Introduction for First Amended Complaint
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
Plaintiff, ) No. 11 CV 4542
V. ) Judge: Robert M. Dow, Jr.
PALOS COMMUNITY HOSPITAL,
and Illinois corporation, and KEN LASH,
PLAINTIFF'S MOTION FOR LEAVE TO FILE HIS FIRST AMENDED COMPLAINT
NOW COMES THE Plaintiff, JOSEPH MIROCHA ("Plaintiff), by and through his attorney, Joseph
P. Berglund, and for his Motion to File his First Amended Complaint pursuant to Fed.R.Civ.Pro.
15(a)(2), states as follows:
Plaintiffs proposed First Amended Complaint is attached to this Motion as Exhibit 1.
Fed.R.Civ.Pro. 15(a)(2) provides that the Court should freely give a party leave to amend its
pleading when justice so requires. Plaintiff respectfully submits that justice requires he be
given leave to file his First Amended Complaint. This Honorable Court previously dismissed
Counts IV,V, VI, VII, and VIII.
Plaintiff is not seeking to amend Count V (Defamation In Connection With Plaintiffs Termination
Against PCH) of his initial Complaint and has not realleged this claim. Plaintiff requests leave
to file his First Amended Complaint which contains additional facts in support of Ms claim in
Counts IV, V, VI, and VII in the attached First Amended Complaint.
B. COUNT IV - Breach of Agreement Against PCH
InPerman v. Arcventures, Inc., 196 111. App. 3d 758 (1st Dist. 1990), the Court found
that certain personnel policies and procedures created a binding contract which are virtually identical to
this case. Specifically, the manual mPerman provided, that "Such discharges must be approved in
advance by the director of employee relations or designees, and are subject to employee appeal
through established grievance procedures." (Emphasis added.) The manual further asserts that, "It is
the policy of the Medical Center to assure every employee of the right of appeal, through and established
grievance procedure from an unfavorable decision affecting his employment." (Emphasis added.)
Perman received the manual during his orientation and commenced work after learning of its
provisions. Given the unequivocal language, we reverse the trial court's summary judgment ruling and
find as a matter of law that Perman's employment could not be terminated at will insofar as the manual
provided for an established grievance procedure for an unfavorable decision affecting employment. 196
Ill.App.3d at 765-766.
Arc Ventures utilized Rush's manual of personnel policies and procedures. The manual's introduction
states the following: " Personnel Policies and Procedures which follow, and which may be modified from
time to time by the Medical Center, are meant to provide managers and supervisors with guidelines as
to how the above-discussed employee relations policy of the Medical Center should be implemented.
The Personnel Policies and Procedures do not constitute, modify or otherwise alter the terms and
conditions of employment of any Medical Center employee, do not limit or restrict the right of
management to terminate or otherwise discipline any Medical Center Employee, and do not constitute
an employment contract with any Medical Center Employee." 196 Ill.App.3d at 762.
The Introduction to Palos Community Hospital Policies and Procedure Manual 951.001, Statement of
Policy, states the following: "The Human Resources Policy Manual responds to many complex legal and
general employment issues affecting everyone in the workplace. PCH reserves the right to amend,
modify or discontinue all or any part of the policies, procedures
and/or programs covered in this manual to conform to legal or organization needs. In the event that
there is an inadvertent unlawful statement in the policy manual, the law takes precedence and the
statement is null and void. Additionally, particular situations may be governed by formal plan documents
established for the benefit programs. The manual serves as an overall guideline and nothing in this
manual constitutes an employment contract between PCH and any of its employees. Employment with
and compensation from PCH is not guaranteed and may be ended by the employee or PCH at any time.
Nearly identical to the manual in Perman, the Palos Community Hospital Policies and Procedure
Manual 951.001 states"The purpose of the Palos Community Hospital (PCH) Human Resources Policy
Manual is to provide guidelines for department heads/managers and staff in accomplishing their work
goals and furthering the mission of PCH."
As in Perman, the Palos Community Hospital Policies and Procedure Manual provides an employee
code of conduct, disciplinary procedures and grievance procedures.
As in Perman, the Palos Community Hospital Policies and Procedure Manual provides that employees
are subject to immediate dismissal, even for a first time offense. Palos Community Hospital Employee
Counseling, Corrective Action & Work Improvement policy 951.708 states: "Termination of employment
may also occur if the employee commits a major violation of Palos Community Hospital rules of
conduct." Plaintiff did not commit a major violation.
