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Remote Court date: 12/8/2022 9:00 AM
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
Shazia Khan, as Special Administrator of the Estate of Sania Khan, Deceased
___________________________________________________________
FILED DATE: 10/3/2022 3:07 PM 2022L008911

v.

First Service Residential Illinois, Inc., Grand Ohio Management, et al.

___________________________________________________________
2022L008911
No. ______________________________

CIVIL ACTION COVER SHEET - CASE INITIATION

A Civil Action Cover Sheet - Case Initiation shall be filed with the
complaint in all civil actions. The information contained herein FILED
is for administrative purposes only and cannot be introduced into 10/3/2022 3:07 PM
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may be checked with this cover sheet. COOK COUNTY, IL
2022L008911
■
Jury Demand‰Yes‰No Calendar, H
PERSONAL INJURY/WRONGFUL DEATH 19738612
CASE TYPES: (FILE STAMP)
‰ 027 Motor Vehicle COMMERCIAL LITIGATION
‰ 040 Medical Malpractice
CASE TYPES:
‰ 047 Asbestos
‰ 002 Breach of Contract
‰ 048 Dram Shop
‰ 070 Professional Malpractice
‰ 049 Product Liability
(other than legal or medical)
‰ 051 Construction Injuries
‰ 071 Fraud (other than legal or medical)
(including Structural Work Act, Road
‰ 072 Consumer Fraud
Construction Injuries Act and negligence)
‰ 073 Breach of Warranty
‰ 052 Railroad/FELA
‰ 074 Statutory Action
‰ 053 Pediatric Lead Exposure
(Please specify below.**)
‰ 061 Other Personal Injury/Wrongful Death
‰ 075 Other Commercial Litigation
‰ 063 Intentional Tort
(Please specify below.**)
‰ 064 Miscellaneous Statutory Action
‰ 076 Retaliatory Discharge
(Please Specify Below**)
‰ 065 Premises Liability
OTHER ACTIONS
‰ 078 Fen-phen/Redux Litigation
‰ 199 Silicone Implant CASE TYPES:
‰ 062 Property Damage
TAX & MISCELLANEOUS REMEDIES ‰ 066 Legal Malpractice
CASE TYPES: ‰ 077 Libel/Slander
‰ 007 Confessions of Judgment ‰ 079 Petition for Qualified Orders
‰ 008 Replevin ‰ 084 Petition to Issue Subpoena
‰ 009 Tax ‰ 100 Petition for Discovery
‰ 015 Condemnation ** ___________________________________________________
‰ 017 Detinue
_____________________________________________________
‰ 029 Unemployment Compensation
‰ 031 Foreign Transcript mgallagher@tpmblegal.com
Primary Email: _________________________________________
‰ 036 Administrative Review Action
‰ 085 Petition to Register Foreign Judgment acoogan@tpmblegal.com
Secondary Email: _______________________________________
‰ 099 All Other Extraordinary Remedies
Michael L. Gallagher
By: _______________________________________________ Tertiary Email: _________________________________________
(Attorney) (Pro Se)

Pro Se Only: ‰ I have read and agree to the terms of the Clerk’s O ice Electronic Notice Policy and choose to opt in to electronic notice
form the Clerk’s OGGJDF for this case at this email address: ______________________________________________________________

*3*4
:
."35*/&;, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

Page 1 of 1
 FILED
10/3/2022 3:07 PM
IRIS Y. MARTINEZ
CIRCUIT CLERK
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COOK COUNTY, IL
2022L008911
COUNTY DEPARTMENT, LAW DIVISION Calendar, H
FILED DATE: 10/3/2022 3:07 PM 2022L008911

SHAZIA KHAN, as Special Administrator of the )

Estate of SANIA KHAN, Deceased, )
)
Plaintiff, )
vs. ) No.
2022L008911
)
FIRST SERVICE RESIDENTIAL ILLINOIS ) Plaintiff Demands Trial by Jury
INC.; GRAND OHIO MANAGEMENT; )
TITAN SECURITY GROUP INC.; and ) Attorney Affidavit Attached
203-2015 EAST OHIO STREET, LLC. )
)
Defendants. )

COMPLAINT AT LAW

COMMON ALLEGATIONS

1. On and before July 18, 2022, and at all times material, there was a building located

at 211 East Ohio Street, in the City of Chicago, County of Cook, State of Illinois (hereinafter

referred to as “the Building”).

2. On and before July 18, 2022, and at all times material, the Building comprised of

29 floors totaling approximately 586 separate residential units.

3. On and before July 18, 2022, and at all times material, public access was generally

limited to the ground floor of the Building.

4. On and before July 18, 2022, and at all times material, public access was not

permitted in the ground floor lobby for loiterers, trespassers and/or those who posed a danger to

others.

5. On and before July 18, 2022, and at all times material, permission was required to

access the elevator bank located on the ground floor lobby of the Building.
 6. On or about July 18, 2022, and at all times material, access to the elevator bank

located on the ground floor lobby was controlled and required authorization to gain entry.
FILED DATE: 10/3/2022 3:07 PM 2022L008911

7. On or about July 18, 2022, and at all times material, after receiving authorization,

admission to the floors above the lobby containing the residential units was generally gained by

use of the elevators.

