 3d 558", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3075200 ], "year": 1981, "pin_cites": [ { "page": "566" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/102/0558-01" ] }, { "cite": "128 Ill. App. 3d 437", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3526318 ], "year": 1984, "pin_cites": [ { "page": "444" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/128/0437-01" ] }, { "cite": "254 Ill. App. 3d 1085", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2979509 ], "year": 1993, "pin_cites": [ { "page": "1098" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/254/1085-01" ] }, { "cite": "110 Ill. App. 3d 1133", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2998672 ], "year": 1982, "pin_cites": [ { "page": "1138", "parenthetical": "\" 'No longer do we seek statutory justification for the exercise of jurisdiction; rather the inquiry must be whether there exists a justiciable controversy, and if so, are there any statutory conditions precedent to judicial intervention' \"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/110/1133-01" ] }, { "cite": "119 Ill. App. 3d 1096", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3629894 ], "year": 1983, "pin_cites": [ { "page": "1100" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/119/1098-01" ] }, { "cite": "198 Ill. 2d 541", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 29951 ], "year": 2002, "pin_cites": [ { "page": "566-67" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/198/0541-01" ] }, { "cite": "164 Ill. 2d 54", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 477002 ], "year": 1994, "pin_cites": [ { "page": "60-61" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/164/0054-01" ] }, { "cite": "197 Ill. 2d 514", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 259086 ], "year": 2001, "pin_cites": [ { "page": "522-23" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/197/0514-01" ] }, { "cite": "372 Ill. App. 3d 372", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4269038 ], "year": 2007, "pin_cites": [ { "page": "383" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/372/0372-01" ] }, { "cite": "302 Ill. App. 535", "category": "reporters:state", "reporter": "Ill. App.", "case_ids": [ 3146886 ], "weight": 5, "year": 1939, "pin_cites": [ { "page": "542" }, { "page": "543-44" }, { "page": "543" }, { "page": "543" }, { "page": "543" } ], "opinion_index": 0, "case_paths": [ "/ill-app/302/0535-01" ] }, { "cite": "175 Ill. 2d 166", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 295827 ], "year": 1997, "pin_cites": [ { "page": "171" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/175/0166-01" ] } ], "analysis": { "cardinality": 899, "char_count": 19962, "ocr_confidence": 0.799, "pagerank": { "raw": 4.03580807328026e-08, "percentile": 0.14359099700407243 }, "sha256": "f13445b2028e5f5754818eabd0cca756077935a5b3c3c21c2a3fbdd06e83ef59", "simhash": "1:8f7cb73e76ac4e50", "word_count": 3223 }, "last_updated": "2023-07-14T19:46:05.228492+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "ABN AMRO SERVICES COMPANY, INC., et al., Plaintiffs-Appellees, v. NAVARRETE INDUSTRIES, INC., d/b/a INS Integrated Security Solutions, Inc., et al., Defendants-Appellants." ], "opinions": [ { "text": "JUSTICE MURPHY\ndelivered the opinion of the court:\nOn September 11, 2006, plaintiffs, ABN AMRO Services Co., Inc., LaSalle Bank Corporation, and LaSalle Bank NA, filed a verified complaint for injunctive relief and damages against defendants, Na-varrete Industries, Inc., doing business as INS Integrated Security-Solutions, Inc. (collectively INS), George Konjuch, and Armando and Ana Navarrete (Armando and Ana), the sole shareholders and officers of INS. Plaintiffs sought injunctive relief and damages for an alleged fraud, constructive trust, and civil conspiracy carried out by defendants. Plaintiffs alleged that defendants conducted a massive scheme that caused plaintiffs to pay millions of dollars in fraudulent invoices to INS. Plaintiffs allege that Konjuch then received kickbacks from these fraudulent payments.\nPlaintiffs also filed several motions on September 11, 2006. Following an ex parte hearing on that date, the trial court entered a temporary restraining order (TRO) and an order of statutory prejudgment attachment (attachment order) pursuant to the Code of Civil Procedure (Code) (735 ILCS 5/4 \u2014 101 et seq. (West 2004)). Following notice, expedited discovery, evidentiary hearings and argument, the trial court ultimately dissolved the TRO, denied plaintiffs\u2019 request for a preliminary injunction and denied defendants\u2019 request to vacate the attachment order. The trial court included language pursuant to Illinois Supreme Court Rule 304(a) (210 Ill. 2d R. 304(a)) and defendants appeal the attachment order. For the following reasons, we reverse the findings of the trial court and remand for further proceedings. An abbreviated summary of the facts of this case sufficient to answer the relevant question on appeal follows.