Medical Malpractice Motion 15 - motion for attorneys fees

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Plaintiffs' Petition for Attorneys' Fees and Expenses Pursuant to Illinois Supreme Court Rule 137

Cates, Kurowski, Bailey, & Shultz LLC, Judy L. Cates #00414743, Attorney for Plaintiffs, 24 Bronze Pointe, Swansea, Illinois 62226, Telephone: (618) 277-5500, Facsimile: (618) 277-6334.

Come now the plaintiffs, by and through their attorney, Judy L. Cates and herewith file Plaintiffs' Petition For Attorneys' Fees And Expenses Pursuant To Illinois Supreme Court Rule 137 (“Petition for Expenses.”) The filing of this Petition is supplemental to Plaintiffs' Motion For Sanctions previously filed herein and is offered in accordance with this Court's Order of March 17, 2004. 1 In support of their Petition For Expenses plaintiffs submit the following:

SUMMARY OF EVENTS

As this Court is well aware, plaintiffs filed a medical negligence complaint against Protestant Memorial Medical Center d/b/a Memorial Hospital of Belleville (“Memorial Hospital”) and eight hospital nurses on February 3, 2000. The event out of which the lawsuit arose occurred on the night of February 24, 1999, when the decedent,Joyce Cretton, was transferred from Memorial Hospital's ICU unit to the IMCU unit. Plaintiffs alleged that Memorial Hospital, by and through its agents' servants and employees, deviated from the standard of care: I) in negligently and carelessly transferring Joyce Cretton to her IMCU bed; 2) in negligently and carelessly failing to afford adequate assistance for the transfer ; 3) in negligently and carelessly allowing Joyce Cretton to fall during the transfer ; and 4) in negligently and carelessly failing to inform anyone of Joyce Cretton's fall during the transfer. (See Complaint, ¶6 attached herewith as “Exhibit I.”)

Attorney Doreen Graham and the law firm of Moser and Marsalek, P.C., filed their entry of appearance for all named defendants on March 6, 2000. On April 3, 2001, plaintiffs served their First Interrogatories To Defendants and First Request For Production To Defendants. At that time, plaintiffs submitted the following interrogatory:

25. Please Identify by full name, current (or last known) residence address and current employer of the nursing supervisor at defendant hospital known as Phil (last name unknown) who discussed the problems encountered during the transfer of decedent from the ICU to the IMCU on February 24, 1999 with plaintiff, Cheryl Creton.

This interrogatory was specifically crafted in an effort to determine the identity of a nursing supervisor. Plaintiff, Cheryl Crotton, had spoken with this supervisor shortly after her mothe Joyce reported having been dropped during the transfer process. This reported conversation by Cheryl Cretton was well known even at the outset of the litigation.

Memorial Hospital answered plaintiffs' interrogatories on July 19, 2001. In response to plaintiffs' interrogatory number 25, Memorial Hospital answered as follows:

Memorial denies that the substance of the conversation was as described in this interrogatory and theonly nursing supervisor named Phil is Phillip Schorfheide who is no longer employed at Memorial. His last known address is 9801 Roanoke Parkway, Kansas City, MO 64112. His current employer is Truman Medical Center. (Emphasis added.)

The Answers To Plaintiffs' First Interrogatories were signed by Doreen Graham, the attorney of record for the hospital. More importantly, the pleading was verified under oath by Terry Walther an authorized agent of Memorial Hospital.

Accompanying Memorial Hospital's July 19, 2001, interrogatory answers was a privilege log. (See Privilege Log Of Protestant Memorial Medical Center, Inc. submitted herewith as “Exhibit 2.”) The pleading was signed by Margaret Lowery, General Counsel for Memorial Hospital. This privilege log purported to identify several documents claiming a privilee under the Medical Studies Act. 2

Of special note for this Petition For Expenses arc documents 21-22 of the privilege log.3 These documents were not disclosed by Ms. Lowery and were described by counsel for Memorial Hospital as follows:

Note: Text of footnote 3 missing in original document

QMCS request for information & typewritten notes from unknown author.

