Case: 1:20-cv-05302 Document #: 1 Filed: 09/08/20 Page 1 of 14 PageID #:1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS – EASTERN DIVISION
ROBIN J. ADAMS, as Trustee for The Robin
Adams Living Trust Dated May 24, 2005,

Plaintiff,

v. No.

PARCEL C LLC, a Delaware limited liability JURY DEMANDED

company, and MAGELLAN MARKETING
GROUP LLC, an Illinois limited liability
company,

Defendants.

COMPLAINT AT LAW

NOW COMES Plaintiff ROBIN J. ADAMS, as Trustee of The Robin Adams Living Trust

Dated May 24, 2005, by his attorneys, Scott M. Levin and Leo G. Aubel, and for his Complaint

against Defendants PARCEL C LLC, a Delaware limited liability company, and MAGELLAN

MARKETING GROUP LLC, an Illinois limited liability company, states as follows:

PARTIES

1. Plaintiff Robin J. Adams (“Adams”) is a Michigan resident, who resides in

Northville, Wayne County, Michigan.

2. Defendant Parcel C LLC (“Parcel C”) is a Delaware limited liability company

qualified to do business in Illinois, with its principal place of business in Chicago, Illinois.

a. The records of the Illinois Secretary of State identify only the managers of
Parcel C, being Magellan Parcel C/D LLC and Wanda Chicago Real Estate
LLC.

b. The records of the Illinois Secretary of State identify only the managers of
Magellan Parcel C/D LLC, being five individuals with addresses in
Chicago, Illinois.

c. Wanda Chicago Real Estate LLC is a Delaware limited liability company

qualified to do business in Illinois. The records of the Illinois Secretary of

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State identify only a manager, being Wanda Americas Commercial

Properties.

d. There is no Illinois Secretary of State record of Wanda Americas

Commercial Properties.

e. On information and belief, none of the members of Parcel C or its related

limited liability companies are residents of Michigan.

3. Defendant Magellan Development Group LLC (“Magellan Development Group”)

is an Illinois limited liability company.

a. The records of the Illinois Secretary of State identify two limited liability
companies named Magellan Development Group. One is File Number
00298646. The other is File Number 08059489. Both are Illinois limited
liability companies.

b. The records of the Illinois Secretary of State show that LLC File Number
00298646 was dissolved on May 31, 2019, and show only the managers on
the date of dissolution, being five individuals with addresses in Chicago,
Illinois.

c. The records of the Illinois Secretary of State identify only a manager of LLC
file number 08059489, being Magellan Holdco LLC.

d. Magellan Holdco LLC is a Delaware limited liability company qualified to

do business in Illinois. The records of the Illinois Secretary of State identify
only the managers of Magellan Holdco LLC, being four individuals with
addresses in Chicago, Illinois.

e. On information and belief, none of the members of Magellan Development

Group or its related limited liability companies are residents of Michigan.

JURISDICTION AND VENUE

4. Jurisdiction is proper pursuant to the diversity jurisdiction provisions of 28 U.S.C.

§1332, in that the amount in controversy is in excess of $75,000, exclusive of interests and costs,

and the parties are citizens of different states. Venue is proper in the Eastern Division of this Court

because the property at issue is located in Chicago, Illinois.

FACTS COMMON TO ALL COUNTS

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5. In April 2017, Adams became aware of a building planned for a site in the River

East neighborhood of Chicago, then known as the Wanda Vista Tower (the “Vista”).

6. Adams contacted his real estate broker, Naomi Wilkinson (“Wilkinson”), to arrange

a visit to the Vista. Wilkinson has been a licensed Illinois real estate broker since 2002. At all

relevant times, Wilkinson’s supervising managing broker was Magellan Realty. At all relevant

times, the president and licensed managing broker of Magellan Realty was Leila H. Zammatta

(“Zammatta”).

7. At all relevant times, Zammatta was Senior Vice President for Sales for Parcel C.

On a date after the Purchase Agreement at issue in this matter was executed, Wilkinson became a

sales agent for Parcel C.

