EXHIBIT F

P~rt 1-.

Case: 1:12-cv-00163 Document #: 1-6 Filed: 01/10/12 Page 1 of 6 PageID #:23
2120 - Served

2220 - Not Served

2320 - Served By Mail

2420 - Served By Publication

SUMMONS

2121 - Served

2221 - Not Served

2321 - Served By Mail

2421 - Served By Publication

ALIAS - SUMMONS (2/28/11) CCG NOOl

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, Law DIVISION

MARCUS EVANS, INC., Plaintiff

(Name all parties)

v.

TRACY COENEN and SEQUENCE, INC., Defendants

No. 2011 L O~165

o SUMMONS @ALIAS SUMMONS

To each Defendant: Tracy Coenen, 341 E. Lloyd Street, Milwaukee, WI 53212-3362

YOU ARE SUMMONED and required to file an answer to the complaint in this case, a copy of which is

hereto attached, or otherwise file your appearance, and pay the required fee, in the Office of the Clerk of this Court at the

following location:

0···

, '

o

Richard J. Daley Center, 50 W. Washington, Room _8_0_1 , Chicago, Illinois 60602

District 2 - Skokie

5600 Old Orchard Rd.

Skokie,IL 60077

o District 3 - Rolling Meadows

212.1 Euclid

Rolling Meadows, IL 60008

o District 6 - Markham

16501 S. Kedzie Pkwy.

Markham,IL 60428

o District 5 - Bridgeview

10220 S. 76th Ave.

Bridgeview, IL 60455

o District 4 - Maywood

1500 Maybrook Ave.

Maywood,IL 60153

o Child Support

28 North Clark St., Room 200

Chicago, Illinois 60602

You must file within 30 days after service of this Summons, not counting the day of service.

IF yOU FAIL TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE RELIEF

REQUESTED IN THE COMPLAINT. '

To the officer:

This Summons must be returned by the officer or otber person to whom it was iiven for service, with endorsement

ofserviee and fees, ifany, immediately after service. lfservice cannot be made, this Summons-shall be returned so endo;sed.

This Summons may not be served later than 30 days after its date.' \' l)EC 1 5 2011 "

Atty. No.:_4_4_7_5_1 _

Name: Baker & Daniels, LLP, David L, Weinstein, Stacey L. Smiricky

Atry.fur;~P~)~ai~n~ti~f~f _

Address: 311 S. Wacker Drive, Suite 4400

CiryIState/Zip: Chicago, Illinois 60606

Telephone: 312-212-6555

WITNESS, ' '

DOROTHY BROW\'t

~$7~~~\~: '.

Clerk of Court

Date of service: , _

(To be inserted by officer on copy left with defendant

or other person)

Service by Facsimile Transmission will be accepted at: _

(Area Colic) (Facsimile Telephone Number)

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

Case: 1:12-cv-00163 Document #: 1-6 Filed: 01/10/12 Page 2 of 6 PageID #:24
2120 - Served

2220 - Not Served

2320 - Served By Mail

2420 - Served By Publication

SUMMONS

2121 - Served

2221 - Not Served

2321 • Served By Mail

2421 • Served By Publication

ALIAS - SUMMONS (2128/11) CCG NOOl

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, Law DIVISION

(Name all parties)

No. 2011 L011165

MARCUS EVANS, INC., Plaintiff

v.

TRACY COENEN and SEQUENCE, INC., Defendants.

To each Defendant:

O.sUMMONS (!)ALIAS SUMMONS

Tracy. Coenen, 111 E. Wisconsin Avenue, Suite 1230, Milwaukee; WI 53202-480~

YOU ARE SUMMONED and required to file an answer to the complaint in this case, a copy of which is

hereto attached, or otherwise file your appearance, and pay the required fee, in the Office ofthe Clerk ofthis Court at the

following location:

o Richard J. Daley Center, 50 W. Washington, Room 801 ,Chicago, Illinois 60602

o

o

District 2 - Skokie 0 District 3 - Rolling Meadows 0 District 4 - Maywood

5600 Old Orchard Rd. 2J21 Euclid 1500 Maybrook Ave.

Skokie, IL 60077 Rolling Meadows, JL 60008 Maywood,IL 60153

District 5 - Bridgeview 0 District 6 - Markham 0 Child Support

10220 S. 76th Ave. 16501 S. Kedzie Pkwy. 28 North Clark St., Room 200

Bridgeview, IL 60455 Markham,IL 60428 Chicago, Illinois 60602

You must file within 30 days after service of this Summons, not counting the day of service.

IF YOU FAIL TO DO SO, A JUDGMENT BY DEFAULT MAY BE ENTERED AGAINST YOU FOR THE RELIEF

REQUESTED IN THE COMPLAINT.

To the officer:

This Summons must be returned by the officer or other person to whom it was given for service, with endorsement

of service and fees, ifany, immediately after service. Ifservice cannot be made, this Summons shall be returned so endorsed.

This Summons may not be served later than 30 days after Its.date,

Atty. No.:_4_4_7_5_1 _

Name: Baker & Daniels, LLP, David L. Weinstein, Stacey L. Smiricky

.At~.fur:~P~la~i~n~ti~ff~ ~ _

Address: 311 S. Wacker Drive, Suite 4400

Ci~/State/Zip: Chicago. Illinois 60606

Telephone: 312-212-6555

WITNESS,

1 52011

Clerkof c.oti~f:,:;~~

.\ .~~i}~~ ~t·"{~

Date of service: ..'\,."::/

(To be inserted by officer·,'oo':t,:opy.1:

or other person) , , .'.

