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STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
____________________________________________________________________________________
MOTION TO GRANT LEAVE TO SUE THE RESPONDENT COMMONWEALTH
EDITION IN CIRCUIT COURT WITHOUT PREJUDICE TO PROCEED WITH THE
LAW SUIT IRRESPECTIVE OF COMMISSION PROCEEDINGS
1. On November 5, 2019 the Commission denied the Motion to Disqualify Rebecca Graham
and Graham & Graham .
2. No order as to Reply filed by the Petitioner /Complainant , Exhibit A, to response by
Rebecca Graham for motion to disqualify or as to the Motion to Vacate the denial.
3. The reason the Commission stated in November 5, 2019 order to deny the motion to
disqualify is that the Graham & Graham and Rebeca Graham have been appearing for
ComEd for many years before the commission as to which Complainant/Petitioner argued in
his Motion to vacate. Exhibit B
4. On November 6, 2019 hearing ,the Commission tacitly denied the motion to vacate the order
denying the disqualification by suggesting that petitioner can appeal through the
commission.
5. Additionally, in spite of NO objection by the defendant ComEd as they did not comply with
the Commission order to respond by October 24, 2019 as to Petitioner’s motion to take video
depositions, the commission did not rule granting the Discovery motion on November 6
hearing. Exhibit C
2
6. Petitioner wish to proceed with suing ComEd, and others as shown in the cover page of the
law suit, Exhibit D , in Circuit court .
7. As a matter of right Petitioner can immediately proceed with expedited depositions of
defendants soon after the summons served as a matter of right and no need to haggle with the
commission to seek leave.
Wherefore , Petitioner seeks this Commission to grant leave to sue ComEd in Circuit court of
Petitioner’s choice.
November 27, 2019 By: /s/ Roger Shekar `
Petitioner
Notice and Certificate of Service
On November 27, 2019, Petitioner certifies that he served the copies of this filing electronically
to respondent’s E mail address on file.
/s/ Roger Shekar
Exhibit A
1
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
____________________________________________________________________________________
MOTION TO VACATE THE ORDER OF NOVEMBER 5, 2019 DENYING THE MOTION
TO DISQUALIFY REBECCA GRAHAM AND GRAHAM & GRAHAM
alternatively ,
TO GARNT LEAVE INSTANTER TO FILE AN IMMEDIATE INTERLOCUTORY
APPEAL WITH THE FIRST DISTRICT APPELLATE COURT
1. On November 5, 2019 the Commission denied the Motion to Disqualify Rebecca Graham
and Graham & Graham .
2. The order has no mention as to Reply filed by the Petitioner /Complainant , Exhibit A, to
response by Rebecca Graham for motion to disqualify .
3. The reason the Commission gave to deny the motion to disqualify is that the Graham &
Graham and Rebeca Graham have been appearing for ComEd for many years before the
commission.
4. However that reason is immaterial , moot , irrelevant in this Petitioner situation and the
motion to disqualify.
5. On the other hand, the reason by Commission to deny because that Graham & Graham ,
Peter Graham have been representing ComEd before this commission for years, that makes
it more compelling and all the more reason that that Graham & Graham must be
disqualified, as it proves that Peter Graham deliberately engaged in a dialogue with the
2
petitioner in spite of conflict with ComEd, when Petitioner called Peter Graham to sue
ComEd for damages.
6. The deliberate dialogue in spite of conflict with ComEd proves that, the ulterior motive for
Peter Graham to continue the dialogue instead of aborting immediately the mention of
ComEd as TO conflict of interest , is to prepare in advance for any defense for his client
ComEd, and to know in advance what evidence Petitioner/Plaintiff will present in the event
of ComEd being sued by the Petitioner(Plaintiff) and to further solicit ComEd for the
business of retaining them in the main law suit.
7. This is further evident why in this particular complaint , only Rebecca Graham filed the
appearance, whereas the Commission order says both Peter and Rebecca Graham appeared
for ComEd before the commission in the past “many years” .