In Perman, the manual provides that for rule violations they may employ any of the following disciplinary
actions: verbal warning, written reprimand, suspension, or discharge. The Palos Community Hospital
Employee Counseling, Corrective Action & Work Improvement policy 951.708 uses a much stronger
wording guaranteeing an employee progressive disciplinary action regarding rule violations. Palos
Community Hospital states: "When these standards are
not met, procedures for corrective action and work improvement will be implemented. These
procedures are verbal warning, written reprimand, suspension, and termination.
In Perman, the manual provided that discharges must be approved in advance by the director of
employee relations. In this case, the Palos Community Hospital Policies and Procedure 951.708
States: "The Vice President of Human Resources is responsible for prior approval of suspensions or
terminations of employment.
In Perman, the employee grievance procedure section provides that, "It is the policy of the Medical
Center to assure every employee of the right of appeal through an established grievance procedure
form an unfavorable decision affecting his employment." The grievance procedure includes a four-step
process, with the employee first discussing the problem or complaint with the immediate supervisor. If
there is no satisfactory resolution, the second and third steps provide for the presentment of the issue
to the next higher supervisor or manager and\or the department of employees relations, respectively.
The department will initiate a conference, investigate, make findings and issue a decision.
As in Perman, Palos Community Hospital Policies and Procedure Employee Complaint Procedures
951.707 similarly states: Palos community Hospital provides procedures for employees to raise
complaints in connection with their employment. The complaint procedure includes a five-step process,
with the employee first discussing the problem or complaint with the immediate supervisor. If there is
no satisfactory resolution, the second, third, fourth and fifth steps provide for the presentment of the
issue to their department head, to the Vice President of Human Resources, to the appropriate Vice
President and finally to the President, respectively. At step three the Human Resource department will
review and investigate the complaint which may include a review of relevant documentation and
meetings with the employee, the employee's supervisor or other individuals with knowledge related to
the complaint. The Vice President of
appropriate Vice President will send a response to the employee. Step-five states: "If the complaint
involves a suspension, termination of employment or alleged discrimination the employee may make
a final appeal to the president. A final decision, in writing, will be sent to employee the right of appeal
through an established complaint procedure from an unfavorable decision affecting his employment.
"A final decision, in writing, will be sent", is a definite and mandatory statement.
In Perman, the "entire purpose is to provide a uniform, methodical system of securing justice for an
employee." 196 Ill.App.3d at 765. As in Perman, Palos Community Hospital Policies and Procedure
Employee Complaint Procedures 951.707 similarly states: "The procedures are established to resolve
complaints in a fair, equitable and non-adversarial manner for prompt response without recrimination
or reprisal." and "This policy for complaint procedures is the exclusive mechanism for resolving
employee complaints within Palos Community Hospital."
The court ruled in Perman that unequivocal language used in the policy manual provided for
established grievance procedures created enforceable contractual rights despite a disclaimer.
Applying the same standard used in Perman the unequivocal language used by Palos Community
Hospital in the policy manual stating "procedures for corrective action and work Improvement will be
implemented" and "The Vice President of Human Resources is responsible for prior approval of
suspensions or terminations of employment." creates enforceable contractual rights for disciplinary
procedures despite a disclaimer in the same manner as grievance procedures did in Perman.
The employee in Perman also asserted that the disclaimer contained in the policy manual which was
not set off from the rest of the text, printed in capital letters or titled, created a
genuine issue of material fact as to whether it was effective to preclude a reasonable person from
believing the policy manual to be an offer. As in Perman the plaintiff in the instant case asserts that the
purported disclaimer in the Palos Community Hospital Policies and from believing the policy manual to
be an offer. As in Perman the plaintiff in the instant case letters or titled, creates a genuine issue of
material fact as to whether it was effective to asserts that the purported disclaimer in the Palos
Community Hospital Policies and preclude a reasonable person from believing the policy manual to
be an offer. In Perman, the Procedure Manual 951.001, which was not set off from the rest of the text,
printed in capital court ruled that it is "mindful that in Duldulao the handbook did not contain a
disclaimer and that a contract claim may be difficult to maintain when the employee handbook
expressly provides that the employment relationship is at will. (Sitek v. Forest City Enterprises, Inc.
