Rip off company
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION THOMAS C. SOURAN Plaintiff, vs. ISRAEL ONE LLC, a Texas Corporation Mary Lee, and individual and employee Michael Grabley and individual Avraham Kadoch and individual Defendant ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: Judge: VERIFIED COMPLAINT THE PARTIES 1. The Plaintiff, Thomas C. Souran, is an individual and his primary residence is located at 14 Bright Oaks Circle, Cary, Illinois 60013. 2. On information and belief the Defendant, ISREAL ONE, LLC is the corporate entity that operates A Team Moving and Storage and is organized under the Laws of the State of Texas. The registered Agent is Avraham Kadoch, an officer of the corporation, who can be served at 1417 Exchange drive, Richardson, Texas 75081 Verified Complaint - 2 3. On belief and information defendant Michael Grabley, an officer of Israel One, LLC who's address is 1417 Exchange Drive, Richardson Texas 75023. 4. On information and belief the defendant, Avraham Kadoch, an officer who operates A Team Moving and Storage who's address is 1417 Exchange Parkway, Richardson, Texas 75023 JURISDICTION AND VENUE 1. Jurisdiction and Venue are proper under United States Code 49 Subtitle IV> Part B> Chapter 147> 14706 which states: “Against carrier responsible for loss- A civil action under this section may be brought against the carrier for alleged to have caused loss or damage, in the in the judicial district in which such loss or damaged is alleged to occurred†2. Venue is proper because all or substantially all of the facts or circumstances giving rise to Plaintiffs' causes of action occurred in northern Illinois. FACTUAL BACKGROUND 1. On May 19, 2011 Defendant sent Plaintiff a “Binding†quote for Defendants to move Plaintiffs' belongings the quote was for $787.50, EXHIBIT “A†2. Plaintiff agreed to the move and arranged it for June 25, 2011. 3. On June 25, 2011 Defendants picked up all of Plaintiffs' belongings at a storage locker in Plano, Texas. Plaintiffs' belongings were in the Verified Complaint - 3 storage locker since in April 2011 the Plaintiff had back fusion surgery. 4. On June 25, 2011 Plaintiff arrived at the storage locker late the movers asked Plaintiff for a deposit, Plaintiff explained that the sales representative for Defendants never informed Plaintiff that he had to have a deposit. The employee called Defendants office and they notified the employee (driver) to proceed with the move. 5. Plaintiff explained to the employee's of the Defendant that he had back fusion surgery and could not stand long. Plaintiff told the e