8. Adams and Wilkinson visited the Vista sales center in April and May 2017

regarding the purchase of a full-floor, penthouse condominium unit. Adams, Wilkinson and

Zammatta met and had conversations with other sales representatives for the Vista, including Sean

Linnane (“Linnane”). Linnane is executive vice president for Magellan Development Group.

Adams was provided with marketing materials and Parcel C’s form purchase agreement.

9. In the meetings with Parcel C’s agents, the only penthouse floor plan shown to

Adams was titled “Custom Full Floor Residence” (the “Custom Plan”). A true and accurate copy

of the Custom Plan is attached hereto as Exhibit A and incorporated herein. The Custom Plan

shows only the exterior walls, the balconies, and spaces and improvements that serve the entire of

the building, such as the elevator, staircase and mechanical spaces.

10. During one of Adams’ meetings with Parcel C’s agents, Zammatta gave Adams

floor plans for numerous penthouse floors, all of which were similar in detail to the Custom Plan,

except for the square footage. Zammatta stated that the Custom Plan was an “open floor plan” and

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that Adams would be able to design the unit as he chose. Adams asked Zammatta questions about

the Custom Plan. Zammatta responded saying Adams should discuss with Linnane how the build-

out would be handled.

11. Subsequently, Adams had a number of meetings with Linnane, most of which

included Wilkinson. At the initial meeting with Linnane, Adams was told by Linnane that Adams

could lay out the floor plan of the unit as he desired.

12. At either the initial meeting or the second meeting, Adams showed Linnane a rough

drawing of Adams’ proposed floor plan. Linnane told Adams the drawing was acceptable, pending

actual riser and waste stack locations on the floor, which had not yet been determined. Linnane

stated that Adams could either use Parcel C’s architect or Adams’ own architect. Linnane stated

to Adams he could have the unit built as he wanted and Adams could use any of the recommended

finishes without additional charge, including those that would have been regarded as an upgrade

in units other than the penthouses.

13. On or about May 2, 2017, Adams and Parcel C entered into a Purchase Agreement

(the “Purchase Agreement”) related to Unit 8101 (“Unit 8101”). The Purchase Price under the

Purchase Agreement is $9,665,604. A true and correct copy of the Purchase Agreement is attached

hereto as Exhibit B and incorporated herein. On June 16, 2018, the parties entered into the First

Amended Attorney Modifications Rider (the “Rider”). A true and correct copy of the Rider is

attached hereto as Exhibit B-1 and incorporated herein.1

14. When the Purchase Agreement was signed, the Custom Plan was initialed by

Adams and attached to the Purchase Agreement. There was no other floor plan attached to the

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The only copy of the Purchase Agreement in Adams’ possession is of poor quality and difficult to read. Attached
as Exhibit B-2 is a copy of the form purchase agreement used by Parcel C, which, on information and belief, is the
form used to create the Purchase Agreement.

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Purchase Agreement. Other than the location of the walls, elevator and mechanical core, and the

building stairwell, the Custom Plan is blank. Upon information and belief, Parcel C did not have

any floor plan for Unit 8101 other than the Custom Plan on the date when the Purchase Agreement

was signed by the parties because the parties intended that Unit 8101 would be custom-designed.

Parcel C never advised Adams that it had a form floor plan for Unit 8101 or the penthouses, and

never showed one to him.

15. At the time the Purchase Agreement was executed, Parcel C had not developed any

floor plans for the penthouse units other than the Custom Plan.

16. Adams paid to Magellan Marketing Group all of the Earnest Money due under the

Purchase Agreement. The total amount of Earnest Money paid by Adams and being held by

Magellan Marketing Group is $1,449,840.60 (the “Earnest Money”).

17. When Adams signed the Purchase Agreement, Linnane provided Adams with the

option of either using Parcel C’s architectural services or using Adams’ own architect to develop

a floor plan for Unit 8101. Adams chose to use his own architect.

