IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT LAW DIVISION

CASEY LOOP,

Plaintiff,

vs.

CHICAGO TRANSIT AUTHORITY and DOE

DEFENDANTS 1 through 10,

Defendants.

Case No.:

AD DAMNUM OVER $50,000

COMPLAINT

Plaintiff Casey Loop, by and through his counsel, the Tsamis Law Firm, P.C., as and for

his complaint against Defendant Chicago Transit Authority and Doe Defendants 1 through 10,

states as follows:

STATEMENT OF PARTIES

1. Plaintiff Casey Loop (hereinafter Plaintiff), during all relevant dates herein, was

and is still, a resident of Cook County, Illinois.

2. Defendant Chicago Transit Authority (hereinafter CTA) is an independent

governmental agency of the State of Illinois created by the Metropolitan Transit Authority Act

(70 ILCS 3605/1 et seq.) with its principal place of business located in Cook County, Illinois.

3. Plaintiff is unaware of the true names and capacities of defendants sued herein as

Doe Defendants 1 through 10, inclusive, and therefore sues these defendants under such

fictitious names. Plaintiff will amend this Complaint to allege their true names and capacities

when ascertained.

JURISDICTION AND VENUE

4. This Court has jurisdiction over the causes of action alleged herein.

5. Venue is proper in this Court pursuant to 735 ILCS 5/2-101 because the

transactions giving rise to Plaintiffs cause of action occurred in Cook County, Illinois.

6. Plaintiff is a resident of Cook County, Illinois and has been during all relevant

dates herein.

7. Defendant CTA conducts business in Cook County, Illinois.

FACTUAL ALLEGATIONS

8. Plaintiff was hired by CTA as a budget project consultant in February 2012.

9. Plaintiffs performance as a budget project consultant was exemplary, as

evidenced by an increase in salary in July 2012 and subsequent increases in responsibility,

culminating in his promotion to Manager of Performance Analysis in June 2013.

10. Plaintiff, in the performance of his duties as budget consultant, discovered severe

accounting irregularities in the CTAs fiscal year 2013 budget.

11. After his promotion to Manager of Performance Analysis, Plaintiff was requested

by Tom McKone, Vice President of Budget & Capital, to continue to assist the budget team to

work through the troubles they had with the budget.

12. Upon information and belief, Plaintiffs discovery was significant because of

well-publicized budgetary problems which had plagued the CTA for many years.

13. The Regional Transportation Authority (hereinafter RTA) is an independent

governmental unit of the State of Illinois. Its responsibilities include oversight of the three

transit agencies in northeastern Illinois: the CTA, Metra and Pace.

14. Upon information and belief, Plaintiff voiced his concerns about the CTA budget

during regular meetings with the CTA Vice President of Budget & Capital, Tom McKone, and

Chief Financial Officer, Ron DeNard, who proposed resolutions that were, in Plaintiffs

professional opinion, not implementable, illegal and not in the best interests of the public interest

or public safety.

15. Upon information and belief, Plaintiffs supervisors at CTA ignored his report of

irregularities which Plaintiff honestly believed were illegal if not highly unethical since the

irregularities worked to misrepresent CTAs fiscal condition to the public.

16. On July 29, 2013, Plaintiff submitted a written report of his concerns to the RTA,

specifically identifying McKone and DeNard as failing to manage their fiscal responsibility in an

effective and transparent manner. See copy of written report attached hereto as Exhibit A.

17. On July 30, 2013, Plaintiff forwarded a copy of the report to Andrell Holloway,

CTAs Chief Internal Auditor, requesting an investigation into his allegations, and further

requested confidentiality pursuant to 140 ILCS 174.

18. Approximately fifteen minutes after contacting Holloway, Plaintiff received a

phone call from Chief Financial Officer Ronald DeNard, who accused Plaintiff of being

disingenuous for reporting his concerns to the RTA. Plaintiff informed DeNard he did not feel

comfortable continuing the conversation and the call ended.

19. Upon information and belief, two days later, on August 1, 2013, Plaintiffs access

to all internal computer and information systems was terminated, preventing him from

continuing many of his job duties and making his ability to perform his responsibilities

extremely difficult.

20. Upon information and belief, Plaintiffs colleagues were instructed to cease any

further collaboration with him on work-related projects.