Wherefore , Petitioner seeks this Commission to vacate the order denying the Motion to
disqualify Rebecca graham, Peter Graham and Graham & Graham grant him the original motion
to disqualify ;
alternatively ,
to grant leave instanter to file an appeal with the First District Appellate court.
Respectfully submitted,
November 5, 2019 By: /s/ Roger Shekar `
Petitioner
Notice and Certificate of Service
On November 5, 2019, Petitioner certifies that he served the copies of this filing electronically
to respondent’s E mail address on file.
/s/ Roger Shekar
1
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
__________________________________________________________________________________
REPLY TO RESPONSE TO DISQAUALIFY GRAHAM AND GRAHAM, REBECCA
GRAHAM, PETER GRAHAM INSTANTER FROM REPRESENTING COMMON
WEALTH EDISON
AND
MOTION TO BAR ANY RESPONSE BY REBECCA GRAHAM PENDING RULING
ON MOTION TO DISQUALIFY AND TO DISALLAOW ANY EXPARTE RESPONSE
ON THE COMPLAINT
The response by Rebecca Graham of Graham & Graham should be disallowed,
stricken and Petitioner motion to Disqualify Graham & Graham and Rebecca Graham must
be granted for the following reasons :
1. First, in an effort to pre-empt the Petitioner from having adequate time , the cunning ,
evil and scorpion lawyer Rebecca Graham mailed the response , when Petitioner had
filed papers with the Clerk of the Commission that he has rescinded his prior revocation
of e-Notices and had consented for notices electronically. See Exhibit A.
2. As additional cunning tactic, the scorpion lawyer delayed the mailing of her response till
Columbus day holiday . Petitioner received the response one day before the due date of
reply on October 18, 2019 and thus evaporated and pre-empted six says in mail , in an
effort to thwart any reply.
2
3. The desperate response by Rebecca Graham to keep a public monies funded multi-
billion dollar white collar criminal client ComEd is very amusing and laughable.
4. In essence the response is a trash by the scavenging Rebecca Graham who is willing to
lose her license /disbarred ( a complaint filed with ARDC) in exchange for a “windfall”
from her client and white Collar criminal ComEd.
5. Rebecca Graham in her response, let her imaginations and self-serving fantasies run
wild assuming there were lot of E mails, Voicemail, et., piled up somewhere as to
conversation petitioner had with Peter Graham as to suing ComEd.
6. Petitioner never stated in his motion to disqualify he had E mail exchanges or voicemail
exchanges with Peter Graham . The response should be directed at what Petitioner filed.
7. On hearing of September 18, 2019 , Petitioner stated he had detailed phone conversation
with Peter Graham a to suing ComEd for property damages; to represent in ICC
Commission hearings .
8. After hearing the case in full details ,Peter wanted a heavy retainer and stated he does not
take contingency cases.
9. Petitioner warned Peter Graham that (though Petitioner would not be hiring him in any
other terms other than contingency fee basis) , all information shared with him was still/is
still “attorney client privileged information” and must be treated so and confidential .
10. After that conversation, they coward scavenger Peter Graham camouflaging behind his
wife? Rebecca Graham and using her “mask” had evidently contacted and solicited
ComEd “begging” for the case.
11. This is further evident that the veiled appearance by Peter Graham through Rebecca
Graham specifically excluded his name.
3
12. It is amusing and laughable that this ignorant imbecile and manipulative crook named
Rebecca Graham trying to defraud the Commission with her pitch that not all the
attorneys need to be named in an appearance. Whereas , this two man show could have
easily added Peter Graham, and is not some 1000 attorneys law firm.
13. The reason being is a “tactic” to hide the fact that Petitioner contacted Peter, and with a
failed attempt to “fool” the Petitioner as if Peter Graham name appeared it would be
come very conspicuous and hence tried to hide his name.