18. On January 15, 2018, Adams provided drawings of his proposed floor plan to

Linnane. The January 2018 drawing was given to Linnane to assist Parcel C in its discussions

regarding the location of utility risers, waste stacks and other floor plan design constraints that

might be potential limitations on how Adams designed Unit 8101, and to meet the contingency in

Paragraph 5 of the Rider to the Purchase Agreement. The proposed floor plans had four bedrooms,

4 baths/2 half-baths, a family room with a fireplace, kitchen, dining room, and a living room with

fireplace and bar.

19. Shortly after delivering the January 15, 2018 drawings, Adams and Wilkinson met

with Linnane to review the drawings. Linnane stated that the plans looked acceptable and that

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Parcel C should be able to work utility risers and waste stacks to accommodate the plans. Linnane

stated that the utility risers and waste stacks locations had not been 100% finalized and the location

contingency in Paragraph 5 of the Rider would probably have to be extended. As of January 2018,

Parcel C had not indicated that Parcel C would itself be proposing any floor plan for Unit 8101.

20. On June 22, 2018, Linnane emailed to Adams certain “Guidelines for Designers,”

a “Penthouse Finish Book” and “MEP constraint diagrams,” referring to mechanical, electrical and

plumbing. A true and accurate copy of the June 22, 2018 email is attached hereto as Exhibit C

and incorporated herein. As part of that email, Parcel C provided its final mechanical, electrical

and plumbing design to Adams.

21. In that June 22, 2018 email, Linnane provided a rough drawing, prepared by

Linnane or someone on his behalf, utilizing Adams’ proposed floor plan to demonstrate how

Adams’ floor plan would fit within the MEP constraint diagrams. The email states, “You are

certainly welcome to layout the unit as you wish, so long as plumbing locational restrictions are

adhered to, but we thought this exercise would be helpful.” Attached to the June 22, 2018 email

was a drawing described by Linnane as “a third drawing in this file that has a default unit that

works with the plumbing constraints. You can ignore this drawing.”

22. These designs and drawing provided in Linnane’s June 22, 2018 email were

acceptable to Adams and he then waived the contingency in Paragraph 5 of the Rider.

23. On August 7, 2018, Adams’ architect provided to Linnane some further refinements

to Adams’ proposed floor plan, based in part on the MEP constraint diagrams. Between that date

and late November 2018, Adams; Adams’ architects; Parcel C’s architects; Linnane; and Mark

Hauser, Parcel C’s project coordinator (“Hauser”), frequently consulted with each other on

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revisions to Adams’ floor plan to, among other things, accommodate plumbing riser and HVAC

locations.

24. On December 17, 2018, Adams’ architects provided Hauser with a Review Set and

a Specifications binder, being the sum and substance of Adams’ floor plan. Hauser responded on

December 21, 2018 by requesting that certain details be updated to meet the requirements for

Parcel C’s permitting and construction drawings. True and accurate copies of the December emails

are attached hereto as Exhibit D and incorporated herein.

25. On January 3, 2019, Adams received an email from his architect with a final bill,

which stated the architect had provided to Parcel C final floor plan drawings, design drawings, and

fixture and finish selections (the “2019 Floor Plan”). At no time during the period from January

15, 2018, when Adams submitted his first proposed floor plan, through January 3, 2019, when the

2019 Floor Plan was submitted, did Parcel C indicate that there was or would be any other floor

plan proposed by Parcel C that would be applicable to Unit 8101.

26. Through most of 2019, the 2019 Floor Plan formed the basis of discussions and

communications between Adams, an interior design firm, a cabinetry maker, and various of Parcel

C’s representatives regarding kitchen, dining room and bathroom elevation designs, including

appliance locations and finish selections.

27. At no time during the period from January 3, 2019, when the 2019 Floor Plan was

submitted to Parcel C, through November 15, 2019 did Parcel C indicate that there was or would

be any other floor plan proposed by Parcel C that would be applicable to Unit 8101.

