Potomac Group v. Pezzola

Appellate Court of Illinois·Decided August 12, 2026·No. 1-25-1138·Unpublished

Opinion

2026 IL App (1st) 251138-U No. 1-25-1138

Third Division

August 12, 2026

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS FIRST DISTRICT

)

POTOMAC GROUP, INC., an Illinois Corporation, )

)

Plaintiff and Counterdefendant-Appellant, )

)

v. ) Appeal from the Circuit Court ) of Cook County.

DAVID PEZZOLA, BRIAK SAK, and NETWORK ) TITLE, LLC, an Illinois Limited Liability Company, ) No. 2019 CH 13463 )

Defendants ) The Honorable ) Daniel J. Kubasiak,

(David Pezzola, ) Judge Presiding.

Defendant and Counterplaintiff-Appellee, )

)

Brian Sak and Network Title, LLC, )

Counterdefendants). )

)

JUSTICE REYES delivered the judgment of the court.

Presiding Justice Martin and Justice Rochford concurred in the judgment.

ORDER

¶1 Held: The circuit court’s judgment is reversed in part, affirmed in part, and vacated in part where (1) summary judgment in favor of the defendant buyer concerning the real estate transaction at issue should not have been granted due to the presence of multiple questions of material fact; (2) denial of the plaintiff seller’s motion for summary judgment was proper for the same reason; (3) given the result concerning the complaint, summary judgment concerning the defendant buyer’s counterclaim

was similarly inappropriate; and (4) the defendant buyer’s request for attorney fees is vacated as premature.

¶2 The instant appeal arises from a failed real estate transaction between plaintiff Potomac Group, Inc. (Potomac), and defendant David Pezzola. The circuit court granted summary judgment in favor of Pezzola with respect to a $50,000 earnest money deposit, finding that Potomac breached the contract between the parties, and also granted Pezzola attorney fees and costs. Potomac now appeals, contending that the circuit court erred in granting summary judgment to Pezzola instead of Potomac, in denying Potomac’s post-summary judgment motions to amend, and in awarding Pezzola attorney fees. For the reasons set forth below, we reverse the grants of summary judgment in Pezzola’s favor, affirm the denial of summary judgment with respect to Potomac, vacate the fee award, and remand for further proceedings.

¶3 BACKGROUND

¶4 Complaint and Amended Complaints

¶5 On November 20, 2019, Potomac filed a complaint in the circuit court of Cook County against defendants Pezzola and Brian Sak concerning a proposed sale of real estate; the complaint was amended several times, and it is the verified third amended complaint which is at issue on appeal. The third amended complaint alleged that, on March 18, 2019, Potomac entered into a real estate purchase and sale contract (the March contract) with “Brian Sak or nominee” with respect to 25 vacant residential lots in Olympia Fields; the purchase price was $750,000, with a $50,000 earnest money deposit tendered to nominal defendant Network Title, LLC (Network Title), as escrowee. Pezzola signed the March contract on behalf of the buyer. The March contract had no mortgage contingency clause and was scheduled to close on or before March 21, 2019. At the time of signing the March contract, Potomac did not hold title to the property, but had a prior agreement in place to purchase the property from Otoniel

Sanchez, its owner. The third amended complaint alleged that Potomac intended to close on its purchase with Sanchez, then close on its sale under the March contract, and alleged that “[a]t all times pertinent, based on its agreement with Sanchez, Potomac was able and willing to perform all its obligations required by the Contract, including transferring title of the Vacant Lots to Buyers.”

¶6 On March 20, 2019, Sak contacted Potomac’s manager and informed him that they would not close on March 21, 2019, as they wanted different lots than they had previously agreed to purchase; Pezzola also confirmed to the manager that they wished to purchase the different lots. The third amended complaint alleged that, “[d]espite having no obligation to do so, and without waiving any rights it had under the Contract, Potomac attempted to accommodate the new request,” and a new proposed agreement was prepared specifying the new lots. The new proposed agreement provided that closing would take place on April 12, 2019, and in anticipation of that closing date, Potomac also scheduled its closing on the purchase of the lots from Sanchez for the same date. At 8 p.m. on April 11, 2019, however, Potomac was notified by the buyers’ counsel that the April 12 closing would not be taking place.

¶7 On April 25, 2019, Potomac was informed by the buyers’ counsel that “ ‘the deal is back on,’ ” with a scheduled closing date of April 26, 2019. Pezzola wired Network Title an additional $325,000 toward the purchase price in connection with the rescheduled transaction. Despite the fact that there was never any financing contingency, the buyers again refused to close, with Pezzola claiming an inability to secure financing. “Without obligation,” Potomac authorized the return of the $325,000, but refused to return the $50,000 earnest money payment.

¶8 The third amended complaint alleged that Pezzola and Sak breached the March contract by failing to close on the purchase, and sought damages of $595,000, which was the profit Potomac would have received from the completed sale.

¶9 Counterclaim

¶ 10 In response to Potomac’s lawsuit, Pezzola filed a verified counterclaim against Potomac, Sak, and Network Title, in which he alleged that, on April 3, 2019, he and Potomac entered into a contract for the sale of the vacant residential lots (the April contract); at the time that they entered into the April contract, Potomac did not own the real estate that was the subject of the contract. The counterclaim alleged that, “[p]ursuant to an earlier iteration of Pezzola’s and Potomac’s agreement for the vacant lots,” he had deposited $50,000 in earnest money with Network Title, which “was to become non-refundable on April 12, 2019,” under the terms of the April contract. The April contract further provided that the attorney review and inspection period would remain open “until the parties reached a resolution on all outstanding issues or one party provided written notice of termination to the other party.” One such “outstanding issue” was Potomac’s ownership of the property. Under the April contract, the closing date was to be five business days after the date on which Pezzola received a written commitment for financing.

¶ 11 The counterclaim alleged that, on April 11, 2019, he provided written notice to Potomac that he was unable to obtain financing and was terminating the April contract effective immediately, and requested the return of the earnest money. Potomac refused to return the earnest money, which Pezzola alleged constituted a breach of contract. Pezzola accordingly requested a return of his earnest money, prejudgment interest, and attorney fees as provided in the April contract.

¶ 12 Contracts

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