Case: 1:12-cv-05836 Document #: 568-1 Filed: 10/17/18 Page 1 of 5 PageID #:14873
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Dr. Nicholas Angelopoulos

Plaintiff, Case No. 12 0 05836

V. Honorable Robert M. Dow

Keystone Orthopedic Specialists, S.C.; Martin

R. Hall; and WACHN, LLC,

Defendants.

Third Party Citation to Discover Assets

To: First Midwest Bank. 8750 Brvn Mawr. Suite 1300. Chicago. IL 60631.

YOU ARE COMMANDED to produce the requested documents on or before August 28, 2018 at the law

offices of Gair Eberhard Nelson Dedinas, Ltd, 1 East Wacker Drive, Suite 2600, Chicago, IL 60601

concerning the property or income or indebtedness due to Nicholas Angelopoulos.

A judgment in favor of Nicholas Angelopoulos and against Kevstone Orthopedic Specialists. S.C. was

entered on July 23, 2018 as follows: Count I: $178,594.29; Count II: $560,034.46; Count VI: $454,000;

and for discovery sanctions of $25,175, and the entire judgment remains unsatisfied. Judgement was further

entered against Martin R. Hall as follows: Count I: $178,594.29; Count II: $1,560,034.46; Count III:

$410,777.17 by virtue of Hall's position with WACHN and $709,294.75 by virtue of Hall's position with

Keystone, plus punitive damages of $1,000,000; and for discovery sanctions of $25,175, and the entire

judgment remains unsatisfied. Judgment was further Entered against WACHN. LLC as follows: Count V:

$111,000; and discovery sanctions of $25,175, and the full amount remains unsatisfied.

YOU ARE COMMANDED to produce all books all books, papers, or records in your possession or over

which you have control, which may contain information concerning the property of judgment debtors which

indicates that you are indebted to or holding any funds for the judgment debtors, including those materials

listed on the attached schedule of documents

YOU ARE PRHOHIBITED from making or allowing any transfer or other disposition of, or interfering

with, any property not exempt from the enforcement of a judgment therefrom, a deduction order or

garnishment, belonging to the judgment debtors or to which he, she or it may be entitled or which may

thereafter be acquired by or become due to him, her or it, and from paying over or otherwise disposing of

any moneys not so exempt which are due or to become due to the judgment debtors, until the further order

of the court or the termination of the proceeding whichever occurs first. The third party may not be

obliged to withhold the payment on any moneys beyond double the amount of the balance due sought to

be enforced by the judgment creditor.

Warning

IF YOU FAIL TO APPEAR AS DIRECTED IN THIS NOTICE, YOU MAY BE ARRESTED AND

BROUGHT BEFORE THE COURT TO ANSWER TO A CHARGE OF CONTEMPT OF COURT,

WHICH MAY BE PUNISHABLE BY IMPRISONMENT. YOUR FAILURE TO COMPLY WITH

THE CITATION PROCEEDING MAY RESULT IN A JUDGMENT BEING ENTERED AGIANST

YOU FOR THE UNSATISFIED AMOUNT OF THE JUDGMENT

Case: 1:12-cv-05836 Document #: 568-1 Filed: 10/17/18 Page 2 of 5 PageID #:14874
Certificate of Attorney for Judgment Creditor

Amount of Judgment

Balance Due

Date of Judgment

Court Entering Judgment

Case Number

Against Keystone Orthopedic Specialists, S.C.: Count I:

$ 178,594.29; Count II: $560,034.46; Count VI: $454,000; and

for discovery sanctions of $25,175,

Against Martin R. Hall: Count I: $178,594.29; Count II:

$1,560,034.46; Count III: $410,777.17 by virtue of Hall's

position with WACHN and $709,294.75 by virtue of Hall's

position with Keystone, plus punitive damages of $1,000,000;

and for discovery sanctions of $25,175,

Against WACHN, LLC; Count V: $111,000; and discovery

sanctions of $25,175.

Full amount remains due.

July 23,2018

United States District Court for the Northern District of Illinois

12 C 05836

Dated: August 7, 2018

Certificate of Attorney

The undersigned certifies, under penalty of

perjury, that the information contained herein

is true and correct.

iris Gair (ARDC # 6190781)

Thomas R. Heisler (ARDC # 6296712)

Ryan P. Laurie (ARDC # 6318306)

Gair Eberhard Nelson Dedinas Ltd

1 East Wacker Drive, Suite 2600

Chicago, IL 60601

(312) 600-4900

fffOMAS G BRUTGfsf

Clerk of the United States District-Court

for the Northern District of Jlhnois

AUG 0 7 2018

Case: 1:12-cv-05836 Document #: 568-1 Filed: 10/17/18 Page 3 of 5 PageID #:14875
Schedule of Documents

First Midwest Bank

8750 Bryn Mawr, Suite 1300

Chicago, IL 60631

For the time period from November 1, 2011 to present

Relevant Persons:

a. Martin R. Hall (SSN )

b. Diane M. Hall (SSN )

c. Jennifer A. Hall (partial SSN )

d. Kelly E. Hall (partial SSN )

e. Samantha R. Hall (partial SSN )

f. Keystone Orthopedic Specialists, SC (EIN

g. WACHN, LLC (EIN )

h. Martin R. Hall MD SC (EIN )

i. MedstafF Supply, Inc. (EIN )

j. The Diane M. Hall Trust dated January 26, 1999

k, Diane M. Hall Trust Number One

1. Advanced Orthopedic Specialists, S.C.

m. Vertical Plus MRI

n. Midwest Diagnostics

o. Scan Partners, Inc.

p. Clinical Regenerative Medicine Center, LLC

q. Magnetic Partners, LLC

r. Midwest Physical Therapy, Inc.

s. Upright MRI of Hazel Crest, LLC

t. Iliana Surgery Center

u. Tinley Woods LLC

V. 3838 Main Street Development, LLC

w. Varsity Medical Center

X. Any trust account in which any of the individuals identified in (a) to (e) is the

settlor, executor, grantor, beneficiary, protector, or trustee

y. Any successor to the above

1. All account opening documents, signature cards, and account statements for any account

held in the name of or for the benefit of the Relevant Persons or any other account in which

Martin Hall or Diane Hall has signatory authority

2. All deposit or transfer items in excess of $1000 paid to accounts relating to Relevant

Persons (b) through (e) which deposit or transfer relates to a check or other instrument

issued by Relevant Persons (a) or (f) through (y).

Case: 1:12-cv-05836 Document #: 568-1 Filed: 10/17/18 Page 4 of 5 PageID #:14876
3. All personal or company financial statements prepared or submitted by or on behalf of or

relating to the Relevant Persons.

4. All loan documents, loan statements, or loan applications relating to any of the Relevant

Persons.

5. All credit approvals, credit reviews, or credit relationship summaries.

6. Documents sufficient to identify the collateral relating to any loans relating to the Relevant

Persons.

7. All trust documents relating to Relevant Persons (a) through (e).

Case: 1:12-cv-05836 Document #: 568-1 Filed: 10/17/18 Page 5 of 5 PageID #:14877