\nI. BACKGROUND\nIn August 2006, plaintiffs received allegations that Armando and Konjuch were engaged in a fraudulent billing scheme through INS relating to security services provided to Chicago area LaSalle Bank branches. INS had provided security services to plaintiffs beginning in the 1990s and continuing through the date of this action. Matthew Kutas, a fraud investigator for plaintiffs, undertook an investigation of the allegations involving Konjuch, who was first vice president of physical security at that time.\nAs a result of Kutas\u2019 investigation, plaintiffs filed a verified complaint on September 11, 2006, attaching an affidavit by Kutas that detailed his findings to date. Plaintiffs asserted claims of fraud, civil conspiracy and constructive trust against all defendants and breach of fiduciary duty against Konjuch. They alleged that they were defrauded of more than $15.9 million through defendants\u2019 scheme of fraudulent invoices and kickbacks. Plaintiffs contemporaneously filed motions for a temporary restraining order, a preliminary injunction, and an order of statutory prejudgment attachment, and memoranda of law in support of their motions.\nAlso on September 11, 2006, the trial court reviewed the verified complaint, motions and Kutas\u2019 affidavit and conducted an ex parte hearing. Kutas was not available to testify and only plaintiffs\u2019 counsel and a bank representative were before the court. The trial court found that, due to the sophisticated nature of the alleged fraud and fear that defendants would attempt to abscond with their proceeds from their scheme, proceeding on the motions ex parte was proper. The trial court opined that plaintiffs had presented a sufficient case in support of the requested prejudgment attachment and temporary restraining orders. Prior to entering the orders, the trial court inquired as to whether plaintiffs had secured an attachment bond. Plaintiffs\u2019 counsel responded that they were in the process of securing a bond and that it could be filed later that day. The trial court entered the attachment order. The attachment bond was filed later that day.\nDefendants received notice and copies of the trial court\u2019s ex parte orders on September 12, 2006. Defendants filed motions to vacate the attachment and temporary restraining orders, arguing inter alia that the attachment order was void due to the failure of the plaintiffs and the trial court to comply with the Code. The trial court allowed expedited discovery, and an initial five days of hearing were held for plaintiffs to present their evidence between October 12, 2006, and October 19, 2006. Konjuch and Navarette each exercised their privilege against self-incrimination and did not testify. Following the end of the hearings on plaintiffs\u2019 case on October 19, 2006, the trial court found that plaintiffs had presented a prima facie case of fraud and met the requirements of paragraphs 7 and 8 of section 4 \u2014 101 of the Code (735 ILCS 5/4 \u2014 101 (West 2004)) to support the attachment order.\nThe trial court dissolved the temporary restraining order and dismissed plaintiffs\u2019 motion for a preliminary injunction. The trial court also heard arguments on Konjuch\u2019s motion for a directed finding on the motion to quash the attachment order. The trial court denied that motion. A written order memorializing these findings was entered on October 23, 2006.\nFurther hearings were held in November 2006 for defendants to present their own witnesses. As noted above, Konjuch and Armando declined to testify. INS employees and financial experts testified for defendants and Konjuch also recalled Kutas to testify in his case. Following presentation of a certified fraud examiner as their rebuttal witness, plaintiffs rested. The trial court denied defendants\u2019 motions to vacate the attachment order. The trial court included language pursuant to Rule 304(a) that there was no just reason to delay appeal in its December 21, 2006, order. These consolidated appeals followed.\nII. ANALYSIS\nDefendants assert several issues on appeal; however, this case may be disposed of based on the plain language of the Code and an examination of Konjuch\u2019s motion to vacate the attachment order. Konjuch argued that the attachment order was void for the trial court\u2019s failure to examine any witness under oath regarding the amount required for bond and for plaintiffs\u2019 failure to file an attachment bond before the order was entered. While case law is limited on this issue, Konjuch argues that the cases that have examined the issue and the plain language of sections 4 \u2014 104 and 4 \u2014 107 of the Code clearly require reversal of the attachment order. We review de novo the issue of the proper construction and interpretation of a statute in considering the issue of the filing of the attachment bond in this case. Lucas v. Lakin, 175 Ill. 2d 166, 171 (1997).