IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS LAW DIVISION, THIRD DISTRICT

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1 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS LAW DIVISION, THIRD DISTRICT STACEY WESCOTT and BRIAN PETERSON, as Parents and Next Friends of SOPHIA PETERSON, a minor Plaintiffs, v. Case No.: ORGANICLIFE, LLC, an Illinois Limited Liability Corporation, Defendant. COMPLAINT AT LAW NOW COMES the plaintiffs, STACEY WESCOTT and BRIAN PETERSON, as Parents and Next Friends of SOPHIA PETERSON, a minor, by and through their attorneys, MARLER CLARK, LLP (admission pending pro hac vice and NEWLAND & NEWLAND, LLP, and in complaining of the defendant, ORGANICLIFE, LLC, alleges and states as follows: I. PARTIES 1. The plaintiffs reside in Elgin, Illinois, with the minor child, their natural daughter, Sophia Peterson. 2. At all times material, the defendant ORGANICLIFE, LLC, owned and operated the foodservice facility located at 281 East Messer Drive in Wheeling, Cook County, Illinois, where defendant manufactured, prepared, serviced, distributed, and sold food, including lunch and meal services to a number of different educational institutions. II. RELEVANT FACTS 3. Salmonellosis is an acute bacterial infection that causes severe gastrointestinal illness.

2 Some individuals with salmonellosis require hospitalization and suffer permanent injuries. The OrganicLife, LLC Salmonella Outbreak 4. On or about October 9, 2012 the Lake County Health Department (LCHD determined that an outbreak cluster of Salmonella Enteriditis (SE occurred at St. Anne Catholic School in Barrington, Illinois. 5. LCHD environmental staff inspected the school kitchen at St. Anne Catholic School on October 4, 2012 and found no issues with the school kitchen facility. 6. All meals served at St. Anne were supplied by OrganicLife. 7. Students enrolled at six different private schools located in the City of Chicago, in Cook County, and in Lake County, also succumbed to the same strain of Salmonella Enteriditis. 8. On October 12, 2012, OrganicLife s 281 East Messer Drive facility in Wheeling, Illinois failed an on-site inspection made by the Cook County Department of Health. Investigators found suboptimal hygiene practices at the facility. 9. Public health investigators summarized their investigation in a report issued December 3, See Illinois Department of Public Health Final Outbreak Report, Exhibit A. They concluded that an outbreak of Salmonella Enteriditis occurred at six private schools, including St. Anne Catholic School, which received school lunches from OrganicLife from mid-september to mid-october OrganicLife was the sole provider of prepared school lunches at the six schools involved in the outbreak. 11. At all relevant times, said prepared lunches were manufactured, prepared, serviced, distributed, and sold from OrganicLife, Inc. s 281 East Messer Drive facility. The Plaintiff s Illness and Injuries 2

3 12. At the time of the defendant s Salmonella outbreak, described at paragraphs 4 through 11 Sophia Peterson was an 11-year-old in the fifth grade at St. Anne Catholic School in Barrington, Illinois. 13. On September 17 and 19, 2012, Sophia bought lunches at school that had been manufactured, distributed and sold by the defendant. The food contained in one or both of these meals was contaminated by Salmonella bacteria. 14. Onset of symptoms related to the infection that Sophia acquired from the defendant s contaminated food occurred on or about Thursday, September 20, Throughout the rest of the day and night on September 20, 2012, Sophia became more and more ill, suffering from abdominal cramps, fevers, lethargy, nausea, diarrhea and vomiting. 16. Over the next two days, Sophia s symptoms worsened, including a fever that spiked to 104 degrees. She could not keep any food down, and anything that she drank merely provoked another round of vomiting, painful abdominal cramps and, ultimately, diarrhea. Her skin began to take on a grayish appearance and her lips began to crack. 17. Sunday morning, September 23, 2012, plaintiff Stacey Wescott rushed her daughter to the emergency department at St. Alexius Medical Center. The treating physician quickly began Sophia on intravenous fluids for rehydration. 18. Following discharge, the symptoms worsened, and Sophia again became dehydrated and was unable to keep any food or fluids down. She was unable to sleep at all, and continued to suffer from extreme fevers and abdominal cramps. 19. On Tuesday, September 25, 2012, plaintiff Stacey Wescott called her daughter s pediatrician and was advised to take Sophia back to the St. Alexius emergency room. 20. At the emergency room, the treating physician indicated that the lab test results done on Sophia s bodily fluids were what would be expected of an individual starving to death. And determined that Sophia s suspected Salmonella infection had aggravated a pre-existing 3

