EXHIBIT D

Case: 1:20-cv-02227 Document #: 1-4 Filed: 04/09/20 Page 1 of 6 PageID #:17
3610C #58856

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, LAW DIVISION

DONALD SLAMA, )

)

Plaintiff, )

)

vs. ) No. 20 L 001318

)

MICHAEL L. FRANKLIN and )

TYSA TRANSPORT, LLC, )

)

Defendants. )

PROOF OF SERVICE

TO: Stephen J. Healy

The Pappas Law Group, LLC

121 West Wacker Drive, Suite 1612

Chicago, Illinois 60601

sjh@pappaslawgroup.com

Please be advised that on April 8, 2020, we served the following documents 

via electronically to the above listed counsel of record, Request to Admit Facts, a 

copy of which is attached and served here upon you.

Thomas F. Cameli 

Alan J. Brinkmeier

CAMELI & HOAG, P.C.

Attorneys for Defendants

105 West Adams Street, Suite 1430

Chicago, IL 60603

312-726-7300

service@camelihoaglaw.com

Case: 1:20-cv-02227 Document #: 1-4 Filed: 04/09/20 Page 2 of 6 PageID #:18
CERTIFICATE OF SERVICE

I, Michelle Wilburn, a non-attorney, certify that I served the attached 

document to all attorneys of record via email on April 8, 2020.

[x] I make this statement under penalties as

 Provided by law pursuant to Section 1-109 /s/ Michelle Wilburn

 Of the Illinois Code of Civil Procedure

Case: 1:20-cv-02227 Document #: 1-4 Filed: 04/09/20 Page 3 of 6 PageID #:19
1

3610C #58856

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, LAW DIVISION

DONALD SLAMA, )

)

Plaintiff, )

)

vs. ) No. 20 L 001318

)

MICHAEL L. FRANKLIN and )

TYSA TRANSPORT, LLC, )

)

Defendants. )

REQUEST TO ADMIT FACTS

To: Stephen J. Healy

The Pappas Law Group

121 West Wacker Drive, Suite 1612

Chicago, IL 60601

Warning: If you fail to serve the response required by Rule 216 within 28 

days after you are served with this paper, all the facts set forth in the 

requests will be deemed true and all the documents described in the 

requests will be deemed genuine.

NOW COMES the defendant TYSA TRANSPORT, LLC., by and through its 

attorneys CAMELI & HOAG PC, and for its request to admit facts to plaintiff 

DONALD SLAMA, states:

1. Admit that the damage award to you (plaintiff DONALD SLAMA) will 

in no event exceed the jurisdictional amount for diversity purposes of the United 

States District Court for the Northern District of Illinois, which is $75,000.00, 

exclusive of interest and costs.

RESPONSE:

Case: 1:20-cv-02227 Document #: 1-4 Filed: 04/09/20 Page 4 of 6 PageID #:20
2

VERIFICATION

Under penalties as provided by law pursuant to 735 ILCS 5/1-109 of the Code of Civil 

Procedure, the undersigned verifies that the statements set for in this instrument are 

true and correct, except as to matters therein stated to be on information and belief 

and as to such matters the undersigned verifies as aforesaid he verily believes the 

same to be true.

DONALD SLAMA

Case: 1:20-cv-02227 Document #: 1-4 Filed: 04/09/20 Page 5 of 6 PageID #:21
3

Respectfully submitted,

CAMELI & HOAG, P.C.

/s/ Thomas F. Cameli

By: Thomas F. Cameli

Thomas F. Cameli

CAMELI & HOAG, P.C.

Attorneys for the Defendants

105 West Adams Street, Suite 1430

Chicago, IL 60603

312-726-7300

312-726-7302 (fax)

tcameli@camelihoaglaw.com

abrinkmeier@camelihoaglaw.com

service@camelihoaglaw.com

Case: 1:20-cv-02227 Document #: 1-4 Filed: 04/09/20 Page 6 of 6 PageID #:22