Service by Facsimile Transmission will be accepted at: _

(Area Code) (Facsimile Telephone Number)

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

Case: 1:12-cv-00163 Document #: 1-6 Filed: 01/10/12 Page 3 of 6 PageID #:25
IN THE CIRCUIT COURT OIt COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT - LAW DIVISION

Plaintiff,

)

)

)

)

)

)

)

)

)

)

MARCUS EVANS, INC.,

v. No. _

TRACY COENEN and

SEQUENCE, INC., JURY DEMAND

Defendants.

COMPLAINT

r"'- . t " ')

Plaintiff, MARCUS EVANS, INC., through its attorneys, BAKER &:DANIELS, LLP,

.....:. . r~-')

,..... , ..; ,

".' .

for its Complaint against TRACY COENEN and SEQUENCE, INC. states as tdlI()ws:

THE PARTIES C:.~" •

C:.:

~. \.J....... •.

1. Marcus Evans is a Delaware corporation with its North American' headquarters

located at 455 North Cityfront Plaza Drive, 9

th Floor, Chicago, Illinois.

2. Sequence, Inc. is a Wisconsin corporation doing business at 10 South Riverside Plaza,

Suite 1800, Chicago, Illinois("Sequence").

3. Tracy Coenen is an individual who is a resident of Wisconsin, doing business in

Chicago, Illinois, as the owner of Sequence ("Coenen").

JURISDICTION AND VENUE

4. This Court has jurisdiction in this matter because Defendants have submitted to

jurisdiction pursuant to 735 ILCS 5/2-209(a)(l) and (2) and 735 ILCS 5/209(b)(1) and (4).

5. Venue properly lies with this Court, pursuant to Section 2-101 of the Illinois Code

of Civil Procedure.

Case: 1:12-cv-00163 Document #: 1-6 Filed: 01/10/12 Page 4 of 6 PageID #:26
FACTS

Background

6. Marcus Evans is a business information company, providing global business

intelligence and information to assist clients in strategic and effective decision-making. Marcus

Evans provides industry sector-focused events for business learning and networking

opportunities across a variety of industries and professions.

7. Marcus Evans's technology (or CIO) summits feature speakers and programs thai

explore issues in the technology industry. The programs include case study presentations, prearranged business meetings, workshops and round table discussions.

Defendants' Website and Content

8. Defendants maintain a website at www.sequenceinc.com (the "Website").

9. The Website promotes Coenen as a supposed expert in financial and accounting

investigation, including "fraud examinations." The Website promotes "an independent and

unbiased analysis" of cases on which Coenen works.

1O. The Website contains a page captioned "The Fraud Files" wherein Defendants

post statements about various companies, including Marcus Evans. The Website is interactive,

allowing Defendants to communicate with the Website's visitors.

11. On or about July 27, 2011, Defendants posted statements of fact on the

Website related to Marcus Evans, its business and its employees. Specifically, Defendants

titled the post "Marcus Evans Scam: Fraud Complaints About Events and Sales Pitch." A

copy of the July 27, 2011 post is attached at Exhibit A.

12. The untruthful statements include, "Searches for terms like "marcus evans

scam", "marcus evans complaints", and "marcus evans fraud" curiously return numerous

websites that Marcus Evans created about their "fraud events" and such ... clearly an attempt to

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dominate the search engine results for anything related to complaints about the company."

(emphasis in original)

13. The statements of fact in the July 27, 20 II post were untruthful.

14. Defendants knew the statements of fact in the July 27, 20 II were false or had no

reasonable basis for believing the statements to be true.

15. Defendants made the statements maliciously and with an evil intent to injure

Marcus Evans without just cause or excuse.

16. In the same July 27, 2011 post (Ex. A), Defendants re-published statements of

fact made by other individuals related to Marcus Evans, its business and its employees. In that

post, Defendants stated that the re-published statements came from www.ripoffreport.com. a

website that Defendants identified as a "scam" (the "ROP Website"). Defendants also stated in

'.1thispost that the ROP Website contains some "posted complaints" that could be considered not

','

legitimate.

17. The untruthful, republished statements in the July 27, 2011 post included:

(a) "[W]e see what is here and realize just another version of the

Nigerian scam."

(b) "By this I mean the rep will always always say that the only reason

she is able to call you is because one of their existing clients either became

insolvent (went out of business) or has a date conflict, and now has been forced to

forfeit their deposit (of approximately $10,000) and now they are interviewing a

small select handful of appropriate companies in your industry niche with your

exact expertise to take over their client's schedule of 30 prequalified face to face

meetings AND also get to apply the forfeited deposit towards the booking of the

next company who books on.

So they hook you with a made up rare discount opportunity that you think "other

clients of theirs did not have the opportunity to take advantage of', which is

wrong. At the same time, this urgency forces your buying decision to be an

emotional impulse decision because the sales rep will actually tell you that if you

want to take the meetings then you will have to set up a call back later that day or

the very next day within 24 hours. They get you to do this by deceptively lying

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