Case: 1:21-cv-06855 Document #: 1 Filed: 12/24/21 Page 1 of 18 PageID #:1
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
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`EASTERN DIVISION
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`Eric Wilim, individually and on behalf of all
`others similarly situated,
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`1:21-cv-06855
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`Plaintiff,
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`
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`- against -
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`Class Action Complaint
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`Mondelēz Global LLC,
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`
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`Defendant
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`Jury Trial Demanded
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`Plaintiff alleges upon information and belief, except for allegations pertaining to plaintiff,
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`which are based on personal knowledge:
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`1. Mondelēz Global LLC (“Defendant”) manufactures, labels, markets, and sells Honey
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`Wheat crackers under the Ritz brand (“Product”).
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`2.
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`The relevant front label representations include “Honey Wheat,” “5g whole grain per
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`16g serving,” a honey dipper, and stalks of wheat.
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`I.
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`CONSUMERS VALUE WHOLE GRAINS
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`3. Whole grains are associated with numerous health benefits.
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`4.
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`The 2015-2020 Dietary Guidelines for Americans recommend that at least half of all
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`grains eaten should be whole grains.
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`5.
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`The Dietary Guidelines recommend consuming 48g of whole grains per day.
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`6. However, Americans are consuming less than 16g of whole grains per day.
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`7.
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`It is recommended that individuals over 9 eat at least three to five daily servings of
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`whole grains, at 16g per serving.
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`A. Consumers Expect Fiber From Whole Grains
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`8.
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`The average person needs 28 grams of fiber per day.
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`9. Dietary Guidelines promote whole grains as an important source of fiber.
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`10. 87% of consumers try to consume more whole grains and 92% try to get more fiber.
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`11. Research proves that consumers seek whole grains because they want more fiber.
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`12.
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`In surveys, more than 60% of consumers stated they want to consume more whole
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`grains to improve their digestive health, which is reflective of a desire to increase fiber intake.
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`13. Almost 75% of consumers who are presented front label claims that a product is
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`made with, or contains whole grains, will expect that food to be at least a good source of fiber –
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`10% of the daily value.
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`14. Almost 70% of consumers agree with the statement that whole grains are one of the
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`best sources of fiber.
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`15. 62% of consumers agree that foods made from whole grains are one of the best
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`sources of fiber.
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`16. 46% of consumers rely on foods with whole grains for their daily fiber needs.
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`17. Based on the proven connection with fiber, whole grain statements do more than tell
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`consumers a product contains a type of grain ingredient.
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`18. At least half of consumers expect that for every gram of whole grain per serving,
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`there will be at least a gram of fiber.
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`19. The survey revealed that almost half of consumers who viewed a claim like that on
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`the Product, that a food contains 5 grams of whole grains per serving, would deliver at least 5
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`grams or more of fiber per serving.
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`20. This is based on the Nutrition Facts, which reveals the Product is not a good source
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`of fiber, as it indicates less than one gram of fiber, or 3% of the daily value, per serving.
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`21. The survey showed that consumers are misled by claims like that on the Product
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`where the food fails to deliver the expected amount of fiber.
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`B. Labeling Whole Grain Claims
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`22. Epidemiological studies have shown that the minimum meaningful amount of whole
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`grains deserving of mention in front-of-pack labeling is 8g per serving.
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`23. This figure is one-sixth of the 48g of whole grains people should consume daily.
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`24. The Product states, “5g whole grain per 16g serving.”
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`25. However, this does not tell consumers how much of the Product’s grain is refined
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`grains.
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`26. Even if consumers review the ingredients, which list “Unbleached Enriched Flour”
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`ahead of “Whole Grain Wheat Flour,” they will not learn the relative amount of refined and whole
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`grains.
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`UNBLEACHED
`INGREDIENTS:
`ENRICHED FLOUR (WHEAT FLOUR,
`NIACIN, REDUCED IRON, THIAMINE
`MONONITRATE
`{VITAMIN
`B1},
`RIBOFLAVIN {VITAMIN B2}, FOLIC
`ACID), WHOLE GRAIN WHEAT
`FLOUR, CANOLA OIL, SUGAR, PALM
`OIL, HONEY, LEAVENING (CALCIUM
`PHOSPHATE AND/OR BAKING SODA),
`SALT, SOY LECITHIN, ARTIFICIAL
`FLAVOR, NATURAL FLAVOR.