The deposition of Cheryl Cretton was next taken on July 24, 2001. In her deposition, Cheryl Cretton described the conversation with the nursing supervisor named “Phil.” Ms. Cretton described that conversation in detail and testified that she told “Phil” about the allegation of the fall during the transfer process. (See pages 80 84 of the deposition of Cheryl Cretton, submitted herewith as “Exhibit 3.”)

On August 14, 2001, Greensfelder, Hemker & Gale, P.C. and Edward S. Bott, Jr. entered their appearance for all named defendants. Plaintiffs filed a Motion To Compel the production of the privileged documents on August 31, 2001. 4 (See Plaintiffs' August 31, 2001, Motion To Compel, attached herewith as “Exhibit 4.”) A hearing was held on September 6, 2001 pursuant to plaintiffs' Motion. The judge assigned to the case at that time, Stephen Kerman, ordered, in part, that Memorial Hospital submit further documentation to plaintiffs in support of the privilege log.

In the meantime, the deposition of Phillip Schorfheide was taken on September 25, 2001. 5 Although Phillip Schorfheide was no longer employed by Memorial Hospital, Mr. Bott and Ms. Lowery met privately with Phillip Schorfheide prior to the deposition. Mr. Bott and Ms. Lowery prepared Mr. Schorfheide for his deposition. Mr. Bott defended Mr. Schorfhide at the deposition. (See Deposition of Phillip Schorfheide taken September 25, 2001, attached herewith as “Exhibit 5.”)

When plaintiffs' counsel initially questioned Phillip Schorfheide regarding the conversation which Cheryl Cretton claimed to have had with Mr. Schorfheide. Mr. Bott directed him to the privilege log. This is proof that Mr. Bott was well aware of the documents contained within that file. When specifically asked whether Cheryl Cretton had ever made an allegation that her mother had been dropped during the transfer process Phillip Schorfheide repeatedly stated throughout his deposition. that he was never informed of an allegation that Joyce Cretton had fallen or been dropped. (This was lie. Moreover, Mr. Bott and Ms. Lowery knew Mr. Schorfheide was lying Nevertheless, neither of these attorneys took any action to correct the record then or any time thereafter.)

On October 9, 2001. pursuant to the Order previously entered by Judge Kan regarding supplemental information, Mr. Bott, on behalf of Memorial Hospital, filed the affidavit of hospital employee, Kerry Wrigley. This affidavit stated that the Quality Management Council Subcommittee which conducted the peer review process related to the death of Joyce Cretton was initiated “on or about March 3, 1999.” 6 That affidavit also specifically stated, inter alia, that “documents Bates numbered P 21-22...arthor.

Plaintiffs' counsel has been actively litigating medical negligence cases since 1982. In that time period, plaintiffs' counsel has never had reason to believe that the personnel at the Memorial Hospital of Belleville would engage in any form of dishonesty, In fact, throughout the years, plaintiffs' counsel was familiar with Terry Walther and had been involved in cases with both Doreen Graham and Edward S. Bott. Jr. Therefore, plaintiffs' counsel did not challenge any of the affidavits filed on behalf of Memorial Hospital. Instead, plaintiffs' counsel relied on the sworn affidavits and representations of the attorneys representing the defendant, Memorial Hospital.

Plaintiffs' counsel continued to prepare this case for trial during the following two years. As the Court aptly notes in its March 17. 2004 Order 7 : “[P]aintiffs were preparing their case without knowledge of the false carly disclosures and unaware of the lies told by Schorftheide in deposition....There were no red flags that would alert the plaintiff to call for an in camera review of the sequestered documents.” See Exhibit 8. page 12.

At the July 17, 2003 pre-trial conference, the issue of the Cheryl Cretton/Phil conversation was raised in pretrial motions. The hospital filed a motion in limine to keep out the alleged statements which Cheryl Cretton had made to Phil. At the July 17. 2003, hearing. Judge LeChien (the judge who was assigned to the case after Judge Keman retired) specifically asked Mr. Bott whether Memorial Hospital disputed the statements made by Cheryl Cretton to Phil Schorfheide with regard to whether her mother “fell or was dropped or was injured.” In response, Mr. Bott replied. “Yes.” Moreover, Judge LeChien then specifically inquired whether Mr. Bott had read the QMCS file to support his representations. When the Court asked Mr. Bott if he had looked at the QMCS documents related to his question. Mr. Bott also replied, “Yes.” (See July 17, 2003, Report of Proceedings, attached herewith as “Exhibit 9, page 16, lines 23-24 and page 17, lines-20.)