21. Upon information and belief, on August 4, 2013, Plaintiff forwarded his report to

the Illinois Office of Executive Inspector General (hereinafter OEIG) via an online

whistleblower submission form.

22. Upon information and belief, on August 6, 2013, Plaintiff met with a CTA-

assigned independent auditor for more than three hours to discuss his report and provide

clarifications.

23. On August 8, 2013, Plaintiff submitted a formal request for reinstatement of his

access privileges to CTA administration, but did not receive any response. See Exhibit B.

24. On August 16, 2013, Plaintiff was finally contacted by the RTA to discuss the

specifics of his report.

25. Upon information and belief, on August 19, 2013, Plaintiff met with the RTA

officials at their central office for more than three hours to discuss the contents of his report.

26. Upon information and belief, on August 23, 2013, Plaintiff was contacted by an

OEIG investigator who requested his permission to forward his report to the Executive Director

of the RTA, having determined the RTA was best equipped to handle any related investigation.

27. On September 11, 2013, Plaintiff was notified by the CTA that his position was to

be abolished on November 11, 2013 in a reorganization of department personnel.

28. Upon information and belief, the decision to abolish Plaintiffs position was made

by individuals in the CTA Finance department, including McKone and DeNard.

29. On September 12, 2013, Plaintiff notified the Human Resources department at

CTA that it was his belief the abolishment of his position was retaliatory.

30. Upon information and belief, CTA general counsel responded to Plaintiff that

same day and ordered him to cease further communications with Human Resources and advised

him that the abolishment of his position was final and irreversible.

31. Upon information and belief, on October 7, 2013, CTA General Counsel formally

denied Plaintiffs request for reinstatement of his access privileges.

32. On November 11, 2013, Plaintiffs employment with CTA was terminated.

COUNT I

VIOLATION OF ILLINOIS WHISTLEBLOWER ACT (740 ILCS 174/1 et seq.)

33. Plaintiff re-alleges and incorporates each preceding paragraph by reference

herein.

34. Plaintiff was, at all relevant times herein, an employee of CTA as that term is

defined in the Illinois Whistleblower Act, 740 ILCS 174/1 et seq. (hereinafter the Act).

35. CTA was, at all relevant times herein, Plaintiffs employer as that term is defined

in the Act.

36. Plaintiff, as a manager of performance analysis for CTA, was responsible for

analysis of the CTA budget for fiscal year 2013.

37. Based upon his analysis of CTAs budget for fiscal year 2013, Plaintiff had a

reasonable belief that CTAs senior financial team was abrogating its fiduciary responsibility to

the CTA, the RTA, the State of Illinois and the citizens and taxpayers of Illinois by endorsing a

budget which, in Plaintiffs professional opinion, was inaccurate, misleading, not financially

sound and contrary to the public policy of the State of Illinois.

38. Plaintiff had a reasonable belief that he had a duty to report the results of his

analysis of the CTA budget for fiscal year 2013 to RTA, which is tasked with oversight of CTA

finances.

39. As a direct result of Plaintiffs report of financial irregularities to the RTA, CTA

eliminated his position and terminated his employment.

40. CTAs actions in eliminating Plaintiffs position and terminating his employment

were in retaliation for his reporting of financial irregularities to the RTA and in violation of the

Act.

41. As a direct and proximate result of CTAs violation of the Act, Plaintiff has

suffered damages including, but not limited to, lost wages, damage to his reputation, emotional

and physical distress and costs of suit.

42. It has been necessary for Plaintiff to retain the services of an attorney to prosecute

this action against Defendants.

COUNT II

RETALIATORY DISCHARGE

43. Plaintiff re-alleges and incorporates each preceding paragraph by reference

herein.

44. Plaintiff was, at all relevant times herein, an employee of CTA.

45. Plaintiff, as a manager of performance analysis for CTA, was responsible for

analysis of the CTA budget for fiscal year 2013.

46. Based upon his analysis of CTAs budget for fiscal year 2013, Plaintiff had a

reasonable belief that CTAs senior financial team was abrogating its fiduciary responsibility to

the CTA, the RTA, the State of Illinois and the citizens and taxpayers of Illinois by endorsing a

budget which, in Plaintiffs professional opinion, was inaccurate, misleading, not financially

sound and contrary to the public policy of the State of Illinois.