\nSection 4 \u2014 107 reads in full:\n\u201cBond. Before the entry of an order for attachment, as herein-above stated, the court shall take bond and sufficient security, payable to the People of the State of Illinois, for the use of the person or persons interested in the property attached, in double the sum sworn to be due, conditioned for satisfying all costs which may be awarded to such defendant, or to any others interested in the proceedings, and all damages and costs which shall be recovered against the plaintiff, for wrongfully obtaining the attachment order, which bond, with affidavit of the party complaining, or his, her or its agent or attorney, shall be filed in the court entering the order for attachment. Every order for attachment entered without a bond and affidavit taken, is hereby declared illegal and void, and shall be dismissed. Nothing herein contained shall be construed to require the State of Illinois, or any Department of Government thereof, or any State officer, to file a bond as plaintiff in any proceeding instituted under Part 1 of Article IV of this Act.\u201d 735 ILCS 5/4 \u2014 107 (West 2004).\nKonjuch argues that the \u201cclear and unequivocal language\u201d of this section provides the mandatory command to file a bond in that amount before an attachment order is entered. Konjuch argues that the legislature could not have been clearer in wording this statute \u2014 if a bond is not filed before entry of an attachment order, the order is to be declared \u201cillegal and void, and shall be dismissed.\u201d Konjuch argues that attachment of one\u2019s property, especially ex parte, is an extraordinary remedy and requires strict adherence to the statute.\nKonjuch notes that this court has stated that the purpose of section 4 \u2014 107 is to protect the debtor. Western Smelting & Refining Co. v. Benj. Harris & Co., 302 Ill. App. 535, 542 (1939). The Western Smelting court concluded that the trial court in that case did not have jurisdiction to enter an attachment order because the plaintiff did not comply with the statute and did not have a bond filed. Western Smelting, 302 Ill. App. at 543-44. The court further noted that if a creditor were allowed to secure an attachment order without filing a bond, \u201cthere would be grave danger of fraud\u201d and open the debtor to harms that the statute was intended to prevent from occurring. Western Smelting, 302 Ill. App. at 543.\nPlaintiffs respond that Konjuch waived these \u201calleged procedural errors\u201d by failing to raise them in the trial court. However, plaintiffs also later note that the failure to timely file a bond was Konjuch\u2019s first argument in his motion to vacate the attachment order. While the record supports plaintiffs\u2019 argument that Konjuch did not fully develop this claim in a memorandum of law or during oral argument, the fact remains that the argument was raised and rejected. Furthermore, the issue of voidness may be raised directly or collaterally so long as it is raised within a proceeding properly pending in the courts. Universal Underwriters Insurance Co. v. Judge & James, Ltd., 372 Ill. App. 3d 372, 383 (2007). As noted above, this matter is properly before this court on appeal and the issue of voidness may be considered. Accordingly, discussion must turn to plaintiffs\u2019 other arguments that Konjuch\u2019s argument fails.\nPlaintiffs assert that the challenges to the initial attachment order are moot because of the subsequent actions in the trial court. Plaintiffs state that an appeal is moot when there is no actual controversy or no effectual relief may be granted to the complaining party. Steinbrecher v. Steinbrecher, 197 Ill. 2d 514, 522-23 (2001). Plaintiffs argue that Konjuch\u2019s claim that the attachment order is void is moot because the trial court also entered the temporary restraining order at the same time, freezing the same funds. Accordingly, plaintiffs conclude that affirming the attachment order after a full evidentiary hearing and argument renders challenges to the initial ex parte order moot.\nPlaintiffs also argue that the plain language of the Act supports their mootness argument. Plaintiffs highlight that section 4 \u2014 132 of the Code provides that, subject to the prompt hearing requirements of the Act, no attachment order \u201cshall be vacated *** on account of any insufficiency of the original affidavit, order for attachment or attachment bond, if the plaintiff, or some credible person for him, her or it shall cause a legal and sufficient affidavit or attachment bond to be filed, or the order to be amended, in such time and manner as the court shall direct; and in that event the cause shall proceed as if such proceedings had originally been sufficient.