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The Plaintiff claim that JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN: (I) Violated the The Racketeer Influenced and Corrupt Organizations (“RICO”) Act; and otherwise, (II) Violated their Fiduciary Duties towards the Plaintiffs

In stating their cause of action against JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN, Plaintiffs claim that although they advertise IPA as a management consulting firm devoted to providing the highest professional standard of business services to its clients, IPA is completely the opposite 

In essence, the Plaintiffs claim that IPA defrauded them at multiple instances and on multiple levels.  Plaintiffs claim that JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN scheme involves multiple phases, all intended to coerce and deceive the Plaintiffs’ and other clients into purchasing consulting services through the myriad and disparate network of companies JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN set up, own and control, to accomplish their scheme to defraud.

Plaintiffs allege that in the first phase of their Fraudulent Scheme, JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN use employees known as Business Coordinators, commonly known as telemarketers (hereinafter “BC’s”) to set appointments with the “decision makers” of potential clients throughout the U.S. and Canada (Plaintiffs call these potential clients “Marks”.  The purpose and intent of the appointment is to get another of their employees, an Outside Sales Representative, in the Mark’s door so he or she can sell the mark an IPA “Business Analysis” or “Survey”.  The BC’s are paid a commission of approximately $200.00 to $300.00 dollars for each appointment they set up which results in the sale of a Business Analysis.

Plaintiffs allege in the second phase of their Fraudulent Scheme, JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN use their Outside Sales Representatives (hereinafter “OSR’s”) to prospect for and meet with Marks throughout the U.S. and Canada, not to advise the Mark in any way, but for the sole purpose of selling said mark an IPA Business Analysis.  The OSR’s are also paid a commission for each Business Analysis they sell.  Plaintiffs allege that the OSR’s commission includes: (a) up to 100% of the Business Analysis fee; and, (b) a “Go-Ahead Bonus” equal to a percentage of the money received by IPA pursuant to any Consulting Agreement sold to the Mark by the third part of the scheme, the Business Analyst. 

Plaintiffs allege in the third phase of their Fraudulent Scheme, JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN use their Business Analysts (hereinafter “BA’s”), under the guise of the Business Analysis, to deceive the Mark into purchase one of their various and myriad consulting contracts.  Although the Mark believes it is paying IPA for an objective 250 point business analysis of their company, what the BA is actually doing is selling the Mark one or more consulting contracts.  Plaintiffs allege that the Business Analysis could never be objective because the BA does not get paid for performing the Business Analysis; it is simply a ruse to get access to the Marks financial or other confidential data in order to sell the Mark a Consulting Agreement or Agreements. Plaintiffs’ claim the proof is that the BA only gets paid is he or she sells a Consulting Agreement or Agreements. The BA does not get paid unless he sells additional consulting services through JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN’s numerous and myriad consulting companies. 

Plaintiffs allege that JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN uses their sales team in the first three phases sell Marks the Business Analysis agreement under the deceptive premise that the Business Analysis is an “objective” review of the Mark’s business and business practices, and will provide solutions to any problems found.  Plaintiffs allege that in reality, the Business Analysis is nothing more that a ruse to get access to the Mark’s internal and confidential financial records and other business data. Once hired by the Mark, Plaintiff allege that the BA, under the ruse of an “objective” analysis, manipulates the Mark’s internal and confidential information with the sole and only goal of selling the Mark one of JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN’s Consulting Agreements. One fact proving the truth of this deception is the fact that the BA does not get paid for the Business Analysis. IPA’s BAs receive a commission only if they sell a Consulting Agreement to the Mark.  The BA’s commission is equal to a percentage of the money received pursuant to the Consulting Agreement. JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN’s BAs do not receive any commission until their paid.

Plaintiffs also allege that in the fourth phase of their scheme, JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN provide consulting services through many different companies owned or controlled by them.  Each company offering a separate and distinct form of consulting services, all of which are claimed by the Plaintiffs to be of the lowest professional standard and virtually worthless.  Their Consultants receive a commission for said services equal to a percentage of the money received by them pursuant to the Consulting Agreement. Their Consultants do not receive any commission until IPA is paid. 

Plaintiffs claim that JOHN R. BURGESS, GREGG STEINBURG, KEN SWEET, TYLER BURGESS and JOHN OWEN’s actions in violation of the RICO statute and their fiduciary duties has cause them great harm which they intend to show to the court and the jury.

For more information on this case, you can call the law firm of Reda & Des Jardins, Ltd., 8 South Michigan Avenue, 34^th Floor, Chicago, Illinois 60603, phone 312-236-9318, x311,
or fill out the appropriate form on this web site and someone will get back to you as soon as possible.