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`
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`27. Consumers are unable to know what percent of the weight of the serving size of the
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`Product is attributable to grain content compared to the Product’s other ingredients.
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`28. The result is consumers unknowingly consume more of the Product to get more
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`whole grains, even though they will end up consuming excess refined grains.
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`29. Consumption of substantially more refined grains than whole grains is inconsistent
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`with dietary guidelines to “make half your grains whole.”
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`30. Without knowing how many grams of refined grain are in the Product, consumers
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`cannot determine whether half their grains are whole.
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`31. Upon information and belief, the amount of whole grains to refined grains in the
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`Product is approximately 25%, based on a rough calculation from the Nutrition Facts.
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`32. Since one serving of the Product contains only 5g of whole grain, three servings
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`would be 15 g of whole grain, significantly less than what the Dietary Guidelines recommend, not
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`just for one day, but for one serving of whole grains.
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`33. The front label does not disclose the percentage of whole grains provided in a serving
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`compared to what the dietary guidelines recommend of 48g whole grains per day.
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`34. A recent study has shown that consumers are misled by the name, “Honey Wheat,”
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`and expect a food bearing this statement has more whole grains than it does.
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`35. Consumers believe that “honey wheat” is a type of wheat, which has more whole
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`grains than regular, refined wheat.
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`C. The Small Amount of Honey Furthers Impression Product Contains More Whole Grain
`than it Does
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`36. Consumers associate darker hues in grain products with a significant amount of
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`whole grain ingredients.
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`37. Though the Product contains honey purportedly for a sweetening effect, the honey is
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`also used to impart a darker color.
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`38. The Product’s color would be significantly lighter if based solely on the ratio of
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`refined grains to whole grains.
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`39. According to expert W.K. Nip, the presence of “mostly reducing sugars in [honey’s]
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`sugar profile” causes it “[to] brown[s] easily during baking, adding a natural dark color to baked
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`Case: 1:21-cv-06855 Document #: 1 Filed: 12/24/21 Page 6 of 18 PageID #:6
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`products such as bread, crackers, and other products.”1
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`40. This small amount of honey contributes to consumers getting the misleading
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`impression the Product contains more whole grains than it does.
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`II.
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`HONEY IS MISREPRESENTED AS MAIN SWEETENER
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`41. The representations convey that honey is the primary and/or a significant source of
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`sweetener ingredients used in the Product are misleading.
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`42. However, the Product is sweetened primarily with conventional sugars and contains
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`a miniscule amount of honey.
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`A. Sugar Disfavored as Sweetener
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`43.
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`In 2014, the National Institutes of Health cautioned, “experts agree that Americans
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`eat and drink way too much sugar, and it’s contributing to the obesity epidemic. Much of the sugar
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`we eat isn’t found naturally in food but is added during processing or preparation.”2
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`44. The NIH noted further: “[s]everal studies have found a direct link between excess
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`sugar consumption and obesity and cardiovascular problems worldwide.”3
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`45. There has long been a consensus among doctors and nutritionists that “[e]ating too
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`much sugar contributes to numerous health problems, including weight gain, Type 2 diabetes,
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`dental caries, metabolic syndrome and heart disease, and even indirectly to cancer because of
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`certain cancers’ relationship to obesity.”4
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`46.
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`In addition, “there is emerging research that suggests high-sugar diets may increase
`
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`1 W.K. Nip et al., eds. Bakery products: science and technology, Ch. 7, “Sweeteners,” John Wiley & Sons, 2006.
`2 NIH, Sweet Stuff: How Sugars and Sweeteners Affect Your Health, October 2014.
`3 Id.
`4 Marlene Cimons, Eating too much sugar can hurt your health, and for some it’s actually addictive, Washington Post
`December 16, 2017.
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`the risk of developing [dementia].”5
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`47. As part of a societal trend toward consuming healthier and natural foods, avoidance
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`of added sugar has been and remains a significant consumer preference, with consumers strongly
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`favoring honey as a sugar substitute.
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`48.
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`In August 2016, an article in “Prepared Foods” magazine noted that “[o]ngoing
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`concerns about obesity and sugar intake have driven interest in reduced sugar and diet drinks in
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`recent years.”6
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`49. As another observer of the food industry explained in May 2017, “[h]ealth concerns
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`and better educated consumers are propelling the demand for sugar reduction across food and
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`beverage categories. . . Sugar reduction will be one of the top marketing claims prominently
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`featured on products in
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`the coming year…”7
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`50. Similarly, an article in the February 28, 2018, edition of “Food Business News”
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`reported that “[s]peakers addressing consumer trends at the International Sweetener Colloquium
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`in Orlando on February 13 said sugar avoidance was a macro trend ‘that is here to stay and will
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`only increase.’”8
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`51.