(E.D. Mich. 1984), 587 F. Supp. 1381,1384.) Nonetheless, we find that the language in Rush's manual
of personnel policies and procedures created enforceable contractual rights despite its disclaimer."
196 Ill.App.3d at 765.
As in Perman, the personnel policies and procedures of PCH create a binding contract. As a result,
Plaintiffs employment could not be terminated at will and he has sufficiently alleged a cause of action
for breach of contract.
C. COUNT V - Defamation In Connection With Disciplinary Memoranda Against Ken Lash
In Leyshon v. Diehl Controls N. Am., Inc., 407 111. App. 3d 1 (111. App. Ct. 1st Dist 2010). the court
ruled, "just because a word may have an innocent meaning does not require that it be innocently
constructed Employer's board member's statement, "you are terminated for cause under the terms of
your employment agreement," was actionable as defamatory because an employee's termination was
the result of a premeditated scheme, and given the context in which the statement that plaintiff was
terminated for cause was made, it did not have an innocent meaning. The context in which the words
or statement were uttered also must be considered."
Corrective Action Form to others which contained false statements.
On February 4, 2011 Mirocha sent Ken Lash an e-mail stating: "As supervisor of the electrical shop my
job description states, "Supervise work performed to assure it conforms with established procedures,
policies and regulations." Maintaining the database, to establish and create maintenance procedures I
believe to be at a job level above mine."
Ken Lash immediately on February 4, 2011 responded to Mirocha's e-mail with a formal Corrective
Action Form which stated that Plaintiff was disciplined for his "Failure to fulfill job duties" and an
attached disciplinary file memorandum. See Exhibit A attached to Plaintiff's proposed First Amended
Complaint. Specifically, Lash wrote in the memorandum that "[Mirocha's] most significant failure as the
electrical supervisor has been his inability to identify what his job duties are and then to work well
independently." Failure to fulfill job duties is a violation of hospital policy when combined with the
Corrective Action Form stating: "see attached memo" Ken Lash's statement taken in context defamed
In Ken Lash's February 4, 2011 file memoranda Ken Lash states: "Currently, the hospital's Utilities
Management Program is in jeopardy if the Joint Commission inspection would occur soon because
Joe failed to perform the infrared scanning tests on the hospital's electrical infrastructure in 2010 when
it was due for inspection. It was Joe's responsibility to see that these tests were performed on-time
and to bring it to my attention if there was a problem. It was only after these issues were brought to
light in January was the infrared testing scheduled to be completed in February 2011." This false
statement by Ken Lash taken in context defamed Mirocha. The infrared scan testing was never part of
the Utilities Management Program and even if it was the goal of the Utilities Management Program is a
95% completion rate, and at the time of Lash's memoranda the infrared scanning was a single
maintenance task which would have
little impact on the percentage of completion. In seven years of being the Electrical Supervisor Mirocha
never heard of anyone being disciplined for any of the over 5% consistently non-completed Utilities
Management Program maintenance routines. In December 2010, Mirocha told Lash that he was
moving the infra-red scanning forward to be done in 2011 based on manpower issues.
department depends on an accurate database and [Plaintiffs] neglect of this over the years has lead to
the desperate state that he is in now. Joe has been employed at Palos Community Hospital since
September 2003 and any database inadequacies that exist are his responsibility and not his
predecessors." This false statement by Ken Lash taken in context defamed Mirocha. Outside of
Mirocha's control and above Mirocha's authority an entirely new 20 million dollar In his February 4,
2011 file memoranda Ken Lash states: "The foundation of the entire electrical infrastructure was put
into service in violation of Hospital policy which requires equipment to be entered into the database
when the equipment is put into service.
In his February 4, 2011 file memoranda Ken Lash states: "On December 30, 2010, Joe Mirocha was
given a deadline of 30 days to bring the Electrical Department's database into full compliance
including the tasks of entering all incoming inspections of new equipment, providing completeness of
all data entries, setting up the correct PM procedures, and updating the emergency procedures. All of
these tasks are a requirement for the position of the electrical supervisor and are addressed in the job
description as well as various departmental policies. Failure of maintaining an accurate electrical
database will result in non-compliance with Joint Commission standards, as well causing an unsafe
environment, as equipment is not properly maintained." This false statement by Ken Lash taken in
context defamed Mirocha. By job description the electrical supervisor is to supervise work performed to
assure it conforms with established procedures, policies and regulations and by the "Equipment
comprehensive preventive maintenance schedule for each piece of equipment. Plaintiff was not a
department manager. Ken Lash was a department manager.