28. Adams met with Hauser on November 15, 2019, to discuss an electrical and lighting

plan for Unit 8101. For the first time, Hauser suggested that additional funds would be necessary

to complete Unit 8101 as specified in the 2019 Floor Plan. Hauser told Adams that Parcel C’s

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general contractor had provided a bid to Parcel C based on a 3-bedroom, 3½-bathroom unit floor

plan. This floor plan was never shown to Adams. Hauser did not have a copy to show Adams at

that meeting. Hauser stated that Adams would be expected to pay the difference in the construction

price between this phantom 3-bedroom, 3½-bathroom unit floor plan and the 2019 Floor Plan.

29. At the November 15, 2019 meeting, Adams denied that there was any contractual

obligation on his part to pay anything to Parcel C in addition to the $9,665,604.00 Purchase Price

for the construction of Unit 8101 in accordance with the 2019 Floor Plan. Adams showed Hauser

the Purchase Agreement with the open floor Custom Plan to show the build-out was never intended

to be a 3-bedroom, 3½-bathroom unit. Hauser stated that he did not get involved in Adams’ project

until the fall of 2018, more than a year after the Purchase Agreement had been signed. He also

stated that he did not know the history of the Purchase Agreement or discussions about it prior to

then. Hauser then requested that Adams meet with Linnane to discuss the additional payments

being demanded by Parcel C.

30. On February 28, 2020, Adams met with Linnane. Hauser participated in the

meeting telephonically. Adams again denied that there was any contractual obligation on his part

to pay anything to Parcel C in addition to the Purchase Price. Adams showed Linnane the Purchase

Agreement with the open floor Custom Plan to show the build-out was never intended to be a 3-

bedroom, 3½-bathroom unit.

31. On March 4, 2020, Hauser sent an email to Adams, providing for the first time a

preliminary list of “purchaser break-outs,” showing Parcel C’s pricing for “upgrades” to Parcel

C’s phantom 3-bedroom, 3½-bathroom unit plan.

32. On March 10, 2020, Adams emailed Linnane, stating that he had never agreed to

have any “pre-planned floor layout” serve as the basis for any part of the Purchase Agreement.

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Also on March 10, 2020, Linnane responded, stating that a 3-bedroom, 3½-bathroom unit plan

would not constitute a base from which additional charges would be unilaterally assessed against

Adams by Parcel C, asserting that “the baseline would be 4.5 baths,” for which he would provide

Adams with a “revised number.” Linnane never provided a revised number. True and accurate

copies of the March 10, 2020 emails are attached hereto as Group Exhibit E and incorporated

herein.

33. On March 12, 2020, Linnane emailed Adams, asserting that the “blank floor plan

[the Custom Plan] does not imply anything,” while admitting that Parcel C “did market the unit as

a 4 Bdrm / 4.5 bath,” further stating that “despite the fact that our construction contract was based

on 3/3.5, I’m willing to absorb the cost of the incremental bath.” A true and accurate copy of this

March 12, 2020 email is attached hereto as Exhibit F and incorporated herein. Linnane did not

dispute Adams’ statement that he had never agreed to have any “pre-planned floor layout” serve

as the basis for any part of the Purchase Agreement.

34. On April 9, 2020, Adams emailed Linnane and requested a copy of the 4 bdm/4.5

bath plan that you are using as a basis,” as referred to in Linnane’s March 10 and 12, 2020 emails.

A true and accurate copy of the April 9, 2020 email is attached hereto as Exhibit G and

incorporated herein. Linnane never provided to Adams the requested “4 bdm/4.5 bath plan.”

35. On April 9, 2020, Linnane emailed Adams, stating that Parcel C’s “basis document”

for the floor plan was “actually a 3/3.5,” but he was moving the basis up to a 4/4.5. A true and

accurate copy of the April 9, 2020 email is attached hereto as Exhibit H and incorporated herein.

The April 9, 2020 email did not state that Adams had ever been presented or approved either a 3-

bed/3.5-bathroom or a 4-bedroom/4.5-bathroom floor plan.

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36. On May 12, 2019, Hauser told Adams that “layout pricing,” meaning an increased

Purchase Price, had still not been determined by Parcel C, and that the Parcel C was not backing

down from its demand for an increase to the Purchase Price related to the January 2019 Floor Plan.