47. Plaintiff had a reasonable belief that he had a duty to report the results of his

analysis of the CTA budget for fiscal year 2013 to RTA, which is tasked with oversight of CTA

finances.

48. Plaintiffs reporting of his analysis of the CTA budget for fiscal year 2013 and its

financial irregularities to RTA was legally protected conduct.

49. As a direct result of Plaintiffs report of his analysis of the CTA budget for fiscal

year 2013 and its financial irregularities to the RTA, CTA eliminated his position and terminated

his employment.

50. CTAs actions in eliminating Plaintiffs position and terminating his employment

were in retaliation for his reporting of financial irregularities to the RTA and in violation of the

Act.

51. As a direct and proximate result of CTAs violation of the Act, Plaintiff has

suffered damages including, but not limited to, lost wages, damage to his reputation, emotional

and physical distress and costs of suit.

52. It has been necessary for Plaintiff to retain the services of an attorney to prosecute

this action against Defendants.

RELIEF REQUESTED

WHEREFORE, Plaintiff Casey Loop requests this Honorable Court enter judgment in his

favor against Defendant Chicago Transit Authority and Doe Defendants 1 through 10, and award

him the following relief:

For Count I:

a. Reinstatement with the same seniority status that the employee would have had, but for the violation;

b. Back pay, with interest; and

c. Compensation for any other damages sustained as a result of the violation, including litigation costs, expert witness fees, and reasonable attorney's fees;

d. Such further relief as this Honorable Court deems necessary and just.

For Count II:

a. Actual damages suffered by Plaintiff adequate to compensate him;

b. Compensatory damages suffered by Plaintiff, including but not limited to lost wages, front pay and future wages;

c. Exemplary damages;

d. Pre-judgment interest;

e. Post-judgment interest;

f. Compensation for any other damages sustained as a result of Defendants wrongful acts, including litigation costs, expert witness fees, and reasonable

attorney's fees;

g. Such further relief as this Honorable Court deems necessary and just.

DATED May 6, 2014.

Respectfully Submitted.

TSAMIS LAW FIRM, P.C.

By: ______________________________

BETTY TSAMIS, ESQ.

One of Plaintiffs Attorneys Attorney No.: 47062

Betty Tsamis, Esq.

Email: btsamis@tsamislaw.com

Christopher T. Smith, Esq.

Email: csmith@tsamislaw.com

TSAMIS LAW FIRM, P.C.

1509 West Berwyn Ave., Suite 201E

Chicago, Illinois 60640

Phone: (866) 703-5509

Attorneys for Plaintiff

EXHIBIT A

EXHIBIT A

EXHIBIT A

CHICAGO TRANSIT AUTHORITY FY13 BUDGET & REFORECAST

Page 1

OVERVIEW

My name is Casey Loop and I am a manager of Performance Analysis at the Chicago Transit Authority. I am writing in regards to the Authoritys FY13 budget and their year-to-date financial performance. As of Friday, July 26th, 2013 the Authority is forecasting a year end variance to budget of -$52,140,973. This negative variance is driven by -$33,686,240 in unfavorable revenue expectations, and -$18,454,733 in unfavorable operating expenses. The intent of this submission is to advise the Regional Transportation Authority (in accordance with 740 ILCS 174

Whistleblower Act) of the status of the Chicago Transit Authoritys financial health and allege that this variance is driven by willful disregard of fiduciary responsibility by the senior financial team at the CTA. I feel it is my personal responsibility as a member of the management team to provide transparency to these facts while there is still time to affect change during the fiscal year. For the prior two months, I have contributed to the discussions involving the current crisis, and I feel that the Vice President of Budget & Capital, Tom McKone, and the Chief Financial Officer, Ron DeNard, have failed to manage their fiscal responsibility in a transparent and effective manner. In my professional opinion, this failure is a combination of technical inability, gross negligence, and personal indifference.

HISTORY

Prior to my current position, I was a Budget Consultant assigned to Bus Operations and Maintenance. These two organizations represent nearly 50% of the operating budget, and I was directly involved with almost every aspect of the budget process.