8. On or about July 18, 2022, and at all times material, upon information and belief

visitors that sought access to the secured elevator bank on the ground floor lobby were required to

provide Building security personnel a form of government issued identification.

9. On or about July 18, 2022, and at all times material, upon information and belief

Building security personnel were required to review the visitor’s identification to determine if they

had any safety alerts associated with their name or were on a “no-entry” list.

10. On or about July 18, 2022, and at all times material, upon information and belief

Building personnel were required to escort

The Parties

11. On and before July 18, 2022, and at all times material, Plaintiff’s decedent, SANIA

KHAN, was a resident and citizen of the City of Chicago, County of Cook, and State of Illinois.

12. On and before July 18, 2022, SANIA KHAN was a tenant of the Building and

resided in apartment Number 2817 located on the 28th floor of the Building.

13. On and before July 18, 2022, SANIA KHAN had authorization to be in the Building

and on the 28th floor of the Building.

14. On and before July 18, 2022, and at all times material, Defendant FIRST SERVICE

RESIDENTIAL ILLINOIS, INC. (hereinafter “FIRST SERVICE”) managed and/or operated the

2
 Building. FIRST SERVICE’S headquarters was located at 303 East Wacker Drive 1900, Chicago,

Cook County, Illinois.

FILED DATE: 10/3/2022 3:07 PM 2022L008911

15. On and before July 18, 2022, and at all times material, Defendant GRAND OHIO

MANAGEMENT (hereinafter “GRAND OHIO”) managed and/or operated the Building.

GRAND OHIO’S headquarter was located at 211 East Ohio Street, Chicago, Cook County,

Illinois.

16. On and before July 18, 2022, and at all time material, Defendant 203-2015 EAST

OHIO STREET LLC. (hereinafter “EAST OHIO”) owned and/or operated the Building. EAST

OHIO’S headquarter is located at 312 Trinity Lane, Oakbrook, DuPage County, Illinois.

17. On and before July 18, 2022, and at all times material, Defendant TITAN

SECURITY GROUP INC. (hereinafter “TITAN”), provided security services at the Building.

TITAN’S headquarter was located at 616 West Monroe Street, Chicago, Cook County, Illinois.

18. On and before July 18, 2022, and at all times material, UNKOWN FEMALE

RENTAL AGENT NO. 1, was acting in the course and scope of her employment and/or agency

with FIRST SERVICE.

19. On and before July 18, 2022, and at all times material, UNKOWN FEMALE

RENTAL AGENT NO. 1, was acting in the course and scope of her employment and/or agency

with GRAND OHIO.

20. On and before July 18, 2022, and at all times material, UNKOWN FEMALE

RENTAL AGENT NO. 1, was acting in the course and scope of her employment and/or agency

with EAST OHIO.

3
 21. On and before July 18, 2022, and at all times material, UNKNOWN MALE

SECURITY GUARD NO. 1, was acting in the course and scope of his agency with FIRST
FILED DATE: 10/3/2022 3:07 PM 2022L008911

SERVICE.

22. On and before July 18, 2022, and at all times material, UNKNOWN MALE

SECURITY GUARD NO. 1, was acting in the course and scope of his agency with GRAND

OHIO.

23. On and before July 18, 2022, and at all times material, UNKNOWN MALE

SECURITY GUARD NO. 1, was acting in the course and scope of his agency with EAST OHIO.

24. On and before July 18, 2022, and at all times material, UNKNOWN MALE

SECURITY GUARD NO. 1, was acting in the course and scope of his employment and/or agency

with TITAN.

25. On and before July 18, 2022, and at all times material, UNKNOWN MALE

SECURITY GUARD NO. 2, was acting in the course and scope of his agency with FIRST

SERVICE.

26. On and before July 18, 2022, and at all times material, UNKNOWN MALE

SECURITY GUARD NO. 2, was acting in the course and scope of his agency with GRAND

OHIO.

27. On and before July 18, 2022, and at all times material, UNKNOWN MALE

SECURITY GUARD NO. 2, was acting in the course and scope of his agency with EAST OHIO.

The Provision of Security at the Building

4
 28. On and prior to July 18, 2022, and at all times material, FIRST SERVICE had onsite

agents, including, without limit, TITAN security personnel concentrating on providing security
FILED DATE: 10/3/2022 3:07 PM 2022L008911

services at the Building.

29. On and prior to July 18, 2022, and at all times material, GRAND OHIO had onsite

agents, including, without limit, TITAN security personnel concentrating on providing security

services at the Building.

30. On and prior to July 18, 2022, and at all times material, EAST OHIO had onsite

agents, including, without limit, TITAN security personnel concentrating on providing security

services at the Building.

31. On and prior to July 18, 2022, and at all times material, FIRST SERVICE had onsite

employees and/or agents concentrating on showing potential tenants available residential units

located in the Building.

32. On and prior to July 18, 2022, and at all times material, GRAND OHIO had onsite

employees and/or agents concentrating on showing potential tenants available residential units

located in the Building.

33. On and prior to July 18, 2022, and at all times material, EAST OHIO had onsite

employees and/or agents concentrating on showing potential tenants available residential units

located in the Building.