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` The same article noted that “I.R.I. [Information Resources, Inc.] surveys show that
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`58% of consumers across generations are avoiding sugar. . . [and of] those avoiding sugar, 85%
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`are doing so for health reasons and 58% for weight concerns.”9
`
`
`5 Kieron Rooney, Yes, too much sugar is bad for our health – here’s what the science says, The Conversation, March
`8, 2018.
`6 PreparedFoods.com, Trends in Sugar Reduction and Natural Sweeteners, August 24, 2016.
`7 Laura Dembitzer, Less is More: Sugar Reduction, Less Sodium & Low-FODMAPS in Food, Beverage, Food Insider
`Journal, May 09, 2017.
`8 Ron Sterk, Avoidance of sugar remains macro trend, Food Business News, February 28, 2018
`9 Id.
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`B. Consumer Preference for Products Sweetened with Honey Instead of Sugar
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`52. Surveys show “[c]onsumers rated honey at 73% ‘better for you than sugar.”10
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`53. A survey in “Prepared Foods” magazine noted that: (i) “93% of consumers consider
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`honey to be a natural sweetener;” (ii) “58% of consumers with one or more children look for honey
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`on the product label;” (iii) “60% of consumers between the ages of 18 and 34 look for honey on
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`the product label; and (iv) about half of consumers would pay at least 5% more for food bars,
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`ready-to-drink tea, and yogurt primarily sweetened with honey.”11
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`54. Referring to food products perceived as healthier, the Huffington Post reported that
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`“[a]ccording to a 2015 Nielsen survey of 30,000 people, 90% of shoppers are willing to pay more
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`for the added quality and benefits” these foods and ingredients provide.12
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`55. Honey fits all these criteria, as a naturally occurring substance and, unlike sugar, has
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`small amounts of nutrients such as vitamins, minerals, enzymes, and antioxidants.
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`56.
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`In addition, honey has a lower glycemic index than sugar, causing slower fluctuations
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`in blood sugar and therefore in insulin levels.
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`57. Rapid spikes of blood sugar lead to quick spurts of energy followed by sharp declines
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`characterized by tiredness, headaches, and difficulties in concentrating (“low blood sugar”).
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`58. Although sugar contains slightly fewer calories than honey by weight, honey is much
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`sweeter than sugar and therefore less is needed to achieve the same level of sweetness.
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`59. Based on the common marketplace perception that honey is healthier and more
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`natural than sugar, consumers place a greater value on products that are sweetened with honey
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`instead of sugar and are willing to pay a higher price for such products.
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`
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`10 Id.
`11 Supra, Trends in Sugar Reduction and Natural Sweeteners.
`12 Brian Kennell, Healthy Food Trends Drive New Products, HuffingtonPost.com, October 1, 2015, updated December
`6, 2017.
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`C. Contrary to Representations, Honey is Present in De Minimis Amount and Product Is
`Sweetened Mainly with Sugar
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`60. The Product’s ingredients, listed in descending order of predominance, reveal that
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`“Sugar” is the predominant sweetening agent, followed by “Palm Oil,” and then “Honey.”
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`61. The Product has more palm oil than honey, yet the front label does not disclose the
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`presence of palm oil.
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`62. Consumer preference is for foods which get their taste from food ingredients – like
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`honey – instead of added “honey” flavor, because it is perceived as more natural and less processed
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`than a flavor solution made by a chemist in a laboratory.
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`63. The amount of honey is misleading because it is present in a smaller amount than
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`expected.
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`64. At best, honey may provide a slight “honey” taste.
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`65. However, because there is such a small amount of honey, it is insufficient to provide
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`such a taste.
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`66.
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` No less than 70% of consumers try to avoid added flavors, because even “natural”
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`flavors have been linked to detrimental health effects, contain additives, and made with
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`environmentally harmful solvents.
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`67. Unfortunately for consumers, what consumers may recognize as a “honey” taste is
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`not entirely from honey, but from the natural and/or artificial flavor listed in the ingredient list.