The 2013 budget was a challenge for the Chicago Transit Authority, as it aimed to provide a balanced budget for the first time in recent history while signing a new labor agreement with the two largest transit unions. In January, we initiated a budget revision upon reaching a collectively bargained agreement, and the FY13 budget decreased by $4.072 million. On the morning the budget revision was due, a draft snapshot of the revision painted a far different picture. Having implemented the policy decisions, amended Labor was projected at $1,000,519,142. (Appendix A) This gap was closed by making a significant decision in regards to how

labor is budgeted. This decision is the primary cause to why were struggling to close our current projected deficit. I was not aware of this labor decision until months after the budget was approved by both boards.

ORGANIZATION 9000Non-Departmental-General

The single most important disclosure I wish to make to you today is the existence of Organization 9000, Non-Departmental-General. This organization contains $56,424,660 in labor credits that reduce the Authoritys 2013 Budget. (Appendix B) Cumulatively, the departmental labor budget was understated to the RTA by over $55 million. This was done, allegedly, based on the inability to close the budget gap. I became aware of this inconsistency approximately four months ago while conducting a monthly variance reconciliation.

-5.3%

5.2%

-9.4% -1.1% -12.7%1.5%

-5.6% -3.6%

0.1%

(11,000,000)

(9,000,000)

(7,000,000)

(5,000,000)

(3,000,000)

(1,000,000)

1,000,000

3,000,000

Reforecast vs Budget

($32.1m)

Operating Expenses

Original

Budget

2013

Amended

Budget

2013 Change

Labor $ $ 918,875 $ 939,679 $ 20,804

Material 57,279 57,279 -

Fuel 65,342 65,342 -

Power 23,175 23,175 -

Provisions for Injuries and Damages 11,792 11,792 -

Purchase of Security Services 38,734 23,246 (15,488)

Other Expenses 242,884 233,496 (9,388)

Total Operating Expenses $ $ 1,358,081 $ 1,354,009 $ (4,072)

System Generated Revenue

Fare and Passes $ $ 611,281 $ 607,209 $ (4,072)

Reduced Fare Subsidy 28,322 28,322 -

Advertising, Charter& Concessions 27,851 27,851 -

Investment Income 629 629 -

Statutory Required Contributions 5,000 5,000 -

Other Revenue 31,954 31,954 -

Total System Generated Revenue $ $ 705,037 $ 700,965 $ (4,072)

President's 2013 Proposed Operating Budget - REVISED

(in thousands)

CHICAGO TRANSIT AUTHORITY FY13 BUDGET & REFORECAST

Page 2

Historically, the 9000 organization was used to book top level labor credits and account for vacancy salvage. This practice in and of itself is not improper, however of the $56 million in the labor account, $15+ million is labor credits and $41 million is a very liberal salvage assumption. (Note: At the Authority, salvage is defined by the value of time a budgeted vacancy is projected to be vacant. If a $100,000 position is projected to take three months to fill, 25% of the salary is booked in Org 9000 as salvage) In 2013, there were 347 budgeted vacancies. The $41 million in Org 9000 represents a salvage assumption of over 100%. This means that Org 9000 suggested all 347 vacancies budgeted in 2013 would not be filled the entire year. Why werent the vacancies simply eliminated to provide transparency? I allege that the adjustment to Org 9000 was made to provide an illusion the budget deficit was closed, rather than provide a true expectation of salvage, and the negligence and technical inability of the senior management allowed it to happen.

The implication of these decisions have severely limited the Authoritys ability to combat the financial crisis we are now in. It means a traditional method of eliminating labor expenses through vacancy reduction is not possible. These potential savings were effectively realized the first day of FY13.

REVENUE

The analysis and assumptions involving the FY13 revenue/ridership, or lack thereof , is astonishing. The projections made in the FY13 budget call to question the technical ability of the people responsible for making them. The lack of diligence throughout the process is now being realized, as Fares and Passes are currently projecting a $32,136,240 unfavorable variance. The analysis involving demand elasticity, given the increase in pass prices, was outsourced to a third party and not validated by Budget. Additionally, upon learning of the significant unfavorable variance, the reforecast was assigned to a new Director of Budget and Capital that has been with the Authority for less than a month. I feel this was done because the current administration, namely the Vice President of Budget and Capital Finance, does not possess the technical ability to conduct the analysis himself. While the analysts on the Budget team are very strong and certainly posses the ability to conduct the analysis, they have not been properly utilized. It does not take a complex price elasticity of demand analysis to show that the revenue and ridership assumptions are inconsistent and simply a hopeful guess to meet a required mark. I highly recommend the RTA investigate these assumptions and independently conduct their own analysis.