34. On and prior to July 18, 2022, and at all times material, the FIRST SERVICE,

individually and/or by and through their agents and/or employees instituted, voluntarily undertook,

contracted to perform, provided and/or maintained security services at the Building. These security

services included, without limit:

5
 a. Instituting and maintaining policies, procedures, plans and post orders concerning
the provision of security services, including without limit workplace violence,
access control, restraint, and/or civil disorder, and those policies, procedures, plans
FILED DATE: 10/3/2022 3:07 PM 2022L008911

and post orders:

1. Authorized the inspection of bags and/or packages;

2. Prohibited weapons;

3. Directed that the elevator bank doors be locked to prevent access to the
lobby elevators that accessed the residential floors above;

4. Directed that police be called in an emergency;

5. Directed that police be called where an individual is uncooperative, a

danger and/or threat;

6. Dictated that there be a response to suspicious activity and/or unusual

events;

7. Prohibited loitering;

8. Prohibited trespassers;

9. Directed that duress/alarm emergency codes over the radio be used in

emergency and/or security situations;

10. Directed that tenants be notified of security situations and/or emergencies;

11. Dictated that those posing a danger be kept away from others;

12. Directed that those who pose a danger be restrained;

13. Directed that those who pose a danger be delayed;

14. Directed that interlopers, trespassers, loiterers, and/or those who pose a
danger and/or threat be barred from accessing the lobby elevators and
residential floors above;

b. Providing security officers;

c. Contracting with TITAN and others to assist in the provision of security services
and provide security services;

6
 d. Requiring initial and periodic training of security officers/personnel on the
provision of security services;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

e. Controlling access to certain areas and the floors above the ground floor by:

1. Installing access control devices to limit access to the elevators;

2. Stationing security officers at a security desk located in the lobby;

3. Stationing security officers and equipment in the lobby to check-in guests

and/or visitors;

4. Requiring visitors seeking access to gain approval of security

officers/personnel by checking in with identification and having the
approval of the tenant that the individual is seeking to visit and/or others;

5. Requiring tenants, employees of tenants and/or others to utilize a key FOB

to pass through access control devices; and

6. Stating that the primary responsibility of security officers is to prohibit

unauthorized access above the lobby floor;

f. Requiring security officers to remain at their post until they are relieved or
communicate to others that they are leaving their post; and/or

g. Placing cameras in and around the Building. (Hereinafter, and previously, the
aforementioned actions/allegations in this paragraph are generally referred to as
“security services”).

35. On and prior to July 18, 2022, and at all times material, FIRST SERVICES,

individually and/or by and through their agents and/or employees, recognized that in implementing

and providing security services:

a. Security as the highest priority;

b. The initial response to an emergency will nearly always determine the

success or failure in resolving the crises;

c. The proper handling of a situation can prevent it from escalating into a

crises;

d. A safe environment should be maintained;

7
 e. Emergencies can lead to death;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

f. Security provides protection against hazards; and/or

g. Domestic violence must be addressed and can result in murder.

36. On and prior to July 18, 2022, and at all times material, the GRAND OHIO,

individually and/or by and through their agents and/or employees instituted, voluntarily undertook,

contracted to perform, provided and/or maintained security services at the Building. These security

services included, without limit:

a. Instituting and maintaining policies, procedures, plans and post orders concerning
the provision of security services, including without limit workplace violence,
access control, restraint, and/or civil disorder, and those policies, procedures, plans
and post orders:

1. Authorized the inspection of bags and/or packages;

2. Prohibited weapons;

3. Directed that the elevator bank doors be locked to prevent access to the
lobby elevators that accessed the residential floors above;

4. Directed that police be called in an emergency;

5. Directed that police be called where an individual is uncooperative, a

danger and/or threat;

6. Dictated that there be a response to suspicious activity and/or unusual

events;

7. Prohibited loitering;

8. Prohibited trespassers;

9. Directed that duress/alarm emergency codes over the radio be used in

emergency and/or security situations;

10. Directed that tenants be notified of security situations and/or emergencies;

8
 11. Dictated that those posing a danger be kept away from others;

12. Directed that those who pose a danger be restrained;

FILED DATE: 10/3/2022 3:07 PM 2022L008911

13. Directed that those who pose a danger be delayed;

14. Directed that interlopers, trespassers, loiterers, and/or those who pose a
danger and/or threat be barred from accessing the lobby elevators and
residential floors above;

b. Providing security officers;

c. Contracting with TITAN and others to assist in the provision of security services
and provide security services;

d. Requiring initial and periodic training of security officers/personnel on the

provision of security services;

e. Controlling access to certain areas and the floors above the ground floor by:

1. Installing access control devices to limit access to the elevators;

2. Stationing security officers at a security desk located in the lobby;

3. Stationing security officers and equipment in the lobby to check-in guests

and/or visitors;

4. Requiring visitors seeking access to gain approval of security

officers/personnel by checking in with identification and having the
approval of the tenant that the individual is seeking to visit and/or others;

5. Requiring tenants, employees of tenants and/or others to utilize a key FOB

to pass through access control devices; and

6. Stating that the primary responsibility of security officers is to prohibit

unauthorized access above the lobby floor;

f. Requiring security officers to remain at their post until they are relieved or
communicate to others that they are leaving their post; and/or

g. Placing cameras in and around the Building. (Hereinafter, and previously, the
aforementioned actions/allegations in this paragraph are generally referred to as
“security services”).