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`68. The front label fails to disclose the Product is natural and/or artificially honey
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`flavored, even though this statement is required under federal and state law.
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`69. The added flavors imitate honey, causing consumers to expect it has more honey than
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`it does.
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`70. Consumers are misled to expect a non-negligible amount of honey because they see
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`the honey dipper and the word “honey.”
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`III. CONCLUSION
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`71. The Product contains other representations which are misleading.
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`72. Reasonable consumers must and do rely on a company to honestly identify and
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`describe the components, attributes, and features of a product, relative to itself and other
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`comparable products or alternatives.
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`73. The value of the Product that Plaintiff purchased was materially less than its value
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`as represented by defendant.
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`74. Defendant sold more of the Product and at higher prices than it would have in the
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`absence of this misconduct, resulting in additional profits at the expense of consumers.
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`75. Had Plaintiff and proposed class members known the truth, they would not have
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`bought the Product or would have paid less for it.
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`76. The Product is sold for a price premium compared to other similar products, no less
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`than approximately $2.99 per 13.7 oz, a higher price than it would otherwise be sold for, absent
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`the misleading representations and omissions.
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`Jurisdiction and Venue
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`77.
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`Jurisdiction is proper pursuant to Class Action Fairness Act of 2005 (“CAFA”). 28
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`U.S.C. § 1332(d)(2).
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`78. The aggregate amount in controversy exceeds $5 million, including any statutory
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`damages, exclusive of interest and costs.
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`79. Plaintiff Eric Wilim is a citizen of Illinois.
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`80. Defendant Mondelēz Global LLC, is a Delaware limited liability company with a
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`principal place of business in East Hanover, Morris County, New Jersey and upon information and
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`belief, at least one member of defendant is not a citizen of the same state as the plaintiff.
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`81. Defendant’s managing member is Mondelēz International, Inc., a Virginia
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`corporation with a principal place of business in New Jersey.
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`82. Defendant transacts business within this District through sale of the Product at stores
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`within this State and District, including big box stores, convenience stores, drug stores, grocery
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`stores, club stores, and online, sold directly to residents of this District.
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`83. Venue is in this District because plaintiff resides in this district and the actions giving
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`rise to the claims occurred within this district.
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`84. Venue is in the Eastern Division in this District because a substantial part of the
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`events or omissions giving rise to the claim occurred in Lake County, i.e., Plaintiff’s purchase of
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`the Product and his awareness of the issues described here.
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`Parties
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`85. Plaintiff Eric Wilim is a citizen of Grayslake, Lake County, Illinois.
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`86. Defendant Mondelēz Global LLC, is a Delaware limited liability company with a
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`principal place of business in East Hanover, New Jersey, Morris County.
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`87. Defendant’s products, including the Product in this action, are sold to consumers by
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`third-parties, available online and in almost every convenience store, grocery store, big box store,
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`drug store in Illinois.
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`88. The Product is sold in packaging of various sizes.
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`89. Defendant’s managing member is Mondelēz International, Inc., a Virginia
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`corporation with a principal place of business in New Jersey.
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`90. The forerunner of Mondelez was the National Biscuit Company, formed in 1898
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`from a merger of over 100 bakeries in the country.
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`91. Nabisco, as it was called, revolutionized packaged snacks through wrapping which
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`maintained freshness and kept out debris.
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`92. Prior to this, crackers were sold loose in a barrel, which is where the term “cracker
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`barrel” comes from.
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`93. Nabisco introduced numerous staples of American pantries, including Oreo Cookies,
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`Barnum’s Animal Crackers, Honey Maid Grahams, Ritz crackers, Wheat Thins, Saltines, and
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`Chips Ahoy.
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`94. Nabisco was the second largest advertiser after tobacco companies for much of its
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`history, which created a great reservoir of public trust.
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`95. Nabisco, and its successor, Defendant, emphasizes its commitment to quality
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`products, labeled honestly, in support of giving consumers the high value they deserve.
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`96. These facts show a company with a significant amount of goodwill and equity when
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`it comes to consumer purchasing.
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`97. Plaintiff purchased the Product on one or more occasions within the statutes of
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`limitations for each cause of action alleged, at stores including Walmart, 1205 S Rte 31 Crystal
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`Lake IL 60014-8213 between December 2020 and July 2021, among other times.
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`98. Plaintiff bought the Product because he expected it contained more whole grains,
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`fiber, and honey, than it did because that is what the representations said and implied.