EXPENSES

The Operating Expense variance represents the most optimistic component of the 2013 budget. The unfavorable projection of -$18,454,733 is -1.36% to budget, and includes a one time $4.3 million expense for 2012 retroactive rate increases booked in FY13, $4.5 million in maintenance capital dollars that were not received, and $2.1 million in Dan Ryan Reconstruction expenses for supervision that cannot be capitalized.

Additionally, the Authority is projecting $16,330,232 in additional 2013 expenses, not included in the reforecast projection, and has identified $12,944,786 in expense reductions/cost avoidance opportunities. I strongly advise the RTA conduct their own due diligence into both of these figures. Figures supplied by the analysts are being misrepresented by the Vice President to the CFO out of fear of supplying unfavorable figures or his inability to understand the material. Specifically, I was the first to identify the Organization 9000 inconsistencies, and after educating Tom McKone on two separate occasions, he still represented cost savings through vacancy reduction. His inability to comprehend complex financial analysis has led to incorrect advice on many occasions and is degrading the quality of work coming from the subject matter experts. While having a casual discussion with Chief of Staff, Doug Kucia regarding the challenges of our YTD variances, Mr. Kucia advised me, We knew Tom was not strong in budget knowledge when we hired him, but we hoped he would learn.

CHICAGO TRANSIT AUTHORITY FY13 BUDGET & REFORECAST

Page 3

FIDIUCARY RESPONSIBILITY

The implications of these events have serious ramifications for the Chicago Transit Authority, the Regional Transportation Authority, and the public. First and foremost, I wish to express that I understand the dynamic nature of transit operations. Budgets and forecasts are built given the best information currently available. The reason I have reached out to the RTA is that I feel there is still time to fix this problem in 2013. Ron DeNard and Tom McKone have been working on a budget reforecast since May, and they have not made an appropriate level of progress. It is my opinion that Tom McKone does not possess the technical financial expertise to properly supervise or delegate responsibility, and Ron DeNard is too new (April 2013) to fully understand the process. It is my recommendation that the RTAs expertise is needed to oversee the process.

COST IMPLICATIONS

As we all know, at year end the Authoritys budget is mandated to balance. I feel this disincentivizes senior finance management from making the difficult decisions. The fact that the CTA has consistently transferred capital funds to balance the budget provides a safety net that traditional organizations do not have. By knowing a capital transfer is an option of last resort, Ron DeNard and Tom McKone are not properly incentivized to conduct the appropriate level of due diligence.

I allege that current reforecast projections are favorably overstated and not implementable. They have been developed with very little departmental input and still leave the Authority with a $10,362,450 deficit. Last Resort options include capital transfers, service reductions, and even mandating no more overtime. During this same time period, Tom McKone has approved over 22 positions, in excess of budget, to be added to the Authoritys headcount. Managers have been made directors, there have been rate increases not budgeted for, and yet the plan to pay for these increases is to simply stop authorizing emergency overtime and reduce service.

If these underdeveloped options are implemented and made policy, the Authority will unquestionably end FY13 with a deficit that will require a capital transfer, additional RTA subsidies, or alternative methods of capital raising. The cost of these options will significantly impact the public. What infrastructure projects will be put on hold due to the millions we must transfer to balance the budget? Will the safety of the system be at risk? How much will it cost to bond or borrow $50 million if we cannot balance the budget?

I implore the Regional Transportation Authority to open an investigation into this matter. I feel without your involvement, these assumptions will provide a false sense of security and as a result the CTA will face a significant year end deficit to be paid for by the Authorities and the public.

ABOUT ME

In regards to my qualifications to make these determinations, I have been employed at the Chicago Transit Authority for 18 months. I received a Bachelors Degree in Economics from the University of California in 2003. I earned a Master of Business Administration in Finance from Loyola University, Chicago and also hold a Master of Finance in Risk Management. My entire professional career has involved performance and financial analytics, financial statement analysis, predictive forecasting, cash flow analysis, and financial modeling. While I am concerned with the consequences at the Authority for bringing this to your attention, I am willing to work with the RTA in efforts to resolve this matter. Please feel free to contact me when you feel it is appropriate. My Authority email address is cloop@transitchicago.com and I can be reached at (312) 681-4528.

