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Civil Action Cover Sheet - Case Initiation (05/27/16) CCL 0520 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION ty of Chicago Jussie Smollett CIVIL ACTION COVER SHEET - CASE INITIATION ‘A Gisil Action Cover Sheet - Case lnitiation shall be fled withthe ‘complaint inal civil actions. ‘The information contained herein is for administrative purposes only and cannot be introduced into ce. Dlease check the box in front of the appropriate case type which best characterizes your action. Only one (1) case rype rmay be checked with this cover sheet Jury Demand @ Yes. Oo )NAL INJURY/ CASE TYPES: 027 Motor Vehicle 1.040 Medical Malpractice D047 Asbestos 048 Dram Shop 049 Product Liability 1051 Construction Injuries (including Seructural Work Act, Road Construction Injuries Aet and negligenes) 052 Railroad/PELA 1053 Pediatrie Lead Exposure 1061 Other Personal Injury/Wrongfal Death 01063 Intentional Tort 1.064 Miscellaneous Stautory Action (Please Specify Below"*) (2.065 Premises Liability 1078 Fen-phen/Redus Litigation 2.199 Silicone Implane ‘TAX & MISCELLANEOUS REMEDIES CASE TYPES: 0.007 Confessions of Judgment 2.008 Replevin D009 Tax 015 Condemnation Qo17 Detinue 2.029 Unemployment Compensation 031 Foreign Transcript 0036 Administrative Review Action 085 Pestion co Register Foreign Judgment 2099 All Other Extraordinary Remedies by; Edward N. Siskel (Atcomey) DEATH (Pro Se) ‘Pro Se Only: C1 have read and agree co che terms of the form the Clerk's Office for chis cae at this email addeess: TILE STANT) (COMMERCIAL LITIGATION 01070 Professional Malpractice (other than legal or medical) Fraud (other than legal or medical) 072 Consumer Fraud D073 Breach of Warranty 074 Scatucory Action (Pease specify below.) 1.075 Other Commercial Litigation (Please specify below.*) 1076 Retaliatory Discharge OTHER ACTIONS (CASE -TYPES: 21062. Property Damage 1.066 Legal Malpractice 07 Libel/Slnder 1079 Pectin for Qualifed Orders 084 Pecicion to Issue Subpoena 1100 Pectin for Discovery + Municipal Code of Chicago, §1-21-010, et seq. & § 1-20-00, et seq Primary Email: edward. siskel@cityofchicago.or Secondary Email: “Tertiary Email ers Office Elecoronie Notice Policy and choose o opt in to electronic notice DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS Page Lf IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION CITY OF CHICAGO, a municipal corporation, ) ) Plaintiff, ) No. ve ) ) JUSSIE SMOLLETT, an individual ) ) Defendant. ) COMPLAINT Plaintiff the City of Chicago (“City”), by its Corporation Counsel, Edward N. Siskel, brings this Complaint under the City’s False Statements Ordinance (“FSO”), § 1-21-010, et seg. of the Municipal Code of Chicago (“MCC”), and the City’s Cost Recovery Ordinance (“CRO”), MCC § 1-20-010, et seq. against Defendant Jussie Smollett (“Defendant”), seeking relief against Defendant for false statements he made to the City, and seeking recovery of the costs of necessary services provided by the City due to Defendant’s violations of the MCC, and in support alleges as follows: NATURE OF THE CASE 1. This action is brought by the City to recover civil penalties, statutory treble damages, and attorney’s fees and costs arising from Defendant's false statements to the City. On January 29, 2019, Defendant submitted a false police report claiming that he was the vietim of racist and homophobic beating by unknown attackers, In reality, Defendant knew his attackers and orchestrated the purported attack himself. Later, when police confronted him with evidence about his attackers, he still refused to disclose his involvement in planning the attack. In investigating Defendant's false statements and false police report, the City incurred significant costs in order to provide services reasonably related to Defendant’s conduct. PARTIES 1. The City is a municipal corporation organized and existing under the laws of the State of Ilinois. 2. Defendant is an actor on the televisi filmed mn show “Empire,” which is primarily in Chicago. While working on “Empire,” and at all times relevant to this Complaint, Defendant resided in the Streeterville neighborhood in Chicago, Illinois. JURISDICTION AND VENUE 3. This Court has subject matter jurisdiction over this action pursuant to the Hlinois Constitution art. VI, § 9. 4. This Court has jurisdiction over Defendant pursuant to 735 ILCS 5/2-209 because Defendant violated the MCC by making false statements in Chicago, Ilinois, and the City incurred significant costs in order to provide services reasonably related to Defendant's false statements. 5. Venue in Cook County is proper because this cause of action arose in Cook County, Illinois. FACTUAL ALLEGATIONS AL Defendant orchestrates and plans a fake attack. 6. In the fall of 2017, Defendant became friends with an individual named Abimbola Osundairo (“Abel”), who is 25 years old and has worked with Defendant on Empire. During the course of their friendship, Defendant and Abel socialized and exercised together, and Defendant occasionally asked for Abel's assistance in obtaining recreational drugs.