9
 37. On and prior to July 18, 2022, and at all times material, GRAND OHIO,

individually and/or by and through their agents and/or employees, recognized that in implementing
FILED DATE: 10/3/2022 3:07 PM 2022L008911

and providing security services:

a. Security as the highest priority;

b. The initial response to an emergency will nearly always determine the

success or failure in resolving the crises;

c. The proper handling of a situation can prevent it from escalating into a

crises;

d. A safe environment should be maintained;

e. Emergencies can lead to death;

f. Security provides protection against hazards; and/or

g. Domestic violence must be addressed and can result in murder.

38. On and prior to July 18, 2022, and at all times material, the EAST OHIO,

individually and/or by and through their agents and/or employees instituted, voluntarily undertook,

contracted to perform, provided and/or maintained security services at the Building. These security

services included, without limit:

a. Instituting and maintaining policies, procedures, plans and post orders concerning
the provision of security services, including without limit workplace violence,
access control, restraint, and/or civil disorder, and those policies, procedures, plans
and post orders:

1. Authorized the inspection of bags and/or packages;

2. Prohibited weapons;

3. Directed that the elevator bank doors be locked to prevent access to the
lobby elevators that accessed the residential floors above;

4. Directed that police be called in an emergency;

10
 5. Directed that police be called where an individual is uncooperative, a
danger and/or threat;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

6. Dictated that there be a response to suspicious activity and/or unusual

events;

7. Prohibited loitering;

8. Prohibited trespassers;

9. Directed that duress/alarm emergency codes over the radio be used in

emergency and/or security situations;

10. Directed that tenants be notified of security situations and/or emergencies;

11. Dictated that those posing a danger be kept away from others;

12. Directed that those who pose a danger be restrained;

13. Directed that those who pose a danger be delayed;

14. Directed that interloper, trespassers, loiterers, and/or those who pose a
danger and/or threat be barred from accessing the lobby elevators and
residential floors above;

b. Providing security officers;

c. Contracting with TITAN and others to assist in the provision of security services
and provide security services;

d. Requiring initial and periodic training of security officers/personnel on the

provision of security services;

e. Controlling access to certain areas and the floors above the ground floor by:

1. Installing access control devices to limit access to the elevators;

2. Stationing security officers at a security desk located in the lobby;

3. Stationing security officers and equipment in the lobby to check-in guests

and/or visitors;

11
 4. Requiring visitors seeking access to gain approval of security
officers/personnel by checking in with identification and having the
approval of the tenant that the individual is seeking to visit and/or others;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

5. Requiring tenants, employees of tenants and/or others to utilize a key FOB

to pass through access control devices; and

6. Stating that the primary responsibility of security officers is to prohibit

unauthorized access above the lobby floor;

f. Requiring security officers to remain at their post until they are relieved or
communicate to others that they are leaving their post; and/or

g. Placing cameras in and around the Building. (Hereinafter, and previously, the
aforementioned actions/allegations in this paragraph are generally referred to as
“security services”).

39. On and prior to July 18, 2022, and at all times material, EAST OHIO, individually

and/or by and through their agents and/or employees, recognized that in implementing and

providing security services:

a. Security as the highest priority;

b. The initial response to an emergency will nearly always determine the

success or failure in resolving the crises;

c. The proper handling of a situation can prevent it from escalating into a

crisis;

d. A safe environment should be maintained;

e. Emergencies can lead to death;

f. Security provides protection against hazards; and/or

g. Domestic violence must be addressed and can result in murder.

40. On and prior to July 18, 2022, and at all times material, TITAN, individually and/or

by and through their employees instituted, voluntarily undertook, contracted to perform, and

provided security services at the Building. These security services included, without limit:

12
 a. Instituting and maintaining policies, procedures, plans and post orders concerning
the provision of security services, including without limit workplace violence,
access control, restraint, and/or civil disorder, and those policies, procedures, plans
FILED DATE: 10/3/2022 3:07 PM 2022L008911

and post orders:

1. Authorized the inspection of bags and/or packages;

2. Prohibited weapons;

3. Directed that the elevator bank doors be locked to prevent access to the
lobby elevators that accessed the residential floors above;

4. Directed that police be called in an emergency;

5. Directed that police be called where an individual is uncooperative, a

danger and/or threat;

6. Dictated that there be a response to suspicious activity and/or unusual

events;

7. Prohibited loitering;

8. Prohibited trespassers;

9. Directed that duress/alarm emergency codes over the radio be used in

emergency and/or security situations;

10. Directed that tenants be notified of security situations and/or emergencies;

11. Dictated that those posing a danger be kept away from others;

12. Directed that those who pose a danger be restrained;

13. Directed that those who pose a danger be delayed;

14. Directed that interlopers, trespassers, loiterers, and/or those who pose a
danger and/or threat be barred from accessing the lobby elevators and
residential floors above;

b. Providing security officers;

c. Contracting with TITAN and others to assist in the provision of security services
and provide security services;

13
 d. Requiring initial and periodic training of security officers/personnel on the
provision of security services;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

e. Controlling access to certain areas and the floors above the ground floor by:

1. Installing access control devices to limit access to the elevators;

2. Stationing security officers at a security desk located in the lobby;

3. Stationing security officers and equipment in the lobby to check-in guests

and/or visitors;

4. Requiring visitors seeking access to gain approval of security

officers/personnel by checking in with identification and having the
approval of the tenant that the individual is seeking to visit and/or others;

5. Requiring tenants, employees of tenants and/or others to utilize a key FOB

to pass through access control devices; and

6. Stating that the primary responsibility of security officers is to prohibit

unauthorized access above the lobby floor;

f. Requiring security officers to remain at their post until they are relieved or
communicate to others that they are leaving their post; and/or

g. Placing cameras in and around the Building. (Hereinafter, and previously, the
aforementioned actions/allegations in this paragraph are generally referred to as
“security services”).