CHICAGO TRANSIT AUTHORITY FY13 BUDGET & REFORECAST

Page 4

APPENDIX A

CHICAGO TRANSIT AUTHORITY FY13 BUDGET & REFORECAST

Page 5

APPENDIX B

EXHIBIT B

EXHIBIT B

EXHIBIT B

August 8th, 2013

Doug Kucia Chief of Staff Chicago Transit Authority 567 W Lake Street Chicago Il, 60661

Dear Mr. Kucia:

I wish to bring to your attention, and serve official notice, that there have been actions taken against me that I feel are in violation of RTA policy pertaining to Whistleblower Protection, and possibly Illinois Statute 140 ILCS 174.

On July 29th, 2013 I submitted a memorandum to the Regional Transportation Authority, in accordance with their Statement of Whistleblower Protection and 140 ILCS 174. I alleged gross negligence within the Chicago Transit Authority Finance department, leading to a projected -$52.1 million year end unfavorable budget variance. On Tuesday, July 30th 2013 I forwarded a copy of the report to Andrell Holloway, Chief Internal Auditor, and requested confidentiality pursuant to 140 ILCS 174. Approximately fifteen minutes later I received a phone call from Ronald DeNard, Chief Financial Officer, who stated he felt I was disingenuous for reporting my concerns to the RTA, at which time I informed him I did not feel comfortable continuing the conversation.

My intent of this correspondence is to discuss the actions which occurred after the event on Tuesday took place, as I am confident the investigation into the allegations in my submission will be fully resolved. On Thursday, August 1st, 2013 at approximately 2:30pm, my access to every shared drive and financial system was removed. Not only did I lose access to financial systems that were to remain intact in efforts to assist the budget department during the budget process, my transit operations access was removed, as well as my Oracle access to systems such as employee self-service.

I feel that my submission to the RTA was a contributing factor in the retaliatory action taken against me on Thursday, August 1st, and I am writing to officially request full reinstatement of my duties and responsibilities. I feel it is in the best interest of the Authority to consider education of the Regional Transportation Authoritys Whistleblower Protection Policy in effort to prevent this from happening again. For your convenience, I have attached a copy of the policy, as well as a copy of 140 ILCS 174.

Thank you very much for your prompt attention in this matter.

Sincerely,

Casey Loop

740 ILCS 174/1, et seq.

ILLINOIS WHISTLEBLOWER ACT

West's Smith-Hurd Illinois Compiled Statutes Annotated

Chapter 740. Civil Liabili)es

Act 174. Whistleblower Act

$174/1. Short )tle

1. Short )tle. This Act may be cited as the Whistleblower Act.

$174/5. Deni)ons

5. Deni)ons. As used in this Act:

"Employer" means: an individual, sole proprietorship, partnership, rm, corpora)on, associa)on,

and any other en)ty that has one or more employees in this State, except that "employer" does not

include any governmental en)ty.

"Employee" means any individual who is employed on a full-)me, part-)me, or contractual basis

by an employer.

$174/10. Certain policies prohibited

10. Certain policies prohibited. An employer may not make, adopt, or enforce any rule,

regula)on, or policy preven)ng an employee from disclosing informa)on to a government or law

enforcement agency if the employee has reasonable cause to believe that the informa)on discloses

a viola)on of a State or federal law, rule, or regula)on.

$174/15. Retalia)on for certain disclosures prohibited

15. Retalia)on for certain disclosures prohibited. An employer may not retaliate against an

employee for disclosing informa)on to a government or law enforcement agency, where the

employee has reasonable cause to believe that the informa)on discloses a viola)on of a State or

federal law, rule, or regula)on.2

$174/25. Civil penalty

25. Civil penalty. Viola)on of this Act is a Class A misdemeanor.

$174/30. Damages

30. Damages. If an employer takes any ac)on against an employee in viola)on of Sec)on 15 or

20, the employee may bring a civil ac)on against the employer for all relief necessary to make the

employee whole, including but not limited to the following, as appropriate:

(1) reinstatement with the same seniority status that the employee would have had, but for the

viola)on;

(2) back pay, with interest; and

(3) compensa)on for any damages sustained as a result of the viola)on, including li)ga)on costs,

expert witness fees, and reasonable a>orney's fees.

174/35. Excep)on

35. Excep)on. This Act does not apply to disclosures that would cons)tute a viola)on of the

a>orney-client privilege.