• LLC Managers and Members No Longer Immune from Liability under Illinois Law

  • Beware of Collecting Fingerprints

  • The Appurtenant Easement-A Valuable Property Right
LLC Managers and Members
No Longer Immune from Liability under Illinois Law
By Christine R. Walsh and Thomas P. Yardley
312.456.0287/Christine R. Walsh
312.456.0184/Thomas P. Yardley
Members and managers of limited liability companies can no longer hide behind what was previously a cloak of immunity under of section 10-10 of the Illinois Limited Liability Company Act. On August 23, 2019, the Illinois legislature approved an amendment to section 10-10 of the Illinois Limited Liability Company Act (805 ILCS 180/10-10), which specifically overrules the cases of Dass v. Yale, 2013 IL App. (1st) 122520 and Carollo v. Irwin, 2011 IL App. (1st) 102765.  
Beware of Collecting
By Caroline S. Smith
Telephone: 312.456.0380
What are biometrics and why should you be wary of collecting biometric information? Biometrics technology collects information that can identify a person based on certain characteristics, such as fingerprints, voice identification, and facial recognition. As biometrics are becoming easier to collect and utilize, they are becoming more commonplace in our everyday activities, such as being able to open your phone with your fingerprint. 
The Appurtenant Easement-
A Valuable Property Right
By Donna M. Shaw
Telephone: 312.456.0377
Does your business or residential property share a common driveway or parking area with the property next door? Do you use the adjoining property for access to your property? Does your property connect to a stormwater drainage system located on the adjoining property? If the answer is yes to any of these questions, then your property may be benefited by an appurtenant easement.
Andrès J. Gallegos
 Telephone: 312.456.0381 | Email:

Andrès J. Gallegos participated as a panel speaker presenting on the topic of " Accessible Healthcare for Persons with Disabilities" to medical students and residents at the University of Illinois Chicago Medical Colloquium and Shirley Ryan AbilityLab in Chicago.

In addition, Mr. Gallegos presented the workshop " Acting B-A-D: A Patient Advocacy Strategy" at the NCIL Ignite Conference held in Washington, DC.
R. Kymn Harp
 Telephone: 312.456.0378 | Email: 

R. Kymn Harp participated as a moderator for the IICLE® 2019 Trends Conference: What’s New in Illinois Commercial Real Estate Practice? held in Chicago. Mr. Harp also conducted a presentation on "Property Due Diligence for Commercial Real Estate-The Four Areas of Concern, Section 1031 Tax Deferred Exchanges, and Qualified Opportunity Zone Investment – What Every Real Estate Lawyer Should Know."
David P. Resnick
  Telephone: 312.456.0376 | Email:

David P. Resnick will lead a roundtable entitled “Challenges with Retail Leasing and Hotels" at the ICSC U.S. Shopping Center Law Conference scheduled for October 23-25 in San Diego. 
L. Steven Platt,
Thomas P. Yardley
and Parker E. Lawton

L.Steven Platt: Telephone: 312.456.0285

Thomas P. Yardley: Telephone: 312.456.0184

Parker E. Lawton: Telephone: 312.456.0283

On September 12, 2019, RSP client Christopher Glass and Aluminum was awarded judgment in the amount of $1,598,439.00 against Tishman Construction Corporation of Illinois by Judge Diane Shelley in Cook County Circuit Court in a dispute involving the construction of Vantage Oak Park, a twenty-one story mixed use building in Oak Park Illinois. Christopher Glass was hired by Tishman to install the exterior glass on the shell of the building. The judge also denied Tishman’s counter-claim against Christopher Glass in the amount of $16,200,000.00. Tishman had alleged that because Christopher was a “critical path” contractor, it delayed construction of the project causing it $16 million in subsequent construction delays and damages to complete the project. Instead, the Court found in favor of Christopher Glass on the counterclaim and ruled that the window system Tishman designated did not allow Christopher Glass to meet the specifications set forth in the construction contract. Christopher Glass was represented by RSP attorneys L. Steven Platt, Thomas P. Yardley and Parker E. Lawton.
Robert J. Trizna
August 29, 1952-August 14, 2019
RSP is saddened by the passing of our partner, colleague and friend, Robert J. Trizna (“Bob”) on August 14. He was 66 years old. Bob was a tireless defender of people’s rights and a dedicated community servant. He was admired and respected by his fellow attorneys, clients, and opposing counsel. Tributes have called him a great orator and passionate lawyer as well as a compassionate and generous person to those less fortunate. He served as a mentor, a sounding board, and a guidepost for colleagues both within and without our Firm.
About Us
For more information, visit us online at .
180 North LaSalle Street, Suite 3300
Chicago, Illinois 60601
Telephone: 312.782.9000
Fax: 312.782.6690
2222 Chestnut Avenue, Suite 101
Glenview, Illinois 60026
Telephone: 847.729.7300
Fax: 847.729.7390
Publication of this legal newsletter by Robbins, Salomon & Patt, Ltd. is not intended as a solicitation of legal representation, but rather educational purposes only as well as to give you general information and a general understanding of the law. It is written entirely by members of the firm. We welcome any comments or questions about topics covered in this or any issue. This newsletter is not intended as a replacement for individual legal advice. The contents of this publication may be quoted or reproduced if credit is properly given to the source.