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: [email protected]
Christopher T. Smith, Esq.
Email: [email protected]
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 [email protected] 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 Liabilies
Act 174. Whistleblower Act
$174/1. Short tle
1. Short tle. This Act may be cited as the Whistleblower Act.
$174/5. Denions
5. Denions. As used in this Act:
"Employer" means: an individual, sole proprietorship, partnership, rm, corporaon, associaon,
and any other enty that has one or more employees in this State, except that "employer" does not
include any governmental enty.
"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,
regulaon, or policy prevenng an employee from disclosing informaon to a government or law
enforcement agency if the employee has reasonable cause to believe that the informaon discloses
a violaon of a State or federal law, rule, or regulaon.
$174/15. Retaliaon for certain disclosures prohibited
15. Retaliaon for certain disclosures prohibited. An employer may not retaliate against an
employee for disclosing informaon to a government or law enforcement agency, where the
employee has reasonable cause to believe that the informaon discloses a violaon of a State or
federal law, rule, or regulaon.2
$174/25. Civil penalty
25. Civil penalty. Violaon of this Act is a Class A misdemeanor.
$174/30. Damages
30. Damages. If an employer takes any acon against an employee in violaon of Secon 15 or
20, the employee may bring a civil acon 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
violaon;
(2) back pay, with interest; and
(3) compensaon for any damages sustained as a result of the violaon, including ligaon costs,
expert witness fees, and reasonable aorney's fees.
174/35. Excepon
35. Excepon. This Act does not apply to disclosures that would constute a violaon of the
aorney-client privilege.