Justin King Complaint

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IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR FORD COUNTY, ILLINOIS

JUSTIN WILLIAM KING, )
)
Plaintiff.)
)
)
v. )
)
Anheuser Busch Companies, Inc.)
)
Defendant.)
____________________________________)

COMPLAINT

Comes Now the plaintiff, Justin King, by and through his attorney, states as follows:

JURISDICTION AND VENUE

Plaintiff, for all times mentioned herein, was and is a resident of the County of Jackson, State of Missouri.

The cause of action took place in Ford County, Illinois.

This is an action for damages in excess of the minimal jurisdictional limits of this court.

This court has original jurisdiction “of all justiciable matters” under Ill. Const. 1970, art. VI, § 1.01 because the matter in controversy exceeds $75,000, the Plaintiff, Justin King, is a resident of the State of Missouri, and the Defendant, Anheuser-Busch Companies, Inc. (Anheuser-Busch), although headquartered in the State of Missouri, is authorized to do, and in fact does, business in the State of Illinois where the accident took place.

This court has appropriate venue under 735 ILCS 5/2-619 because the events leading to the Plaintiff’s claim and cause of action occurred in this judicial district, and because the Defendant was subject to personal jurisdiction in this judicial district at the time of the occurrence.

FACTUAL ALLEGATIONS TO ALL COUNTS

COUNT I: Negligence

1. Plaintiff Justin King is a resident of Kansas City, Missouri. 2. Defendant Anheuser-Busch is a Missouri-based corporation and also does business in the State of Illinois. 3. On or about April 8, 2004, Plaintiff was driving a 2006 black Harley Davidson motorcycle, License No. 07 MO 327-HP8, owned by Plaintiff. 4. On or about April 8, 2004, Frank Cuellar, an employee of Defendant, was operating a 1992 White Nissan beer truck, License No. 07 MO 968-7RL, owned by defendant. 5. Frank Cuellar at all times...
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