In his February 4, 2011 file memoranda Ken Lash states: "While Joe has made significant
improvements in the state of the database during January, an unbiased assessment would indicate
that more work needs to be done and he has missed the goal of full compliance within the 30 day
window." This false statement by Ken Lash taken in context defamed Mirocha. Mirocha completed the
original task of entering all equipment into the electrical panel database. Ken Lash and Marty Baron
had the electrical panel database moved into the equipment database three days before the 30 day
deadline sabotaging any chance Mirocha had to meet the deadline a second time by adding 350
panels with over 1050 additional entries to be researched throughout a 2 million square foot facility
and then be entered into the database.
The February 4, 2011 formal Corrective Action Form, which contains the reason "Failure to fulfill job
duties" is defamatory per se not reasonably capable of an innocent construction coupled with Ken
Lash's attached file memoranda taken in context constitutes defamation based on false allegations to
substantiate Plaintiffs alleged failure to fulfill job duties which is a violation of hospital policy. Ken
Lash used Mirocha as a scapegoat to cover up that Lash failed to do work he himself was
responsible to perform. Ken Lash's statements taken in context cannot reasonably be construed as
having an innocent meaning.
Plaintiff alleges that Ken Lash defamed him by distributing Involuntary Termination of Employment
Report form to other persons in the hospital.
Ken Lash gave Mirocha an Involuntary Termination of Employment Report dated April 8, 2011 with the
reason "Failure to fulfill job duties" which in itself is defamatory per se and not reasonably capable of
an innocent construction.
Ken Lash knew his statements were false yet still passed the defamatory statements on to other
corporate officials and employees. Palos Community Hospital abused its qualified privilege knowing
Ken Lash acted with actual malice, Marry Baron was aware the panel database was moved into the
equipment database, thereby abusing any privilege.
A statement is defamatory if it tends to harm a person's reputation to the extent that it lowers Tuite,
224111.2d at 501. Illinois recognizes five categories of statements that are defamatory per se, two of
which are implicated in this case: statements imputing an inability to perform or want of professional
integrity in performing employment duties and statements imputing a lack of ability or that otherwise
prejudice a person in his profession or business. Tuite, 224 I11.2d at 501-02. Even if a statement
falls into one of the per se categories, the statement will not be actionable if it is reasonably capable
of an innocent construction. Tuite, 224 m.2d at 502.
In Green v. Rogers, 234111.2d 478, 917 N.E.2d 450 (2009), our supreme court explained the
innocent-construction rule as follows: "Under the 'innocent-construction rule,' a court must consider
the statement in context and give the words of the statement, and any implications arising from them,
their natural and obvious meaning.... Indeed, this court has emphasized that the context of the
statement is critical in determining its meaning, as a given statement may convey entirely different
meanings when presented in different contexts. [Citation.] If the statement may reasonably be
innocently interpreted, it cannot be actionable per se. [Citation.] Stated differently, 'a statement
"reasonably" capable of a nondefamatory interpretation, given its verbal or literary context, should be
so interpreted. There is no balancing of reasonable constructions * * *.' [Citation.] At the same time,
when the defendant clearly intended and unmistakably conveyed a defamatory meaning, a court
should not strain to see an inoffensive
gloss on the statement. [Citation.]" (Emphasis in original.) Green, 234111.2d at 499-500, quoting
Mittelman v. Witous, 135 I11.2d 220, 232, 552 N.E.2d 973 (1989), abrogated on other grounds in
Kuwikv. Starmark Star Marketing & Administration, Inc., 156 I11.2d 16, 619 N.E.2d 129 (1993).
In Bryson v. New America Publications, Inc., 174111.2d 77, 672 N.E.2d 1207 (1996), the Illinois
Supreme Court emphasized that the innocent construction must be reasonable. The court explained
that the innocent-construction rule did not apply simply because the allegedly defamatory words were
"capable" of an innocent construction. The court explained further as follows:
"In applying the innocent construction rule, courts must give the allegedly defamatory words
their natural and obvious meaning. [Citations.] Courts must therefore interpret the allegedly
defamatory words as they appeared to have been used and according to the idea they were
intended to convey to the reasonable reader. [Citation.] When a defamatory meaning was
clearly intended and conveyed, this court will not strain to interpret allegedly defamatory
words in their mildest and most inoffensive sense in order to hold them nonlibellous under
the innocent construction rule ." Bryson, 174 ILL.2d at 93.