14. The two man show otherwise would not have been known to ComEd . Neither Rebecca
Graham cited any prior cases before Commission or elsewhere that Graham & Graham
represented ComEd ; even if such representation exist, Peter Graham never informed
petitioner that he could not talk any farther any discussions as to suing ComEd and could
have terminated the conversation simply stating he had a conflict of interest, the
moment ComEd name mentioned. Instead he asked for all the details of damages,
complete narrative of the happenings leading to damages.
15. Petitioner further brings to this Commission attention that the respondent ComEd is in
default and have not filed the response to the complaint or served the Petitioner.
16. As of October 21, 2019 , petitioner has not been noticed /served of any response .
17. Petitioner further asks the Commission that until the pending motion to disqualify
Graham & Graham and Rebecca Graham is ruled by the Commission , Rebecca Graham
and Peter Graham , Graham & Graham must be barred from participating, filing any
response to the Complaint . If any response filed exparte , must be stricken besides late.
18. Respondent has another attorney Michael Goldstein who had filed appearance. Any
response Goldstein could have filed timely, but he did not and respondent is in default for
4
not filed the response or if filed not served or noticed the Petitioner and hence must be
stricken as exparte if any response in fact filed.
19. The affidavit by Peter Graham must be stricken as it constitutes perjury and given no
consideration. Rebecca and Peter Graham knew that no one ever prosecuted and sent to
Prison for perjury in signing an affidavit under oath; the affidavit means nothing other
than a motherlode of lies.
Wherefore, Rebecca Graham, Graham & Graham must be disqualified instanter from
representing ComEd. Petitioner further seeks any exparte response to complaint if exist be
stricken with prejudice for attempted multiple fraud on Commission by Rebecca Graham.
Respectfully submitted,
October 19, 2019 By: /s/ Roger Shekar `
VERIFICATION BY CERITIFICATION AND AFFIDAVIT
Under penalties as provided by law pursuant to 735 ILCS 5/109-1 I certify that the
statements set forth herein in this Reply are true and correct
October 19, 2019 By: /s/Roger Shekar
5
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
__________________________________________________________________________________
NOTICE OF FILING
To: Rebecca Graham, 20 North Clark Street, Chicago, Il 60602
Veronica Gomez , Corporate Counsel for ComEd [email protected];
Mark Goldstein, 300 Anthony Ave; apartment no: 313 , Mundelein , Il 60060
Effective immediately , Petitioner rescinds his previously noticed revocation of E-mail
notices and Petitioner consents Electronic Notices of filings and other reacted
communications in this case.
September 29,2019 By: /s/ Roger Shekar
Petitioner
Courtesy copies sent to:
Mr. Dolan, Administrative Law Judge , Illinois Commerce Commission
Carrie Zalewski Chairperson, Illinois Commerce Commission, Via E mail
EXHIBIT A
6
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
__________________________________________________________________________________
NOTICE OF FILING
To: Rebecca Graham, 20 North Clark Street, Chicago, Il 60602
Veronica Gomez , Corporate Counsel for ComEd [email protected];
Mark Goldstein, 300 Anthony Ave; apartment no: 313 , Mundelein , Il 60060
Take notice that on October 19, 2019 ,I filed with the Clerk of the Illinois Commerce
Commission, , Petitioner’s Reply to Response for the Motion to Disqualify Rebecca Graham,
Peter Graham and Graham & Graham from appearing for representing ComEd, copies of
which are attached and served upon you.
October 19,2019 By: /s/ Roger Shekar
Petitioner
Courtesy copies sent to:
Mr. Dolan, Administrative Law Judge , Illinois Commerce Commission
Carrie Zalewski Chairperson, Illinois Commerce Commission, Via E mail
Exhibit B
1
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
__________________________________________________________________________________
REPLY TO RESPONSE TO DISQAUALIFY GRAHAM AND GRAHAM, REBECCA
GRAHAM, PETER GRAHAM INSTANTER FROM REPRESENTING COMMON
WEALTH EDISON
AND
MOTION TO BAR ANY RESPONSE BY REBECCA GRAHAM PENDING RULING
ON MOTION TO DISQUALIFY AND TO DISALLAOW ANY EXPARTE RESPONSE
ON THE COMPLAINT
The response by Rebecca Graham of Graham & Graham should be disallowed,
stricken and Petitioner motion to Disqualify Graham & Graham and Rebecca Graham must
be granted for the following reasons :
1. First, in an effort to pre-empt the Petitioner from having adequate time , the cunning ,
evil and scorpion lawyer Rebecca Graham mailed the response , when Petitioner had
filed papers with the Clerk of the Commission that he has rescinded his prior revocation
of e-Notices and had consented for notices electronically. See Exhibit A.