\u201d 735 ILCS 5/4 \u2014 132 (West 2004). Plaintiffs argue that this language demonstrates that the legislature understood that this type of proceeding would often be executed on an emergency basis and, as such, errors would occur that could, and should, be cured by amendment.\nIn addition, plaintiffs argue that with the additional evidence provided during the hearings, the doctrine of aider by verdict renders these challenges moot. The doctrine of aider by verdict provides that if a party allows an action to proceed to verdict, the verdict cures technical and clerical errors as well as defective allegations of essential facts. Adcock v. Brakegate, Ltd., 164 Ill. 2d 54, 60-61 (1994). Therefore, plaintiffs argue that the full hearings and final attachment order preclude review of any alleged procedural or technical defects.\nFinally, plaintiffs argue that Konjuch\u2019s alleged procedural arguments misstate the law and fail to allege any prejudice. Plaintiffs argue that litigants are not entitled to error-free trials and a party asserting an error must demonstrate the error affected the outcome with a clear showing of prejudice. Simmons v. Garces, 198 Ill. 2d 541, 566-67 (2002). Plaintiffs continue to argue that the circuit court is vested with general jurisdiction pursuant to the Judicial Article of 1962 and the Illinois Constitution of 1970. Thus, there were no jurisdictional obstacles as the instant matter is a justiciable issue. See McGinnis Plumbing Co. v. Zeus Development Corp., 119 Ill. App. 3d 1096, 1100 (1983), quoting In re Estate of Mears, 110 Ill. App. 3d 1133, 1138 (1982) (\u201c \u2018No longer do we seek statutory justification for the exercise of jurisdiction; rather the inquiry must be whether there exists a justiciable controversy, and if so, are there any statutory conditions precedent to judicial intervention\u2019 \u201d). Accordingly, plaintiffs argue that Konjuch and the other defendants\u2019 framing of issues as jurisdictional is incorrect and the failure to show any prejudice from filing the bond after entry of the attachment order requires affirming the trial court.\nPlaintiffs contend that section 4 \u2014 107 of the Code \u201cmerely states that \u2018[b]efore the entry of an order for attachment, as herein above stated, the court shall take bond *** for the use of the person or persons interested in the property attached, in double the sum sworn to be due. 735 ILSC [sic] 5/4 \u2014 107.\u2019 \u201d They continue to argue that section 4 \u2014 108 provides an alternative ex parte procedure of fixing the bond at a lower value based on a value of attached property that is lower than the amount sworn due. Accordingly, plaintiffs conclude that the Code does not even require fixing the bond before entering an attachment order in ex parte proceedings and Konjuch has relied upon the wrong section of the Code.\nFirst, we must note that the Code requires construing the statute in \u201cthe most liberal manner for the detection of fraud.\u201d 735 ILCS 5/4 \u2014 102 (West 2004). Despite that mandate, undertaking a liberal construction of a statute does not allow a court to ignore unequivocal and plain language within that statute. The language of section 4 \u2014 107 clearly requires filing of bond prior to entry of an attachment order. Every order that is entered without such a bond filed \u201cis hereby declared illegal and void, and shall be dismissed.\u201d 735 ILCS 5/4 \u2014 107 (West 2004). It is impossible to read this out of the statute as plaintiffs have argued.\nBecause section 4 \u2014 108 follows section 4 \u2014 107, it does not mean that the preorder filing requirement is removed. This court has found that it is apparent that section 4 \u2014 108 is simply for the benefit of a creditor with a claim larger than the value of property that is being attached and must be read in conjunction with section 4 \u2014 107. Old Kent Bank v. Stoller, 254 Ill. App. 3d 1085, 1098 (1993). Section 4 \u2014 108 provides an alternative method of fixing the bond, not filing the bond. Accordingly, construing the sections in conjunction, the filing requirement remains and section 4 \u2014 108 simply provides a plaintiff with the protection of securing a lower bond when the attached property value warrants.\nWhile aider by verdict avoids the waste of judicial and party resources as argued by plaintiffs, they also note that it is limited to when the defect argued could have been cured by amendment. Pieszchalski v. Oslager, 128 Ill. App. 3d 437, 444 (1984). The statute also provides for this type of scenario in section 4 \u2014 132. However, Konjuch\u2019s key claim is that the attachment order was entered prior to the filing of bond and plaintiffs cannot amend something that does not properly exist.