In Bryson, the court found that it need not determine whether the term "slut" always implied
unchastity. Given the context of the statement, the court refused to find that the defamatory word must
be innocently construed as a matter of law. Bryson, 174 I11.2d at 94. More recently, the decision in
Green, reemphasized the importance of the context in which the alleged defamatory words were
uttered. In Green, the Illinois supreme court found that the statement accusing the plaintiff, who had
served as a little league coach and manager, of misconduct and stating that he abused players,
coaches and umpires, was capable of an innocent construction, given the very broad meanings of
"misconduct" and "abuse," as well as the context in which they were used. Green, 234111.2d at
501-02. Since the abuse and misconduct statements were then followed by assurances that the
plaintiff would be free to assist with activities involving his son's team, the court found the statements
reasonably capable of an innocent construction. Green, 234 m.2d at 503.
In contrast, where as long as a word or statement could be innocently construed, it was
nonactionable under the innocent-construction rule, under Bryson and its progeny, just because a
word may have an innocent meaning does not require that it be innocently constructed. The context in
which the words or statement were used also must be considered. In the present case, the context in
which Lash's statements were made states that the reasons for the plaintiffs and willful violation of
PCH policies and thereby imputed to Plaintiff a want of integrity in the performance of his duties and
prejudiced him in his trade or profession. Accordingly, Lash's statements cannot reasonably be
construed as having an innocent meaning as a matter of law as the court ruled in Leyshon v. Diehl
Controls N. Am., Inc.
D. COUNT VI - Intentional Infliction of Emotional Distress against PCH and
COUNT VII - Negligent Infliction of Emotional Distress against PCH
Under Illinois law, a plaintiff may recover damages for intentional infliction of emotional distress only
if she establishes that: "(1) the defendant's conduct was extreme and outrageous, (2) the defendant
intended to inflict severe emotional distress or knew that there was at least a high probability that his
conduct would inflict severe emotional distress, and (3) the defendant's conduct did cause severe
emotional distress." Van Stan v. Fancy Colours & Co., 125 F.3d 563, 567 (7th Cir.1997). In Naeem v.
McKesson Drug Co., 2000 U.S. Dist. LEXIS 16794 (N.D. 111. Nov. 14, 2000)(attached hereto as
Exhibit 2), the trial held that given the extreme behavior presented to the jury, we must conclude the
defendants committed a tort independent of any duties not to discriminate against Ms. Naeem. The
conduct that she alleges is not just sexually harassing conduct; instead, she alleges a pattern of
behavior by the defendants that created impossible deadlines, set up obstacles to her performing
her job, and sabotaged her work. The defendants' conduct will be discussed in more detail below;
however, it is clear that her claim
rests not just on behavior that is sexually harassing, but rather behavior that would be a tort no matter
what the motives of the defendant. Therefore, her claim is not preempted by the IHRA.
As in Naeem v. McKesson Drug Co.. PCH engaged in a pattern of behavior that created impossible
deadlines, set up obstacles to the Plaintiffs performance of his job, and sabotaged his work. Plaintiff
specifically alleges in Counts VI and VII:
98. After Ken Lash gave Mirocha the verbal discipline on December 30, 2010 with the 30 day
deadline Ken Lash added 16 new job tasks, intentionally setting Mirocha up for failure and creating
impossible deadlines in at least the following ways:
a. Two weeks into the 30 day discipline, Ken Lash added the task of requiring
Plaintiff to perform preventative maintenance procedures with manufacturer recommended
b. Three days before the 30 day discipline was up, Ken Lash and Marty Baron had
the electrical panel database moved into the electrical equipment database which created the task
of requiring Plaintiff to research and enter over 1050 new data entries into the database.
c. On February 4, 2011 Ken Lash added the task of requiring Plaintiff to complete
the infra-red scanning maintenance routine.
d. On February 4, 2011 Ken Lash added the task of requiring Plaintiff to update
e. On March 8, 2011 Ken Lash added the task of requiring Plaintiff to write
procedures for responding to all utility system disruptions.
f. On March 8, 2011, Ken Lash added the task of requiring Plaintiff to survey
Chicago area hospitals and electrical contractors.
g. On March 8, 2011, Ken Lash added the task of requiring Plaintiff to use sales
order numbers as serial numbers in some cases for database fields.
h. On March 8, 2011, Ken Lash added the task of requiring Plaintiff to add major events and
repairs for new Central Plant electrical equipment retroactively into the database.