2. As additional cunning tactic, the scorpion lawyer delayed the mailing of her response till
Columbus day holiday . Petitioner received the response one day before the due date of
reply on October 18, 2019 and thus evaporated and pre-empted six says in mail , in an
effort to thwart any reply.
2
3. The desperate response by Rebecca Graham to keep a public monies funded multi-
billion dollar white collar criminal client ComEd is very amusing and laughable.
4. In essence the response is a trash by the scavenging Rebecca Graham who is willing to
lose her license /disbarred ( a complaint filed with ARDC) in exchange for a “windfall”
from her client and white Collar criminal ComEd.
5. Rebecca Graham in her response, let her imaginations and self-serving fantasies run
wild assuming there were lot of E mails, Voicemail, et., piled up somewhere as to
conversation petitioner had with Peter Graham as to suing ComEd.
6. Petitioner never stated in his motion to disqualify he had E mail exchanges or voicemail
exchanges with Peter Graham . The response should be directed at what Petitioner filed.
7. On hearing of September 18, 2019 , Petitioner stated he had detailed phone conversation
with Peter Graham a to suing ComEd for property damages; to represent in ICC
Commission hearings .
8. After hearing the case in full details ,Peter wanted a heavy retainer and stated he does not
take contingency cases.
9. Petitioner warned Peter Graham that (though Petitioner would not be hiring him in any
other terms other than contingency fee basis) , all information shared with him was still/is
still “attorney client privileged information” and must be treated so and confidential .
10. After that conversation, they coward scavenger Peter Graham camouflaging behind his
wife? Rebecca Graham and using her “mask” had evidently contacted and solicited
ComEd “begging” for the case.
11. This is further evident that the veiled appearance by Peter Graham through Rebecca
Graham specifically excluded his name.
3
12. It is amusing and laughable that this ignorant imbecile and manipulative crook named
Rebecca Graham trying to defraud the Commission with her pitch that not all the
attorneys need to be named in an appearance. Whereas , this two man show could have
easily added Peter Graham, and is not some 1000 attorneys law firm.
13. The reason being is a “tactic” to hide the fact that Petitioner contacted Peter, and with a
failed attempt to “fool” the Petitioner as if Peter Graham name appeared it would be
come very conspicuous and hence tried to hide his name.
14. The two man show otherwise would not have been known to ComEd . Neither Rebecca
Graham cited any prior cases before Commission or elsewhere that Graham & Graham
represented ComEd ; even if such representation exist, Peter Graham never informed
petitioner that he could not talk any farther any discussions as to suing ComEd and could
have terminated the conversation simply stating he had a conflict of interest, the
moment ComEd name mentioned. Instead he asked for all the details of damages,
complete narrative of the happenings leading to damages.
15. Petitioner further brings to this Commission attention that the respondent ComEd is in
default and have not filed the response to the complaint or served the Petitioner.
16. As of October 21, 2019 , petitioner has not been noticed /served of any response .
17. Petitioner further asks the Commission that until the pending motion to disqualify
Graham & Graham and Rebecca Graham is ruled by the Commission , Rebecca Graham
and Peter Graham , Graham & Graham must be barred from participating, filing any
response to the Complaint . If any response filed exparte , must be stricken besides late.
18. Respondent has another attorney Michael Goldstein who had filed appearance. Any
response Goldstein could have filed timely, but he did not and respondent is in default for
4
not filed the response or if filed not served or noticed the Petitioner and hence must be
stricken as exparte if any response in fact filed.