41. On and prior to July 18, 2022, and at all times material, TITAN, individually and/or

by and through their agents and/or employees, recognized that in implementing and providing

security services:

a. Security as the highest priority;

b. The initial response to an emergency will nearly always determine the

success or failure in resolving the crises;

c. The proper handling of a situation can prevent it from escalating into a

crises;

d. A safe environment should be maintained;

14
 e. Emergencies can lead to death;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

f. Security provides protection against hazards; and/or

g. Domestic violence must be addressed and can result in murder.

Defendants Prior Notice that Raheel Ahmad was a Threat to Physically Harm Sania Khan

42. On June 19, 2021, SANIA KHAN married Raheel Ahmad (hereinafter “Ahmad”).

43. Upon information and belief, Ahmad had undiagnosed mental health issues that

SANIA KHAN was unaware of when the couple was married.

44. On or about December 7, 2021, Ahmad had a mental health episode while he and

SANIA KHAN were in their shared apartment Number 2817 located on the 28th floor of the

Building.

45. On or about December 7, 2021, upon information and belief Ahmad attempted to

commit suicide by jumping out of the apartment’s 28th floor window.

46. On or about December 7, 2021, upon information and belief Ahmad attempted to

physically harm SANIA KHAN by pulling/pushing her out of the apartment’s 28th floor window.

47. On or about December 7, 2021, upon information and belief the Chicago Police

Department was emergently contacted and informed that Ahmad had attempted suicide and

attempted to physically harm SANIA KHAN.

48. On or about December 7, 2021, upon information and belief Chicago Police

Department officer(s) facilitated transferring Ahmad to a downtown hospital for acute mental

health treatment.

15
 49. On or about December 7, 2021, FIRST SERVICE, individually and/or by and

through their agents and/or employees, were placed on notice of Ahmad’s suicide attempt and the
FILED DATE: 10/3/2022 3:07 PM 2022L008911

physical threat of great bodily harm that he posed to SANIA KHAN.

50. On or about December 7, 2021, GRAND OHIO, individually and/or by and through

their agents and/or employees, were placed on notice of Ahmad’s suicide attempt and the physical

threat of great bodily harm that he posed to SANIA KHAN.

51. On or about December 7, 2021, EAST OHIO, individually and/or by and through

their agents and/or employees, were placed on notice of Ahmad’s suicide attempt and the physical

threat of great bodily harm that he posed to SANIA KHAN.

52. On or about December 7, 2021, TITAN, individually and/or by and through their

agents and/or employees, were placed on notice of Ahmad’s suicide attempt and the physical threat

of great bodily harm that he posed to SANIA KHAN.

53. In response to the December 7, 2021 incident, SANIA KHAN notified Defendants

FIRST SERVICE, GRAND OHIO, EAST OHIO, and/or TITAN, that Ahmad was to be removed

from the apartment’s lease and was not to be allowed in the Building. SANIA KHAN’s request to

have Ahmad removed from the lease and not to be allowed in the Building provided Defendants

FIRST SERVICE, GRAND OHIO, EAST OHIO, and TITAN, notice that Ahmad posed a physical

threat of great bodily harm to SANIA KHAN.

54. In response to the December 7, 2021 incident, SANIA KHAN enlisted Defendants

FIRST SERVICE, GRAND OHIO, EAST OHIO, and/or TITAN, to change the locks on her

apartment door in order to ensure that Ahmad would not gain entry to her apartment. SANIA

KHAN’S request to change the locks on her apartment door provided Defendants FIRST

16
 SERVICE, GRAND OHIO, EAST OHIO, and/or TITAN, further notice that Ahmad posed a

physical threat of great bodily harm to SANIA KHAN.

FILED DATE: 10/3/2022 3:07 PM 2022L008911

55. On February 8, 2022, SANIA KHAN filed a Petition for Dissolution of Marriage

which was filed with the Circuit Court of Cook County.

56. In the Spring of 2022, upon information belief SANIA KHAN personally notified

Defendants FIRST SERVICE, GRAND OHIO, EAST OHIO, and/or TITAN again that Ahmad

was not allowed to enter the Building because she felt threatened by his presence. SANIA

KHAN’S additional notification that Ahmad was not allowed to enter the Building provided

Defendants FIRST SERVICE, GRAND OHIO, EAST OHIO, and/or TITAN, further notice that

Ahmad posed a physical threat of great bodily harm to SANIA KHAN.

The Attack

57. In the days prior to July 18, 2022, Ahmad contacted agents and/or employees of

Defendants FIRST SERVICE, GRAND OHIO and/or EAST OHIO to inquire about renting

various apartments located the Building.