\nThe plain language of the statute requires the dismissal of the order as void when an order is entered without prior filing of sufficient bond. The plain language does not allow for amendment to cure the fatal failure to file bond before entering the order. \u201c \u2018[I]f a statute prescribes in terms that acts or proceedings shall be void if they are not done in the manner set out in the statute, the statutory prescription is obviously mandatory.\u2019 \u201d Havens v. Miller, 102 Ill. App. 3d 558, 566 (1981), quoting 2A C. Sands, Sutherland on Statutory Construction \u00a757.08, at 423 (4th ed. 1973).\nWe are mindful of our supreme court\u2019s recent admonishments that courts must declare an order void only when no other alternative is possible \u201c \u2018[b]ecause of the disastrous consequences which follow when orders and judgments are allowed to be collaterally attacked.\u2019 \u201d Belleville Toyota, Inc. v. Toyota Motor Sales, U.S.A., Inc., 199 Ill. 2d 325, 341 (2002), quoting In re Marriage of Vernon, 253 Ill. App. 3d 783, 788 (1993); see also Ford Motor Credit Co. v. Sperry, 214 Ill. 2d 371, 380 (2005); J.S.A. v. M.H., 224 Ill. 2d 182, 211 (2007). These cases each considered the vast jurisdiction granted to our circuit courts by the Illinois Constitution of 1970 as highlighted by plaintiffs and their quote of McGinnis Plumbing Co. However, plaintiffs quoted this expansive take on jurisdiction to summarily dismiss Konjuch\u2019s voidness argument and jump to an assertion that Konjuch must prove that he was prejudiced by the procedural failure. We obviously disagree that the plain language may be overcome and that some \u201cother alternative is possible.\u201d\nAs detailed in Western Smelting, without requiring this procedure, allowing an attachment creditor to wait to file bond would itself open up a grave danger of fraud. Western Smelting, 302 Ill. App. at 543. The bond is for the protection of the debtor in the event of judgment against the creditor. The Western Smelting court also opined that the intent of section 4 \u2014 132 was to allow an attachment creditor to cure clerical and other deficiencies in the bond \u201cwhere there has been a bona fide attempt to comply with the statute.\u201d Western Smelting, 302 Ill. App. at 543.\nUnfortunately, the result of declaring the order void results in a waste of resources in this case. While plaintiffs clearly attempted to comply with the statute, they failed to do so. This issue could not be resolved by simple amendment because of the absolute mandatory command of the statute; therefore, the mootness and aider by verdict doctrines do not apply. The order is simply void. A liberal construction of the Code cannot cure this defect and the order must be dismissed. The legislature had a clear and valid reason for providing this strict procedural requirement and denying a collateral attack in this instance could open up the possibility of future collateral arguments that would eviscerate the protections provided to debtors by the legislature.\nIII. CONCLUSION\nFor the foregoing reasons, we reverse the decision of the trial court and remand for further proceedings.\nReversed and remanded.\nNEVILLE, P.J., and CAMPBELL, J., concur.", "type": "majority", "author": "JUSTICE MURPHY" } ], "attorneys": [ "Patrick C. Dowd, Michael G. Patrizio, and Jane E. Hughes, all of Dowd & Dowd, Ltd., of Chicago, for appellant Ana Navarrete.", "Gemma B. Dixon, of Law Offices of Gemma B. Dixon, of Chicago, for appellants Navarrete Industries, Inc., and Armando Navarrete.", "Edward L. Schuller and Kevin Quinn Butler, both of Edward L. Schuller, Ltd., and Kevin Quinn Butler and Cornelius E. McKnight, both of McKnight, Kitzinger, McCarty & Pravdic LLC, both of Chicago, for appellant George Konjuch.", "Marta A. Stein, Gary L. Starkman, and John A. Leja, all of McGuire Woods LLP of Chicago, for appellees." ], "corrections": "", "head_matter": "ABN AMRO SERVICES COMPANY, INC., et al., Plaintiffs-Appellees, v. NAVARRETE INDUSTRIES, INC., d/b/a INS Integrated Security Solutions, Inc., et al., Defendants-Appellants.\nFirst District (4th Division)\nNos. 1\u201407\u20140089, 1\u201407\u20140606 cons.\nOpinion filed May 1, 2008.\n\u2014 Rehearing denied July 15, 2008.\nPatrick C. Dowd, Michael G. Patrizio, and Jane E. Hughes, all of Dowd & Dowd, Ltd., of Chicago, for appellant Ana Navarrete.\nGemma B. Dixon, of Law Offices of Gemma B. Dixon, of Chicago, for appellants Navarrete Industries, Inc., and Armando Navarrete.\nEdward L. Schuller and Kevin Quinn Butler, both of Edward L. Schuller, Ltd., and Kevin Quinn Butler and Cornelius E. McKnight, both of McKnight, Kitzinger, McCarty & Pravdic LLC, both of Chicago, for appellant George Konjuch.\nMarta A. Stein, Gary L. Starkman, and John A. Leja, all of McGuire Woods LLP of Chicago, for appellees." }, "file_name": "0138-01", "first_page_order": 154, "last_page_order": 161 }