As this Court is well aware, plaintiffs requested an in camera review of the documents claimed as privileged. The Court, as a part of the pretrial process, ordered the production of the documents claimed as privileged. It was during that document production that this Court “exposed the hospital's discovery subterfuge.” (See Exhibit 8, page 13.)

Once the Court reviewed documents #21 and #22, which had been described in the Privilege Log, the Court immediately determined that the hospital “knew the testimony of [Phillip Schorfheide] was a lie and [the hospital had] failed in its obligation [to] correct the perjury.” (See Exhibit 8, page 13.) More specifically, the Court found that certain portions of documents #21 and #22 were not privileged by the Medical Studies Act and released those portions to the plaintiffs. The Court also determined that the name “Phil” appeared on document #22. When considered with the other documents contained in the file, as well as the reported conversation which Cheryl Cretton had described from early on in the litigation, the Court could easily conclude that “Phil” was the author of documents #21 and #22. In other words, the representation that these documents were by an “unknown author” was absolutely untrue. Upon revelation of the truth, plaintiffs' counsel immediately moved for sanctions. In an attempt to “undue” the prejudice to plaintiffs' the Court imposed sanctions against the hospital.

Trial commenced on August 4. 2003. During trial, Phillip Schorfhcide's testimony had to be corrected from his prior deposition. Additionally, plaintiffs' counsel was never quite sure whether the hospital witnesses would continue with the testimony given during their depositions, or change their testimony to reflect the “corrected” account of Phillip Schorfheide. At the conclusion of the evidence, the jury returned a verdict in favor of the plaintiffs on the survival action only, awarding plaintiffs $950,000.00.

Prior to the jury's verdict, plaintiffs filed their Motion For Sanctions Pursuant to Illinois Supreme Court Rules 137 and 219(c). Pursuant to that motion, this Court has held numerous hearings. At the conclusion of the hearings' this Court entered its Order on March 17, 2004 and has allowed plaintiffs leave to supplement the record in support of plaintiffs' request for attorneys' fees and expenses.

I. Illinois Law Supports An Award Of Attorneys' Fees and Expenses for a Violation Of Illinois Supreme court Rule 137.

This Court has already entered an Order finding a violation of Illinois Supreme Court Rule 137. 8 Rule 137 provides, in pertinent part:

If a pleading, motion, or other paper is signed in violation of this rule, the court, upon motion or upon its own initiative, may impose upon the person who signed it, a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of reasonable expenses incurred because of the filing of the pleading, motion or other paper, including a reasonable attorney fee. [Emphasis added.]

Rule 137 “serves to penalize the litigant or attorney who pleads false or frivolous matters, or who brings suit without any basis in the law.” In Re Marriage of Schneider, 298 III.App.3d 103, 697 N.E.2d 1161, 232 Ill.Dec. 231 (1st Dist. 1998). When making a determination of monetary sanctions pursuant to Rule 137, the trial court must consider the following: I) the degree of bad faith by the opposing party, 2) whether an award of fees could deter others from acting under similar circumstances; and 3) the relative merits of the parties' positions. See Penn v. Gerig, 334 III.App.3d 345, 354, 778 N.E.2d 325, 333. 268 Ill.Dec. 339, 347 (4th Dist. 2002). Plaintiffs bear the burden of presenting sufficient evidence from which the Court can render a decision as to the reasonableness of the requested fees and expenses.See Chicago Title & Trust Co. Trustee Under Trust No. 89-044884 v. Chicago Title & Trust Co Trustee No. 1092636, 248 Ill.App.3d 1065, 1072, 618 N.E.2d 949, 954, 188 Ill.Dec. 379, 384 (1st Dist. 1993).