58. In the days prior to July 18, 2022, Ahmad spoke with UNKNOWN FEMALE

RENTAL AGENT NO. 1 and coordinated with her a date and time at which she would show

Ahmad various rental apartments in the Building.

59. On the morning of July 18, 2022, Ahmad entered the Building with two large

suspicious packages and walked past the security desk which was occupied by UNKNOWN

MALE SECURITY GUARD No. 1. The unknown male security guard failed to request that

Ahmad provide his identification prior to entering the secured area of the Building in violation of

various policies and/or post-orders. The unknown male security guard failed to inspect the

17
 suspicious packages prior to Ahmad entering the secured area of the Building in violation of

various policies and/or post-orders.

FILED DATE: 10/3/2022 3:07 PM 2022L008911

60. Immediately thereafter, Ahmad met with the UNKNOWN FEMALE RENTAL

AGENT NO. 1 in the lobby of the Building. The unknown female failed to request that Ahmad

provide his identification prior to entering the secured area of the Building in violation of various

policies and/or post-orders.

61. The UNKNOWN FEMALE RENTAL AGENT NO. 1 then escorted Ahmad past

the secured door into the lobby elevator bank providing him access to the residential area of the

Building in violation of various policies and/or post-orders.

62. The UKNOWN MALE SECURITY GUARD NO. 1 pressed the access button

located at his security desk allowing the locked door to be opened and granting Ahmad access to

secured elevator bank. The unknown male security guard’s failure to unlock the door without

requesting Ahmad’s identification was in violation of various policies and/or post-orders.

63. Upon information and belief, the UNKNOWN FEMALE RENTAL AGENT NO.

1 proceeded to show Ahmad several rental apartments prior to him requesting that he be allowed

to remain in the secured residential area unaccompanied.

64. Upon information and belief, the UNKNOWN FEMALE RENTAL AGENT NO.

1 granted Ahmad’s request and allowed him to remain in the secured residential area

unaccompanied in violation of various policies and/or post-orders.

65. The UNKNOWN FEMALE RENTAL AGENT NO. 1’S failure to escort Ahmad

from the secured residential area and while in possession of two suspicious packages was in

violation of various policies and/or post-orders.

18
 66. Ahmad proceeded to the 28th floor of the Building unabated and while in possession

of the two suspicious packages, one of which contained a loaded handgun.

FILED DATE: 10/3/2022 3:07 PM 2022L008911

67. Ahmad proceeded to gain entry to SANIA KHAN’S 28th floor apartment before

shooting and killing her.

68. Ahmad then turned the handgun on himself and committed suicide.

Count I

(Wrongful Death - FIRST SERVICE RESIDENTIAL ILLINOIS, INC.;

individually and/or by and through their agents and/or employees)

NOW COMES Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, FIRST SERVICE RESIDENTIAL

ILLINOIS, INC., individually and/or by and through their agents and/or employees, pleading

hypothetically and in the alternative, state as follows:

1-68. Plaintiff repeats and realleges the Common Allegations listed in paragraphs 1

through 68 above.

69. On and before July 18, 2022, FIRST SERVICE, individually and/or by and through

their agents and/or employees voluntarily assumed, contracted to perform, and owed a duty of care

to provide security services at the Building and for the residents in the Building; and to ensure the

safety of all persons and property and for the protection of life at the Building.

70. On and before July 18, 2022, and at all times material, FIRST SERVICE

individually and/or by and through their agents and/or employees including, was then and there

negligent in one or more of the following respects:

19
 a. Failing to prohibit individuals from having weapons in the Building including
Ahmad in violation of polices and/post orders;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

b. Failing to request that visitors including Ahmad provide their government issued
identification upon entering the Building and walking past the security desk;

c. Failing to inspect the suspicious bags and/or packages of visitors including Ahmad
in violation of policies and/or post orders;

d. Failing to request visitors including Ahmad provide their government issued

identification prior to opening the secured door to the ground floor elevator bank;

e. Failing to compare a visitor’s including Ahmad’s government issued identification

against any “no-entry” lists and barring his entry into the secured residential area;

f. Failing to ensure that visitors including Ahmad remain accompanied by

Defendant’s agents and/or employees at all times while remaining in the secured
residential area;

g. Failing to ensure that visitors including Ahmad were escorted by Defendant’s

agents and/or employees past the secured residential area;

h. Providing Ahmad with unauthorized access to the 28th floor of the Building;

i. Failing to prevent Ahmad from shooting and killing SANIA KHAN despite prior
notice that Ahmad posed a physical threat of great bodily harm to SANIA KHAN;

j. Failing to follow initial and periodic training for the provision of security services;
and

k. Failing to provide reasonable security services.

71. As a proximate result of the foregoing negligent acts and/or omissions, the

survivors of SANIA KHAN have sustained substantial pecuniary loss, including the loss of her

society, companionship, services, and support, and expenses for funeral and burial.

72. At the time of her death, SANIA KHAN left surviving her: mother Shazia Khan,

father Haider Khan, sister Eman Khan, and her brother Haris Khan.