4 condition, Thalassemia. Therefore, Sophia was admitted to the regular hospital for four days. 21. During her hospitalization, Sophia continued to suffer from regular, painful bouts of diarrhea in fact, up to 30 bouts a day fevers, and significant nausea. She continued to get little sleep, and remained acutely uncomfortable and ill. She was seen in consultation by a gastroenterologist, who believed that she was suffering from an acute bacterial infection. Sophia was finally released on September 29, On or about October 1, 2012, Sophia s stool sample was confirmed positive for Salmonella. 23. Sophia s symptoms continued at varying frequencies and intensities for over one month following her discharge from the hospital. Sophia continued to test positive for Salmonella until January III. COUNT I (STRICT PRODUCT LIABILITY 24. The plaintiffs incorporate the paragraphs 1 through 23 of this Complaint, by this reference, as if each and every of these paragraphs were set forth here in its entirety. 25. The defendant manufactured, distributed, and sold the adulterated food that injured the minor plaintiff and caused her to become infected with Salmonella. 26. The defendant manufactures food and drink products for sale to the public. 27. Food and drink that is contaminated with Salmonella is unsafe when put to the use reasonably, foreseeable considering the nature of the product. Namely, Salmonella contaminated food and drink is unfit for human consumption. 28. The food that the minor plaintiff purchased from the defendant was contaminated with Salmonella. The minor plaintiff s consumption of the contaminated food caused her to become infected with Salmonella and to suffer injuries as a direct and proximate result. 29. The food that the minor plaintiff purchased and consumed was contaminated with 4

5 Salmonella when it left the defendant s control. 30. The defendant is strictly liable to the plaintiffs for the harm proximately caused by its manufacture and sale of an unsafe and defective food product. WHEREFORE, the plaintiffs, STACEY WESCOTT and BRIAN PETERSON, Parents and Next Friends of SOPHIA PETERSON, pray for judgment against the defendant, ORGANICLIFE, LLC, in an amount in excess of the minimum amount allowed to establish jurisdiction in the Law Division of the Circuit Court of Cook County, Illinois. IV. COUNT II (NEGLIGENCE 31. The plaintiffs incorporate paragraphs 1 through 30 of this Complaint, by this reference, as if each and every of these paragraphs were set forth here in its entirety. 32. The defendant designed, manufactured, distributed, and sold food and drink products that were adulterated with the Salmonella bacteria. These products, as a result of adulteration, were unfit for human consumption, and were not reasonably safe as designed, constructed, manufactured, and sold. 33. The defendant owed a duty to all persons who were the eventual consumers of its product to manufacture and sell food and drink that was safe to eat, that was not adulterated with potentially deadly pathogens, like Salmonella, and that was not in violation of applicable food and safety regulations. 34. The defendant owed a duty to all persons who were the eventual consumers of its product to maintain its premises in a sanitary and safe condition so that no one eating food produced at the defendant s premises would be exposed to, or infected by, a potentially deadly pathogen, like Salmonella. 35. The defendant breached the duties it owed to persons who were the eventual consumers of 5