37. On May 13, 2020, Adams sent a notice to Parcel C stating that he had rescinded the

Purchase Agreement due to the disagreement over the plans and pricing for Unit 8101, and

demanding a refund of the Earnest Money. A true and accurate copy of the May 13, 2020 Notice

is attached as Exhibit I and incorporated herein.

38. Parcel C has refused and continues to refuse to refund the Earnest Money.

COUNT I
(BREACH OF CONTRACT)

39. Adams repeats and realleges Paragraphs 1-38 of the Complaint, inclusive, as and

for Paragraph 39 of this Count I.

40. Pursuant to the Purchase Agreement, Parcel C provided the Custom Plan, being an

open floor plan, and, for the Purchase Price of $9,665,604, agreed to construct Unit 8101 to a floor

plan to be developed by either Parcel C or Adams’ architect. The parties agreed that Adams’

architect would develop the floor plan and later created the 2019 Floor Plan.

41. Parcel C has breached the Purchase Agreement by refusing to use the 2019 Floor

Plan unless Adams paid for additional costs beyond the Purchase Price.

42. Pursuant to Paragraph 14(c) of the Purchase Agreement, if Parcel C defaults, it is

required to return to Adams:

all sums theretofore paid to [to Parcel C by Adams], with interest, actually accrued
on the Earnest Money, and shall reimburse [Adams] in an amount equal to
[Adams’] verified out-of-pocket expenses incurred in connection with this
Agreement (which reimbursement shall not exceed seven hundred fifty dollars
($750.00)), as the sole and exclusive remedy of Purchaser hereunder.” This
Agreement shall thereupon be null and void and of no further force or effect, and
neither party shall have any further obligation hereunder.

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43. Adams has paid to Parcel C $1,449,840.60 in Earnest Money.

WHEREFORE, Plaintiff Robin Adams prays that this Court to enter judgment in his favor

and against Defendant Parcel C LLC in the amount of $1,449,840.60, plus out-of-pocket expenses

of $750, interest on the Earnest Money, and costs.

COUNT II
(ILLINOIS CONSUMER FRAUD ACT)

44. Adams repeats and realleges Paragraphs 1-43 inclusive as and for Paragraph 44 of

this Count II.

45. Parcel C’s practice of executing purchase agreements for penthouse units and only

showing customers the Custom Plan was a deceptive act or practice.

46. Parcel C intended that Adams rely on the deceptive act or practice.

47. The deception occurred in a course of conduct involving trade and commerce.

WHEREFORE, Plaintiff Robin Adams prays that this Court to enter judgment in his favor

and against Defendant Parcel C LLC in an amount to be determined at trial, plus attorney’s fees

and costs.

COUNT III
(RESCISSION – CONDOMINIUM ACT)

48. In the alternative, Adams repeats and realleges Paragraphs 1-43 inclusive as and

for Paragraph 48 of this Count III.

49. Section 22 of the Illinois Condominium Property Act (765 ILCS 605/22) (the

“Act”) provides, in pertinent part:

Full disclosure before sale. In relation to the initial sale or offering for sale of any
condominium unit, the seller must make full disclosure of, and provide copies to the
prospective buyer of, the following information relative to the condominium project:

(a) the Declaration;

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(b) the Bylaws of the association;

(c) a projected operating budget for the condominium unit to be sold to the
prospective buyer, including full details concerning the estimated monthly
payments for the condominium unit, estimated monthly charges for
maintenance or management of the condominium property, and monthly
charges for the use of recreational facilities; and

(d) a floor plan of the apartment to be purchased by the prospective buyer and
the street address of the unit, if any, and if the unit has no unique street
address, the street address of the project.

...