19. The affidavit by Peter Graham must be stricken as it constitutes perjury and given no
consideration. Rebecca and Peter Graham knew that no one ever prosecuted and sent to
Prison for perjury in signing an affidavit under oath; the affidavit means nothing other
than a motherlode of lies.
Wherefore, Rebecca Graham, Graham & Graham must be disqualified instanter from
representing ComEd. Petitioner further seeks any exparte response to complaint if exist be
stricken with prejudice for attempted multiple fraud on Commission by Rebecca Graham.
Respectfully submitted,
October 19, 2019 By: /s/ Roger Shekar `
VERIFICATION BY CERITIFICATION AND AFFIDAVIT
Under penalties as provided by law pursuant to 735 ILCS 5/109-1 I certify that the
statements set forth herein in this Reply are true and correct
October 19, 2019 By: /s/Roger Shekar
5
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
__________________________________________________________________________________
NOTICE OF FILING
To: Rebecca Graham, 20 North Clark Street, Chicago, Il 60602
Veronica Gomez , Corporate Counsel for ComEd [email protected];
Mark Goldstein, 300 Anthony Ave; apartment no: 313 , Mundelein , Il 60060
Effective immediately , Petitioner rescinds his previously noticed revocation of E-mail
notices and Petitioner consents Electronic Notices of filings and other reacted
communications in this case.
September 29,2019 By: /s/ Roger Shekar
Petitioner
Courtesy copies sent to:
Mr. Dolan, Administrative Law Judge , Illinois Commerce Commission
Carrie Zalewski Chairperson, Illinois Commerce Commission, Via E mail
EXHIBIT A
6
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
__________________________________________________________________________________
NOTICE OF FILING
To: Rebecca Graham, 20 North Clark Street, Chicago, Il 60602
Veronica Gomez , Corporate Counsel for ComEd [email protected];
Mark Goldstein, 300 Anthony Ave; apartment no: 313 , Mundelein , Il 60060
Take notice that on October 19, 2019 ,I filed with the Clerk of the Illinois Commerce
Commission, , Petitioner’s Reply to Response for the Motion to Disqualify Rebecca Graham,
Peter Graham and Graham & Graham from appearing for representing ComEd, copies of
which are attached and served upon you.
October 19,2019 By: /s/ Roger Shekar
Petitioner
Courtesy copies sent to:
Mr. Dolan, Administrative Law Judge , Illinois Commerce Commission
Carrie Zalewski Chairperson, Illinois Commerce Commission, Via E mail
Exhibit C
1
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
____________________________________________________________________________________
MOTION TO GRANT LEAVE FOR EXPEDITIOUS DISCOVERY DEPOSITION
PETITIONER REQUESTS RULING BY MAIL
1. On September 18 , 2019 status hearing, Judge Dolan indicated that parties could engage in
discoveries .
2. However, the respondent ComEd interjected and stated that want to wait till they file response.
3. Petitioner is the master of the case, nothing stops Petitioner to engage in discovery ,including
depositions.
4. The Commission indicated ICC requires a Motion to Grant leave to take depositions filed
before the Administrative Judge.
5. Accordingly, Petitioner moves this Commission to grant him leave take “Video depositions”
under oath of the following individuals at ComEd and ComEd Contractors:
ComEd: Joseph Dominguez, Christopher Crane, Bradley Perkins, Anne Pramaggiore.
ComEd Contractors Intren/USIC: Kirk Doty, Matthew Turk, Lance Rosenmayer, Loretta
Rosenmayer, Kelly Tomblin, Richard Ryman, William Nightingale, Dan Bednarski, Shane
Doyle , Rob Tullman
ComEd Contractor Monterrey security: Juan Gaytan, Michael Boyle, Steven Gaytan, Daniel
Ramos , Vivian Ogo, Lindsay Saklak and John Doe
2
6. The Video Depositions will take place at Zurich Tower Corporate Conference Room in
Schaumburg , on or before October 16, 2019 starting at 8 A.M and going into 17th.