6 its product by committing the following acts and omissions of negligence: a. Failed to adequately maintain or monitor the sanitary conditions of its food, drink, water, premises, and employees; b. Failed to properly operate the locations where it manufactured its food in a safe, clean, and sanitary manner; c. Failed to prevent the transmission of Salmonella from its food, drink, water, premises, or employees to the ultimate consumers of its products, and those foreseeably at risk of secondary transmission of disease; d. Failed to properly train its employees and agents how to prevent the transmission of Salmonella on its premises, or in its food, drink and water; e. Failed to properly supervise its employees and agents to prevent the transmission of Salmonella on its premises, or in its food, drink and water; f. Manufactured and sold adulterated food in violation of 410 ILCS 620/3.2; g. Stored, offered, and delivered food in violation of 410 ILCS 620/3.1 and 410 ILCS 620/3.4; h. Failed to maintain its premises in a clean, sanitary, and healthful manner in violation of 410 ILCS 650/1 and 410 ILCS 650/2; and 36. The minor plaintiff was injured and sustained personal injury and damages as the proximate result of the defendant s negligent acts and omissions, as set forth above. WHEREFORE, the plaintiffs, STACEY WESCOTT and BRIAN PETERSON, Parents and Next Friends of SOPHIA PETERSON, pray for judgment against the defendant, ORGANICLIFE, LLC, in an amount in excess of the minimum amount allowed to establish jurisdiction in the Law Division of the Circuit Court of Cook County, Illinois. 6

7 V. COUNT III (BREACH OF IMPLIED WARRANTY 37. The plaintiffs incorporate paragraphs 1 through 36 of this Complaint, by this reference, as if each and every of these paragraphs were set forth here in its entirety. 38. By offering food for distribution, sale and consumption to schools, the defendant made an implied warranty that its food was not adulterated with a deadly pathogen, had been safely prepared under sanitary conditions, and was fit for human consumption. 39. The defendant breached its implied warranty with regard to the food it manufactured and that was ultimately consumed by the minor plaintiff, when it distributed said food to St. Anne s Catholic School contaminated with norovirus. 40. Said contaminated food, directly and proximately resulted in the minor plaintiff s norovirus infection and related illnesses. 41. The minor plaintiff suffered personal injury and damages as a foreseeable consequence of the defendant s breach of implied warranty, as set forth above, and thus plaintiffs are entitled to recover for all actual, consequential, and incidental damages that flow directly and in a foreseeable fashion from said breach. WHEREFORE, the plaintiffs STACEY WESCOTT and BRIAN PETERSON, Parents and Next Friends of SOPHIA PETERSON, pray for judgment against the defendant, ORGANICLIFE, LLC, in an amount in excess of the minimum amount allowed to establish jurisdiction in the Law Division of the Circuit Court of Cook County, Illinois. VI. COUNT IV (PARENT S RIGHT TO REIMBURSEMENT 7

8 42. The plaintiffs incorporate paragraphs 1 through 41 of this Complaint, by this reference, as if each and every of these paragraphs were set forth here in its entirety. 43. Parents are entitled to file a cause of action to recover reimbursement for expenses they incur that relate to an injured minor child, including medical expenses, as governed by the Family Expense Act 750 ILCS 65/15 [See Dewey v. Zack, 272 Ill.App.3d 742, 746, 651 N.E.2d 643 (2 nd Dist. 1995]. 44. The plaintiffs incurred multiple medical, medicinal and laboratory expenses due to the necessary testing, diagnosis and treatment for the minor child s Salmonella infection, including lost wages and additional expenses. WHEREFORE, the plaintiffs STACEY WESCOTT and BRIAN PETERSON, Parents and Next Friends of SOPHIA PETERSON, a minor, pray for Judgment against the defendant, ORGANICLIFE, LLC, in an amount in excess of the minimum amount allowed to establish jurisdiction in the Law Division of the Circuit Court of Cook County, Illinois. Respectfully submitted, Gary A. Newland NEWLAND & NEWLAND, LLP 121 South Wilke Road, Suite 301 Arlington Heights, IL Tel: Fax: Attorney No By: One of the Attorneys for Plaintiffs, STACEY WESCOTT and BRIAN PETERSON, Parents & Next Friends of SOPHIA PETERSON, a Minor. And Co-Counsel (pending admission pro hac vice William D. Marler MARLER CLARK, LLP, PS 8

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