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`99. Plaintiff relied on the words and images on the Product, on the labeling and/or claims
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`made by Defendant in digital and/or social media.
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`100. Plaintiff bought the Product at or exceeding the above-referenced price.
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`101. Plaintiff would not have purchased the Product if he knew the representations and
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`omissions were false and misleading or would have paid less for it.
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`102. Plaintiff chose between Defendant’s Product and products represented similarly, but
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`which did not misrepresent their attributes, features, and/or components.
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`103. The Product was worth less than what Plaintiff paid and he would not have paid as
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`much absent Defendant's false and misleading statements and omissions.
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`104. Plaintiff intends to, seeks to, and will purchase the Product again when he can do so
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`with the assurance the Product's representations are consistent with its abilities and/or composition.
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`105. Plaintiff is an unable to rely on the labeling of not only this Product, but other similar
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`products, because he is an unsure of whether their representations are truthful.
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`Class Allegations
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`106. Plaintiff seeks certification under Fed. R. Civ. P. 23(b)(2) and (b)(3) of the following
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`classes:
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`Illinois Class: All persons in the State of Illinois who
`purchased the Product during the statutes of limitations for
`each cause of action alleged.
`
`Consumer Fraud Multi-State Class: All persons in the
`States of Ohio, Michigan, Nevada, Arizona, Rhode Island,
`North Dakota, Texas, Iowa, Virginia, New Hampshire,
`Maine, Alaska, South Dakota, and Oklahoma, who
`purchased the Product during the statutes of limitations for
`each cause of action alleged
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`107. Common questions of law or fact predominate and include whether defendant’s
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`representations were and are misleading and if plaintiff and class members are entitled to damages.
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`108. Plaintiff's claims and basis for relief are typical to other members because all were
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`subjected to the same unfair and deceptive representations and actions.
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`109. Plaintiff is an adequate representative because his interests do not conflict with other
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`members.
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`110. No individual inquiry is necessary since the focus is only on defendant’s practices
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`and the class is definable and ascertainable.
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`111. Individual actions would risk inconsistent results, be repetitive and are impractical
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`to justify, as the claims are modest relative to the scope of the harm.
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`112. Plaintiff's counsel is competent and experienced in complex class action litigation
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`and intends to protect class members’ interests adequately and fairly.
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`113. Plaintiff seeks class-wide injunctive relief because the practices continue.
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`Illinois Consumer Fraud and Deceptive Business Practices Act
`(“ICFA”), 815 ILCS 505/1, et seq.
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`(Consumer Protection Statute)
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`114. Plaintiff incorporates by reference all preceding paragraphs.
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`115. Plaintiff and class members desired to purchase a product that contained more whole
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`grains, fiber, and honey, than it did.
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`116. Defendant’s false and deceptive representations and omissions are material in that
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`they are likely to influence consumer purchasing decisions.
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`117. Defendant misrepresented the Product through statements, omissions, ambiguities,
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`half-truths and/or actions.
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`118. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`119. Defendant misrepresented the Product through statements, omissions, ambiguities,
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`half-truths and/or actions.
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`120. Plaintiff relied on the representations that the Product contained more whole grains,
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`fiber, and honey, than it did
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`121. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`Violation of State Consumer Fraud Acts
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`(On Behalf of the Consumer Fraud Multi-State Class)
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`122. The Consumer Fraud Acts of the States in the Consumer Fraud Multi-State Class are
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`similar to the ICFA and prohibit the use of unfair or deceptive business practices in the conduct of
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`trade or commerce.
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`123. Defendant intended that each of members of the Consumer Fraud Multi-State Class
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`would rely upon its deceptive conduct, and a reasonable person would in fact be misled by this
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`deceptive conduct.
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`124. As a result of defendant’s use or employment of artifice, unfair or deceptive acts or
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`business practices, each of the other members of the Consumer Fraud Multi-State Class, have
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`sustained damages in an amount to be proven at trial.
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`125. In addition, defendant’s conduct showed motive, and the reckless disregard of the
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`truth such that an award of punitive damages is appropriate.
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`Breaches of Express Warranty,
`Implied Warranty of Merchantability/Fitness for a Particular Purpose and
`Magnuson Moss Warranty Act, 15 U.S.C. §§ 2301, et seq.
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`126. The Product was manufactured, identified, and sold by defendant and expressly and
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`impliedly warranted to plaintiff and class members that it contained more whole grains, fiber, and
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`honey, than it did.