When considering whether to award attorneys' fees, the “reasonableness” of attorneys' fees is generally determined by several factors. “In assessing the reasonableness of fees, the trial court should consider a variety of factors, including the skill and standing of the attorneys employed, the nature of the case, the novelty and difficulty of the issues involved, the degree of responsibility required, the usual and customary charge for the same or similar services in the community, and whether there is a reasonable connection between the fees charged and the litigation.” Clay v. County of Cook, 325 III.App.3d 893, 902, 759 N.E.2d 6, 13, 259 Ill.Dec. 526, 533 (1st Dist. 2001). (Citation omitted.)

In Illinois, contingency fees for attorneys in medical malpractice actions are governed by 735 ILCS 5/2-1114 Under subparagraph (a), the statute states:

In all medical malpractice actions the total contingent fee for plaintiff's attorney or attorneys shall not exceed the following amounts:

33 1/3% of the first $150,000 if the sum recovered;

25 % of the next $550.000 of the sum recovered;

20% of any amount recovered over $1.000,000 of the sum recovered.

Subparagraph (c) of that section allows the statutory sliding scale to be amended based on attorney performance:

(c) The court may review contingent fee arrangements for faimess. In special circumstances, where an attorney performs extraordinary services involving more than usual participation in time and effort the attorney may apply to the court for approval of additional compensation.

735 ILCS 52-1114(c).

The Fifth District has held that for purposes of determining statutory attorney fees, “the term ‘reasonable’ applies regardless of the nature of the client's contractual relationship with his attorney.” Blankenship v. Dialist International Corp., 209 III App.3d 920, 927, 568 N.E.2d 503, 507, 154 III.Dec. 503, 507 (5th Dist. 1991).However, courts are to consider the contractual fee arrangement between the attorney and client as only one factor in the determination. Id.In Blankenship, the court reviewed the trial court's award of the contingency fee contract amount of 33 1/3 % of the plaintiffs total award in conjunction with noting the high level of expertise and the amount of work performed by the plaintiff's attorneys. This Court then stated that they did “not feel that the trial court abused its discretion in awarding the contingency fee amount of $5000 as reasonable attorney fees.” Id. (Emphasis added.)

In other cases awarding attorneys' fees, the court's reliance on contingency fee contracts was not considered to be arbitrary. See e.g. Dunn v. Illinois Central Gulf Railroad Co., 215 Ill.App.3d 190, 202, 574 N.E.2d 902, 910, 158 Ill.Dec. 789, 797 (4th Dist. 1991). “In those instances where a contingency fee represents the standard remuneration for the type of case involved, the contingency fee may adequately serve as the final award.” Renken v. Northern Illinois Water Co., 191 Ill.App.3d 744, 750. 547 N.E.2d 1376, 1380, 138 Ill.Dec. 755, 759 (4th Dist. 1989).

II. This Court Should Award a Reasonable Attorney Fee And The Expenses Incurred To Date.

As noted previously, when making a determination of monetary sanctions pursuant to Rule 137, this Court must consider the following: 1) the degree of bad faith by the opposing party, 2) whether an award of fees could deter others from acting under similar circumstances; and 3) the relative merits of the parties' position. Penn supra. This Court has already made explicit findings related to the bad faith of the hospital and its lawyers. The Court specifically found that nothing short of conscious disregard and utter indifference for the truth explains how the hospital could make the connection between Cheryl Cretton and Phil Schorfeid but fail to associate him with his notes. 9 The Order entered by this Court on March 17, 2004 further describes the violation of Rule 137 as “unvarnished fabrication.” “a meritless privilege objection,” “corruption of the self-evaluation process, “perpetuation] the chaos of the early discovery censorship,” “discovery subterfuge,” and “perjury,” to name a few. (See Exhibit 8.) Clearly, the degree of bad faith in this case went far beyond mere mistake and was in intentional act of misconduct.

Hopefully, this Court's award of attorneys' fees would act as a strong deterrent against this kind of misconduct in the future. Penalizing the attorneys by an award of fees and expenses would send a strong message that the Rules enacted by the Illinois Supreme Court were designed to protect against abuse.