20
 73. Plaintiff brings this action under the Illinois Wrongful Death Act, 740 ILCS 180/1

and 2.
FILED DATE: 10/3/2022 3:07 PM 2022L008911

WHEREFORE, Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, FIRST SERVICE RESIDENTIAL

ILLINOIS, INC., requests judgment against Defendant, FIRST SERVICE RESIDENTIAL

ILLINOIS, INC., individually and/or by and through their agents and/or employees, in an amount

in excess of FIFTY THOUSAND DOLLARS ($50,000.00) as shall represent fair and just

compensation.

Count II

(Wrongful Death - GRAND OHIO MANAGEMENT;

individually and/or by and through their agents and/or employees)

NOW COMES Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, GRAND OHIO MANAGEMENT,

individually and/or by and through their agents and/or employees, pleading hypothetically and in

the alternative, state as follows:

1-68. Plaintiff repeats and realleges the allegations listed in paragraphs 1 through 68

above.

69. On and before July 18, 2022, GRAND OHIO MANAGEMENT, individually

and/or by and through their agents and/or employees voluntarily assumed, contracted to perform,

and owed a duty of care to provide security services at the Building and for the residents in the

21
 Building; and to ensure the safety of all persons and property and for the protection of life at the

Building.
FILED DATE: 10/3/2022 3:07 PM 2022L008911

70. On and before July 18, 2022, and at all times material, GRAND OHIO

MANAGEMENT, individually and/or by and through their agents and/or employees including,

was then and there negligent in one or more of the following respects:

a. Failing to prohibit individuals from having weapons in the Building including

Ahmad in violation of polices and/post orders;

b. Failing to request that visitors including Ahmad provide their government issued
identification upon entering the Building and walking past the security desk;

c. Failing to inspect the suspicious bags and/or packages of visitors including Ahmad
in violation of policies and/or post orders;

d. Failing to request visitors including Ahmad provide their government issued

identification prior to opening the secured door to the ground floor elevator bank;

e. Failing to compare a visitor’s including Ahmad’s government issued identification

against any “no-entry” lists and barring his entry into the secured residential area;

f. Failing to ensure that visitors including Ahmad remain accompanied by

Defendant’s agents and/or employees at all times while remaining in the secured
residential area;

g. Failing to ensure that visitors including Ahmad were escorted by Defendant’s

agents and/or employees past the secured residential area;

h. Providing Ahmad with unauthorized access to the 28th floor of the Building;

i. Failing to prevent Ahmad from shooting and killing SANIA KHAN despite prior
notice that Ahmad posed a physical threat of great bodily harm to SANIA KHAN;

j. Failing to follow initial and periodic training for the provision of security services;
and

k. Failing to provide reasonable security services.

22
 71. As a proximate result of the foregoing negligent acts and/or omissions, the

survivors of SANIA KHAN have sustained substantial pecuniary loss, including the loss of her
FILED DATE: 10/3/2022 3:07 PM 2022L008911

society, companionship, services, and support, and expenses for funeral and burial.

72. At the time of her death, SANIA KHAN left surviving her: mother Shazia Khan,

father Haider Khan, sister Eman Khan, and her brother Haris Khan.

73. Plaintiff brings this action under the Illinois Wrongful Death Act, 740 ILCS 180/1

and 2.

WHEREFORE, Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, GRAND OHIO MANAGEMENT,

requests judgment against Defendant, GRAND OHIO MANAGEMENT, individually and/or by

and through their agents and/or employees, in an amount in excess of FIFTY THOUSAND

DOLLARS ($50,000.00) as shall represent fair and just compensation.

Count III

(Wrongful Death - TITAN SECURITY GROUP INC.;

individually and/or by and through their agents and/or employees)

NOW COMES Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, TITAN SECURITY GROUP INC.,

individually and/or by and through their agents and/or employees, pleading hypothetically and in

the alternative, state as follows:

1-68. Plaintiff repeats and realleges the Common Allegations listed in paragraphs 1

through 68 above.

23
 69. On and before July 18, 2022, TITAN SECURITY GROUP INC., individually

and/or by and through their agents and/or employees voluntarily assumed, contracted to perform,
FILED DATE: 10/3/2022 3:07 PM 2022L008911

and owed a duty of care to provide security services at the Building and for the residents in the

Building; and to ensure the safety of all persons and property and for the protection of life at the

Building.

70. On and before July 18, 2022, and at all times material, TITAN SECURITY GROUP

INC. individually and/or by and through their agents and/or employees including, was then and

there negligent in one or more of the following respects:

a. Failing to prohibit individuals from having weapons in the Building including

Ahmad in violation of polices and/post orders;

b. Failing to request that visitors including Ahmad provide their government issued
identification upon entering the Building and walking past the security desk;

c. Failing to inspect the suspicious bags and/or packages of visitors including Ahmad
in violation of policies and/or post orders;

d. Failing to request visitors including Ahmad provide their government issued

identification prior to opening the secured door to the ground floor elevator bank;

e. Failing to compare a visitor’s including Ahmad’s government issued identification

against any “no-entry” lists and barring his entry into the secured residential area;

f. Failing to ensure that visitors including Ahmad remain accompanied by

Defendant’s agents and/or employees at all times while remaining in the secured
residential area;

g. Failing to ensure that visitors including Ahmad were escorted by Defendant’s

agents and/or employees past the secured residential area;

h. Providing Ahmad with unauthorized access to the 28th floor of the Building;

i. Failing to prevent Ahmad from shooting and killing SANIA KHAN despite prior
notice that Ahmad posed a physical threat of great bodily harm to SANIA KHAN;

24
 j. Failing to follow initial and periodic training for the provision of security services;
and
FILED DATE: 10/3/2022 3:07 PM 2022L008911

k. Failing to provide reasonable security services.