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`127. Defendant directly marketed the Product to consumers through its advertisements
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`and partnerships with retailers, through social media, and in print circulars.
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`128. Defendant knew the product attributes that potential customers like Plaintiff were
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`seeking, and developed its marketing to directly meet those needs and desires.
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`129. Defendant’s representations affirmed and promised that the Product contained more
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`whole grains, fiber, and honey, than it did.
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`130. Defendant described the Product as one which contained more whole grains, fiber,
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`and honey, than it did, which became part of the basis of the bargain that the Product would
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`conform to its affirmation and promise.
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`131. Defendant had a duty to disclose and/or provide non-deceptive descriptions and
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`marketing of the Product.
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`132. This duty is based on Defendant’s outsized role in the market for this type of Product,
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`a trusted company known for its high quality products.
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`133. Plaintiff provided or will provide notice to defendant, its agents, representatives,
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`retailers, and their employees.
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`134. Defendant received notice and should have been aware of these issues due to
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`complaints by regulators, competitors, and consumers, to its main offices, and by consumers
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`through online forums.
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`135. The Product did not conform to its affirmations of fact and promises due to
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`defendant’s actions and were not merchantable because it was not fit to pass in the trade as
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`advertised and not fit for the purpose for which it was intended.
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`136. The Product was not merchantable because it was not adequately contained,
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`packaged, and labeled as required by the representations, and did not conform to the promises and
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`affirmations of fact made on the container or label.
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`137. Defendant had reason to know that the purpose for which the Product was bought by
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`Plaintiff and consumers was because they expected it contained more whole grains, fiber, and
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`honey, than it did, and they relied on Defendant’s skill or judgment to select or furnish such a
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`Case: 1:21-cv-06855 Document #: 1 Filed: 12/24/21 Page 17 of 18 PageID #:17
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`suitable product.
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`138. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`Negligent Misrepresentation
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`139. Defendant had a duty to truthfully represent the Product, which it breached.
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`140. This duty is based on defendant’s position, holding itself out as having special
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`knowledge and experience in this area, a trusted company known for its high quality products.
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`141. The representations took advantage of consumers’ cognitive shortcuts made at the
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`point-of-sale and their trust in defendant.
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`142. Plaintiff and class members reasonably and justifiably relied on these negligent
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`misrepresentations and omissions, which served to induce and did induce, their purchase of the
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`Product.
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`143. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`Fraud
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`144. Defendant misrepresented and/or omitted the attributes and qualities of the Product,
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`that it contained more whole grains, fiber, and honey, than it did.
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`145. Moreover, the records Defendant is required to maintain, and/or the information
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`inconspicuously disclosed to consumers, provided it with actual and/or constructive knowledge of
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`the falsity of the representations.
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`146. Defendant’s fraudulent intent is evinced by its knowledge that the Product was not
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`consistent with its representations.
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`Unjust Enrichment
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`147. Defendant obtained benefits and monies because the Product was not as represented
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`Case: 1:21-cv-06855 Document #: 1 Filed: 12/24/21 Page 18 of 18 PageID #:18
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`and expected, to the detriment and impoverishment of plaintiff and class members, who seek
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`restitution and disgorgement of inequitably obtained profits.
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`Jury Demand and Prayer for Relief
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`Plaintiff demands a jury trial on all issues.
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` WHEREFORE, Plaintiff prays for judgment:
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`1. Declaring this a proper class action, certifying plaintiff as representative and the
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`undersigned as counsel for the class;
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`2. Entering preliminary and permanent injunctive relief by directing defendant to correct the
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`challenged practices to comply with the law;
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`3. Injunctive relief to remove, correct and/or refrain from the challenged practices and
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`representations, and restitution and disgorgement for members of the class pursuant to the
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`applicable laws;
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`4. Awarding monetary damages, statutory and/or punitive damages pursuant to any statutory
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`claims and interest pursuant to the common law and other statutory claims;
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`5. Awarding costs and expenses, including reasonable fees for plaintiff's attorneys and
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`experts; and
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`6. Other and further relief as the Court deems just and proper.
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`Dated: December 24, 2021
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`Respectfully submitted,
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`Sheehan & Associates, P.C.
`/s/Spencer Sheehan
`60 Cuttermill Rd Ste 409
`Great Neck NY 11021
`Tel: (516) 268-7080
`spencer@spencersheehan.com
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