Finally, there can be no doubt about the relative merits of the parties' positions. Plaintiffs can only reiterate that the sanctionable misconduct of the Memorial Hospital attorneys began as far back as the initial discovery stages of this litigation, when plaintiffs first propounded the interrogatory inquiring about Cheryl Cretton's conversation with nursing supervisor “Phil.” As stated above, Memorial Hospital's false pleading in response to plaintiffs' interrogatory was filed on July 19, 2001 - almost three years ago, and only three months after counsel Doreen Graham entered her appearance for Memorial Hospital. Also accompanying Memorial Hospital's discovery responses at that time was the false privilege log, signed by Margaret Lowery, in-house general counsel for Memorial Hospital, and verified under oath by a hospital representative. In essence, there was utter disregard for the rules.

Moreover, it is also important to note that Edward S. Bott Jr. entered his appearance on behalf of Memorial Hospital just one month after the false discovery responses were filed. Nevertheless, in the ensuing period of time between August 2001 and August 2003, Mr. Bott never sought to correct the fraudulent pleadings. Instead, Mr. Bott joined the conspiracy, accepting the party-line that the Cretton/Schorfheide conversation never occurred.

As the Court stated in its March 17, 2004 Order, the “pervasiveness” of Memorial Hospital's misconduct “had its genesis in the July, 1999 discovery fraud and falsity.” See Exhibit 8, page 14. Therefore, this Court should award reasonable attorneys' fees and all expenses incurred to prepare this litigation for trial.

Once the Court determines it should award attorneys fees and expenses, the next inquiry is how to determine a fair amount. Illinois law clearly allows an award of a “reasonable fee.” As noted previously, the Court looks at several factors, “including the skill and standing of the attorneys employed, the nature of the case, the novelty and difficulty of the issues involved, the degree of responsibility required, the usual and customary charge for the same or similar services in the community, and whether there is a reasonable connection between the fees charged and the litigation.” Clay v. County of Cook, 325 III.App.3d 893, 902, 759 N.E.2d 6, 13, 259 Ill.Dec. 526, 533 (1st Dist. 2001). (Citation omitted.) More importantly, “[t]he trial judge is permitted to use his own knowledge and experience to assess the time required to complete particular activities....” Id.

With regard to the first inquiry, this Court is well aware that the litigation at issue was a medical malpractice claim. Plaintiffs' counsel is one of handful of practitioners in southern Illinois who has the experience and expertise in handling these kinds of matters. (See Affidavit of Judy L. Cates submitted herewith as “Exhibit 10.”) Such litigation, in and of itself, is more complicated and requires a higher level of litigation experience. Special rules enacted by the Illinois legislature require expert review prior to filing the litigation. The political climate for medical malpractice cases over the past few years has made successful prosecution of the claims more difficult.

More importantly, in this case, there were significant obstacles regarding proof of the event claimed to have occurred by Joyce Cretton. i.e., the fall during transfer. Joyce Crotton, the victim who claimed she had been dropped, had died. By the time plaintiffs were able to determine the name of the roommate who allegedly reported the incident to Cheryl Cretton, that roommate had also died. The hospital personnel claimed no knowledge of the incident. More importantly, the medical record did not contain any mention of such an incident. Therefore, plaintiffs' counsel was left with the problem of proving that Joyce Cretton had been dropped or had fallen during the transfer from ICU to IMCU based on the statement of Cheryl Crotton and the finding of a subdural hematoma at autopsy. 10

The plaintiffs task was even more difficult as a result of the hospital's cover up of the evidence. As the Court noted in its March 17.2004 Order. “[t]he impact on the case was massive.” See Exhibit 8, page 14. Plaintiffs' counsel undertook a significant responsibility in preparing the case for trial and faced great risk in losing the litigation.