71. As a proximate result of the foregoing negligent acts and/or omissions, the

survivors of SANIA KHAN have sustained substantial pecuniary loss, including the loss of her

society, companionship, services, and support, and expenses for funeral and burial.

72. At the time of her death, SANIA KHAN left surviving her: mother Shazia Khan,

father Haider Khan, sister Eman Khan, and her brother Haris Khan.

73. Plaintiff brings this action under the Illinois Wrongful Death Act, 740 ILCS 180/1

and 2.

WHEREFORE, Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, TITAN SECURITY GROUP INC.,

requests judgment against Defendant, TITAN SECURITY GROUP INC., individually and/or by

and through their agents and/or employees, in an amount in excess of FIFTY THOUSAND

DOLLARS ($50,000.00) as shall represent fair and just compensation.

Count IV

(Wrongful Death – 203-2015 EAST OHIO STREET, LLC;

individually and/or by and through their agents and/or employees)

NOW COMES Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, 203-2015 EAST OHIO STREET, LLC,

25
 individually and/or by and through their agents and/or employees, pleading hypothetically and in

the alternative, state as follows:

FILED DATE: 10/3/2022 3:07 PM 2022L008911

1-68. Plaintiff repeats and realleges the Common Allegations listed in paragraphs 1

through 68 above.

69. On and before July 18, 2022, 203-2015 EAST OHIO STREET, LLC, individually

and/or by and through their agents and/or employees voluntarily assumed, contracted to perform,

and owed a duty of care to provide security services at the Building and for the residents in the

Building; and to ensure the safety of all persons and property and for the protection of life at the

Building.

70. On and before July 18, 2022, and at all times material, 203-2015 EAST OHIO

STREET, LLC individually and/or by and through their agents and/or employees including, was

then and there negligent in one or more of the following respects:

a. Failing to prohibit individuals from having weapons in the Building including

Ahmad in violation of polices and/post orders;

b. Failing to request that visitors including Ahmad provide their government issued
identification upon entering the Building and walking past the security desk;

c. Failing to inspect the suspicious bags and/or packages of visitors including Ahmad
in violation of policies and/or post orders;

d. Failing to request visitors including Ahmad provide their government issued

identification prior to opening the secured door to the ground floor elevator bank;

e. Failing to compare a visitor’s including Ahmad’s government issued identification

against any “no-entry” lists and barring his entry into the secured residential area;

f. Failing to ensure that visitors including Ahmad remain accompanied by

Defendant’s agents and/or employees at all times while remaining in the secured
residential area;

26
 g. Failing to ensure that visitors including Ahmad were escorted by Defendant’s
agents and/or employees past the secured residential area;
FILED DATE: 10/3/2022 3:07 PM 2022L008911

h. Providing Ahmad with unauthorized access to the 28th floor of the Building;

i. Failing to prevent Ahmad from shooting and killing SANIA KHAN despite prior
notice that Ahmad posed a physical threat of great bodily harm to SANIA KHAN;

j. Failing to follow initial and periodic training for the provision of security services;
and

k. Failing to provide reasonable security services.

71. As a proximate result of the foregoing negligent acts and/or omissions, the

survivors of SANIA KHAN have sustained substantial pecuniary loss, including the loss of her

society, companionship, services, and support, and expenses for funeral and burial.

72. At the time of her death, SANIA KHAN left surviving her: mother Shazia Khan,

father Haider Khan, sister Eman Khan, and her brother Haris Khan.

73. Plaintiff brings this action under the Illinois Wrongful Death Act, 740 ILCS 180/1

and 2.

WHEREFORE, Plaintiff, SHAZIA KHAN, as Special Administrator of the Estate of

SANIA KHAN, Deceased, by and through her attorneys, TAXMAN, POLLOCK, MURRAY &

BEKKERMAN, LLC., hereby complaining of Defendant, 203-2015 EAST OHIO STREET, LLC,

requests judgment against Defendant, 203-2015 EAST OHIO STREET, LLC, individually and/or

by and through their agents and/or employees, in an amount in excess of FIFTY THOUSAND

DOLLARS ($50,000.00) as shall represent fair and just compensation.

By: ________________ _____ __

Attorneys for Plaintiff

Michael L. Gallagher
27
 TAXMAN, POLLOCK, MURRAY & BEKKERMAN, LLC
225 W. Wacker Drive, Suite 1650
Chicago, IL 60606
FILED DATE: 10/3/2022 3:07 PM 2022L008911

T: (312) 586-1700
F: (312) 586-1701
Firm No.: 61090
mgallagher@tpmblegal.com

and

Furqan Mohammed
Mohammed, Shamaileh & Tabahi, LLC
2040 N. Harlem Avenue
Elmwood Park, IL 60707
(847) 916-7800
Firm No. 61514
fmohammed@mstlawfirm.com

28
 FILED
10/3/2022 3:07 PM
IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
2022L008911
Calendar, H
FILED DATE: 10/3/2022 3:07 PM 2022L008911

2022L008911