Circuit Court of Cook County

Law Division

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Renee D. McKinney, Plaintiff

versus

Peter W. Poulos, Defendant

Russ E. Eisenstein

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Complaint(1)

COUNT II - FRAUDULENT MISPREPRESENTATION

  1. On 3 September 2004, Defendant Poulos said to Plaintiff, "Don't worry. We have a contract. I will pay you if I lose the bet on the Derby."
  2. Defendant Poulos intended for Plaintiff to rely on the statement set forth in paragraph 1.
  3. When Defendant Poulos made the statement set forth in paragraph 1, he knew that his representation was false.
  4. Plaintiff relied to her detriment on the statement set forth in paragraph 1 by reducing the amount of student loans she applied for.

COUNT III - INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS

5. On 1 October 2004, Defendant Eisenstein said to Defendant Poulos, "Don't pay that bet. Gambling contracts are not enforceable in Illinois."

6. As a result of the statement set forth in paragraph 5, Defendant Poulos breached his contract to pay Plaintiff $7,000 if his horse did not win the Kentucky Derby.