All of the information required by this Section which is available at the time shall
be furnished to the prospective buyer before execution of the contract for sale.
Thereafter, no changes or amendments may be made in any of the items furnished
to the prospective buyer which would materially affect the rights of the buyer or
the value of the unit without obtaining the approval of at least 75% of the buyers
then owning interest in the condominium. If all of the information is not available
at the time of execution of the contract for sale, then the contract shall be voidable
at option of the buyer at any time up until 5 days after the last item of required
information is furnished to the prospective buyer, or until the closing of the sale,
whichever is earlier. Failure on the part of the seller to make full disclosure as
required by this Section shall entitle the buyer to rescind the contract for sale at any
time before the closing of the contract and to receive a refund of all deposit moneys
paid with interest thereon at the rate then in effect for interest on judgments.

(emphasis added)

50. Adams never received “a floor plan of the apartment to be purchased” as required

by Section 22 of the Act and has demanded a rescission of the Purchase Agreement.

WHEREFORE, Plaintiff Robin Adams prays that this Court rescind the Purchase

Agreement, order Defendant Parcel C LLC to release the Earnest Money to Adams, award Adams

his costs of suit, and provide such further relief as this Court deems appropriate.

COUNT IV
(RESCISSION – MUTUAL MISTAKE OF FACT)

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51. In the alternative, Adams repeats and realleges Paragraphs 1- 43 inclusive as and

for Paragraph 51 of this Count IV.

52. Adams believed that, for the Purchase Price, he was purchasing Unit 8101 built out

per his specifications, which became embodied in the 2019 Floor Plan.

53. At the time the Purchase Agreement was executed, the parties had two different,

incompatible understandings with respect to the floor plans and who would bear the cost of

building Unit 8101 pursuant to those plans. There was, therefore, no meeting of the minds on a

material issue of the Purchase Agreement.

54. A return of the $1,449,840.60 in Earnest Money to Adams will restore the parties

to the status quo ante.

55. The Purchase Agreement must be rescinded.

WHEREFORE, Plaintiff Robin Adams prays that this Court rescind the Purchase

Agreement, order Defendant Parcel C LLC to release the Earnest Money to Adams, award Adams

his costs of suit, and provide such further relief as this Court deems appropriate.

COUNT V
(DECLARATORY JUDGMENT)

56. Adams repeats and realleges Paragraphs 1-55 inclusive as and for Paragraph 56 of

this Count V.

57. Pursuant to Paragraph 2 of the Purchase Agreement, the Earnest Money “shall be

held in a segregated account by Seller’s sales agent [Magellan Marketing Group] for the benefit

of [Adams] and if the date of the Closing is more than forty five (45) days from the date of this

Agreement, the Earnest Money will bear interest for [Adams’] benefit as required by applicable

law.”

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58. Magellan Marketing Group, as Escrowee, holds the Earnest Money pursuant to the

terms of the Purchase Agreement.

59. On May 13, 2020, Adams made a written demand for the Earnest Money held by

Magellan Marketing Group.

60. Parcel C refused to consent to the release of the Earnest Money to Adams.

61. Adams and Parcel C have conflicting claims to the Earnest Money.

62. Magellan Marketing Group has no cognizable legal interest in the Earnest Money

other than to hold it in a segregated account “for the benefit of the Purchaser.”

63. An actual dispute exists between the parties with respect to the disposition of the

Earnest Money being held by Magellan Marketing Group, LLC pursuant to the Purchase

Agreement.

PLAINTIFF DEMANDS TRIAL BY JURY.

WHEREFORE, Plaintiff Robin Adams prays that this Court:

A. Declare that he is entitled to be paid the Earnest Money.

B. Order Defendant Magellan Marketing Group, LLC to pay the Earnest Money to
Adams.

C. Provide such further relief as this Court deems appropriate.

ROBIN ADAMS, as Trustee for The Robin Adams

Living Trust Dated May 24, 2005

/s/ Scott M. Levin

One of his attorneys

Scott M. Levin (sml@h2law.com) - ARDC #6185743

Leo G. Aubel (lga@h2law.com) - ARDC #6192847
Howard & Howard Attorneys PLLC
200 S. Michigan Avenue, Suite 1100
Chicago, Illinois 60604
(312) 456-3418
4847-0448-7624, v. 1

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