IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
WESTERN DIVISION

DEKALB COUNTY, and JOHN ACARDO,
in his capacity as DeKalb Clerk & Recorder,
on behalf of themselves and all others
similarly situated,
Plaintiffs,

vs.

FEDERAL HOUSING FINANCE
AGENCY, AS CONSERVATOR FOR
FEDERAL NATIONAL MORTGAGE
ASSOCIATION AND FEDERAL HOME
LOAN MORTGAGE CORPORATION;
FEDERAL NATIONAL MORTGAGE
ASSOCIATION, a federally chartered
corporation; and FEDERAL HOME LOAN
MORTGAGE CORPORATION, a federally
chartered corporation,
Defendants.

CLASS ACTION COMPLAINT

Excerpt:

8. Plaintiffs bring this action on their own behalf and, pursuant to Fed. R. Civ. P. 23,
on behalf of a class of persons defined as any Illinois county, and the Recorder or Registrar of
Titles of said counties, which have recorded a deed or other conveyance from Defendants Fannie
Mae or Freddie Mac where those Defendants have claimed they are exempt from the Illinois
Transfer Tax as set forth in 35 ILCS 200/31-1, et seq.

9. The members of the class are so numerous that joinder of all members is
impracticable. The total number of class members is believed to include all Illinois counties.
There are 102 counties in Illinois.

10. The questions of law and fact common to the class concern whether Defendants
Fannie Mae and Freddie Mac qualify for the exemptions they claim from the Illinois Transfer
Tax. These common questions will predominate over any individual questions throughout the
litigation.

11. The claim of Plaintiffs and the absent class members have a common origin and
share a common basis. Their claim originates from the same practice by Defendants Fannie Mae
and Freddie Mac and Defendants act in the same way toward Plaintiffs and the members of the
class. Consequently, the named Plaintiffs and each class member has been the victim of
Defendants’ actions. Plaintiffs’ claim is typical of the claim of absent class members. If brought
individually, the claim of each class member would necessarily require proof of the same
material and substantive facts, and seek the same remedies.

12. The Plaintiffs are willing and prepared to serve the Court and the proposed class
in a representative capacity. The Plaintiffs will fairly and adequately protect the interest of the
class and have no interest adverse to, or which directly and irrevocably conflicts with, the
interests of other members of the class. Plaintiffs have retained counsel experienced in
prosecuting complex class action litigation.

13. A class action is superior to other available methods for the fair and efficient
adjudication of this controversy because individual claims by the class members are impractical
as the costs of prosecution may exceed what any class member has at stake.

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