7. The depositions of deponents will be taken by the Petitioner and an attorney of Petitioner
who will be engaged for this limited purpose with a court reporter present.
Wherefore , Petitioner requests this Commission to grant him this motion and allow him to take
discovery depositions.
Respectfully submitted,
October 11, 2019 By: /s/ Roger Shekar `
Petitioner
3
STATE OF ILLINOIS
ILLINOIS COMMERCE COMMISSION
Roger Shekar , )
Petitioner, )
v. )
) 19-0863
Common Wealth Edison, )
)
Respondent. )
__________________________________________________________________________________
NOTICE OF MOTION
To: Veronica Gomez , Corporate Counsel for ComEd [email protected];
Mark Goldstein, 300 Anthony Ave; apartment no: 313 , Mundelein , Il 60060
Third Party Respondents Intren, USIC, Monterrey Security
Take notice that on October 11 , 2019, I have filed with the Clerk of the Illinois Commerce
commission the attached Motion to Grant Leave to Take Video Depositions .
By: /s/ Roger Shekar
Petitioner
Courtesy copies sent to: Mr. Dolan, Administrative Law Judge , Illinois Commerce Commission
Carrie Zelweski, Chairperson, Illinois Commerce Commission
Exhibit D
IN THE TWENTY SECOND JUDCIAL CIRCUIT COUNTY
McHENRY COUNTY , ILLINOIS
1 of 32
_____________________________________________________________________________________
Roger Shekar , ) 2019-L-0XXXX Plaintiff , )
) INTENTIONAL TORT, DEFAMATION
) PROPERTY DAMAGES ) DAMAGES CLAIMED:
Joseph Dominguez, Christopher Crane, ) TWETY MILLION DOLLARS
Bradley Perkins, Rob Tullman , )
Anne Pramaggiore,Kirk Doty, ) PUNTIVE DAMAGES Matthew Turk, ) 100 MILLION DOLLARS
Juan Gaytan, Shane Doyle, )
Lance Rosenmayer, Loretta Rosenmayer, ) Kelly Tomblin,Richard Ryman , )
William Nightingale, Dan Bednarski, ) TWELVE PERSON JURY DEMAND
Monterrey Security Consultants Inc; ) John Does 1 to 11 of ComEd & Intren, )
John Doe 12 of Monterrey, )
Common Wealth Edison Company , )
Exelon Corporation, ) USIC LLC, )
Intren Holdings, LLC, )
Defendants. ) ______________________________________________________________________________
COMPLAINT AT LAW
Plaintiff Roger Shekar, through his attorneys sue the defendants Dominguez, Crane, Perkins, Tullman ,
Pramaggiore , Doty, Turk, Gaytan, Doyle, ,Tomblin, Ryman, Nightingale, Bednarski ,Loretta and Lance
Rosenmayer, John Does 1-11 ; John Doe 12; Exelon Corporation, Common Wealth Edison company,
Monterrey Security Consultants Inc., USIC LLC, Intern Holdings ,LLC (hereinafter “defendants’) -suing
for compensatory damages on TWENTY SIX counts- for Defamation, Pursuant to 720 ILCS 5/32–13 ;
740 ILCS 145 ; Property Damages; Intentional Tort acts ; Vandalism; Trespassing; Violation of 220
ILCS 5/8-505.1(a)(1) (West 2010), Section 8-505.1(a)(2) [requiring ComEd direct notice of no less than
21 days before any alleged repair work] ; and specifies the accompanying information that must be
provided to customers and property owners pursuant to 220 ILCS 5/8-505.1(a)(2) (West 2010); violation
of section 8-505.1 of the Public Utilities Act ,(Damages to vegetation, lawn et- Sheffler v.
Commonwealth Edison Co., 2011 IL 110166, Ill.Sup.Ct.) ; violation of Easement ; Devaluation of the
property as proximate cause and the damages; unauthorized removal of vegetation ; punitive damages.