As a result of the hospital's cover-up. counsel for plaintiffs prepared this case with the idea that no evidence of the allegation existed. It is impossible for plaintiffs' counsel to segregate the work that was done on the Crotton litigation as a result of Memorial Hospital's fraudulent and false pleadings from the work that may not have involved the hospital's fraudulent and false pleadings. More than two years of work on this case went by from the time the discovery responses and privilege log were filed to the time of trial, when plaintiffs first became aware that a violation had occurred. As a result, the false discovery responses filed by Memorial Hospital became so inextricably connected to the way in which this litigation advanced to trial, that an effort to single out plaintiff

Additionally, an effort to substantiate the time spent working on the Cretton case leading up to and including trial is rather difficult. Like most attorneys that handle medical malpractice cases, counsel for plaintiffs represented the Crotton family based on a contingency fee agreement. Unlike other attorneys that may keep their time records so that clients may be billed for services rendered, plaintiffs' attorneys do not generally keep a record of time spent on a case - as they are only compensated if they succeed in obtaining a favorable result for their client(s), not on time spent. This type of arrangement is the common business practice of counsel for plaintiffs and was the practice in this case.

Moreover, the Illinois legislature has presumptively determined a “reasonable” fee in medical malpractice cases. As stated above, the jury in this case returned a verdict in favor of the plaintiffs in the amount of $950,000.00 for the survival action only Therefore, based solely on the sliding scale of Section 5/2-1114, the statutory attorney fee would be calculated as follows:

$150,000.00 * 33 1/3%

$ 49,950.00

$800,000.00 * 25%

$200.000.00

$950,000.00 Jury Verdict

$249,950.00 Attorney Fee

Plaintiffs therefore request this Court grant a minimum fee of $249,950.00.

Although Illinois law sets a presumptive fee in medical malpractice cases. 735 ILCS 5/2-1114 allows the Court certain discretion to review the attorney fees. Specifically, when an attorney provides “extraordinary” services involving more the usual time and participation, the attorney may apply to the Court for an amount in addition to the statutory formula. Counsel for plaintiff's submits to this Court that such “extraordinary” services were provided in this instance.

Without even factoring in the sanctionable conduct by the hospital's counsel, the Cretton case was as noted previously, not a simple clear-cut case of negligence where all parties agree on the facts but dispute causation or breach of duty. Rather, plaintiffs had to prove that the triggering event even occurred. Again, there was no report of a “drop” or “full” in Joyce Cretton's hospital records. Plaintiffs had nothing in the patient's own record to substantiate such an allegation. Only the autopsy report of Dr. Harry Parks was available to indicate that Joyce Cretton died as a result of a subdural hematoma. consistent with a drop or fall-type of injury. During the discovery deposition of Dr. Parks, taken by Mr. o, the hospital's questioning was aimed at disputing the allegation of the fall. 11 This effort by the hospital's counsel ignored the information kept secret only by the conspiracy of the lawyers representing the hospital. More importantly,

In addition to the amount which plaintiffs' counsel could receive pursuant to 735 ILCS 5/2-1114, this Court should award the additional attorneys' fees for another reason. Specifically, as a direct consequence of the hospital's misconduct, plaintiffs counsel havespent months arguing over this post-trial motion. This effort has included a post-trial deposition and filing supporting submissions to this Court. Moreover, the plaintiffs and beneficiaries of the Estate of Joyce Cretton have been denied a final judgment because of this misconduct. Interest cannot begin to accrue on the verdict until this Court enters judgment thereon.

Therefore, plaintiffs' counsel believes this Court should enter an award of attorneys' fees in the amount $316,350.00. which constitutes a 1/3 fee of the S950,000.00 jury verdict. Such an award is more than reasonable under the circumstances.

In addition to the attorneys' fees herein, this Court should also award the expenses of the litigation which were incurred. These expenses are in addition to and separate from any consideration of the fee. As noted throughout the argument herein, these expenses were warranted in order to prepare the case for trial. (See Affidavit of Judy L. Cates, Exhibit 10.) Therefore, plaintiffs request this Court enter an award in the amount of $24,542.57 for expenses incurred.

CONCLUSION

In light of the foregoing, plaintiffs request this Court enter an award of $316.350.00 in attorney's fees plus expenses in the amount of $24,542.57. This award of $340,892.57 is more than reasonable based upon all of the circumstances and will deter future violations of the Rules pertaining to pleadings.

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