I. On March 8, 2011, Ken Lash added the task of requiring Plaintiff to correct 5
errors in data entry out of thousands which were a result of bad information given to Mirocha by the
people Ken Lash directed to gather the information to give to Mirocha.
j. On March 16, 2011, Ken Lash added the task of requiring Plaintiff to perform maintenance
procedures to be cost effective solutions that balance reliable maintenance and impact on hospital
of the different layers of redundancy that have been designed, such as closed transition switching, to
minimize hospital impact.
l. On March 16, 2011, Ken Lash added the task of requiring Plaintiff to determine a method to
plan when maintenance should be performed and to attempt to spread out costs, hospital operations
and manpower issues.
m. On March 16, 2011, Ken Lash added the task of requiring Plaintiff to verify the list of emergency
contact telephone numbers.
n. On March 16, 2011, Ken Lash added the task of requiring Plaintiff to change the pm frequency
and/or make the database do something it was not capable of doing because the database did not
automatically handle pm frequencies that are not a multiple of each other.
o. On March 16, 2011, Ken Lash added the task of requiring Plaintiff to have preventative
maintenance procedures identify which maintenance tasks will be performed by outside electrical
99. Ken Lash and Marty Baron set up obstacles to Mirocha performing his job in at
least the following ways:
a. Plaintiff was instructed to refrain from talking to the electrical contractor
installing the electrical equipment that Mirocha was required to enter into the database. Mirocha was
instructed to figure out an entire 20 million dollar electrical infrastructure without talking to the
b. Plaintiff was instructed to refrain from discussing the electrical infrastructure or
electrical maintenance procedures with Tony Maiellaro who was the manager of plant
100. Ken Lash and Marty Baron sabotaged Plaintiffs work by moving the electrical
panel database into the electrical equipment database. Plaintiff and his electrical staff for the month
of January 2011 researched 350 electrical panels, counted the number of each amp rating of circuits
for each panel, and entered the number of each amp rating of circuits for each panel in the electrical
panel database to comply with the 30 day discipline deadline. All the information and work done on
the electrical panel database was thrown away when the database was moved.
101. Moving the electrical panel database into the electrical equipment database three
days before the end of the 30 day discipline deadline added 350 panels to research and required
over 1050 new data entries to be entered into the database.
102. Defendants' conduct was extreme and outrageous. Ken Lash intended that and
knew his conduct inflicted severe emotional distress and Plaintiff advised Ken Lash that Lash was
causing him distress. Defendants committed a tort independent of any duties not to discriminate
against Mirocha. The conduct Mirocha alleges is not just age discrimination;
instead, Mirocha alleges a pattern of behavior by the defendants that created impossible deadlines,
set up obstacles to Mirocha performing his job, and sabotaged Mirocha's work. It is clear that
Mirocha's claim rests not just on behavior that is based on age discrimination, but rather behavior
that is a tort no matter what the motives are of the defendant. The defendants' conduct did cause
severe emotional distress to Plaintiff.
103. PCH, through the acts complained of above, engaged in conduct which was repeated and
intentionally caused Plaintiff to suffer damages and injury, including extreme and severe emotional
distress, for which PCH is liable and Plaintiff is entitled to relief as set forth in his prayer for relief.
In accordance with Naeem v. McKesson Drug Co., Plaintiff has sufficiently alleged a cause of action
for intentional infliction of emotional distress VI. Similarly, Plaintiff has sufficiently alleged an action for
negligent infliction of emotional distress in Count VII.
WHEREFORE, Plaintiff prays that this Honorable Court grant him leave to file his First Amended
Complaint instanter and for such other relief deemed just and equitable.
Respectfully submitted, JOSEPH MIROCHA
By: /s/Joseph P. Berglund One of His Attorneys Joseph P. Berglund
BERGLUND ARMSTRONG & MASTNY, P.C. 1010 Jorie Boulevard, Suite 370 Oak Brook, Illinois
60523 (630) 990-0234
Palos Community Hospital
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