PA110 complaint form unit3
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF 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:
PARTIES AND JURISDICTION
1. Plaintiff, for all times mentioned herein, was and is a resident of Cook County, State of Illinois.
2. Defendant is a corporation with is principal place of business in Missouri and carries on business in Illinois.
This court has subject matter jurisdiction over the claims presented in this complaint under 28 U.S.C. § 1332 because plaintiff is a resident of Kansas and the defendant is a citizen of Illinois and the amount in controversy exceeds $75,000, exclusive of fees and costs.
Personal jurisdiction and venue are proper in this District pursuant to 28 U.S.C. § 1391 because the acts of defendant caused harm to plaintiff in Ford County, in Paxton of Illinois.
COUNT I: ________
On or about April 8,2011, plaintiff [description of plaintiff's activity].
On the occasion in question, defendant, Anheuser-Busch, and their employee Frank Cuellar failed to maintain a safe driving experience with a secure load..
Shipment became loose and hit oncoming motorcyclist.
Defendant had a duty to maintain a safe and secure shipment while traveling.
Defendant breached the duty of due care by making sure shipment was loaded securely.[describe negligent conduct as a breach of duty of care]
As a direct and proximate cause of defendant's negligent activity, as set forth above, plaintiff has incurred the following expenses for medical care and attention:
Ongoing medical mentally and physically care with date. Damages for vocal contract denied. Physical and emotional damages. Motorcyle damages.
DEMAND FOR JURY TRIAL
Plaintiff demands a trial by jury.
PRAYER FOR RELIEF
WHEREFORE, plaintiff
FOR THE NORTHERN DISTRICT OF 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:
PARTIES AND JURISDICTION
1. Plaintiff, for all times mentioned herein, was and is a resident of Cook County, State of Illinois.
2. Defendant is a corporation with is principal place of business in Missouri and carries on business in Illinois.
This court has subject matter jurisdiction over the claims presented in this complaint under 28 U.S.C. § 1332 because plaintiff is a resident of Kansas and the defendant is a citizen of Illinois and the amount in controversy exceeds $75,000, exclusive of fees and costs.
Personal jurisdiction and venue are proper in this District pursuant to 28 U.S.C. § 1391 because the acts of defendant caused harm to plaintiff in Ford County, in Paxton of Illinois.
COUNT I: ________
On or about April 8,2011, plaintiff [description of plaintiff's activity].
On the occasion in question, defendant, Anheuser-Busch, and their employee Frank Cuellar failed to maintain a safe driving experience with a secure load..
Shipment became loose and hit oncoming motorcyclist.
Defendant had a duty to maintain a safe and secure shipment while traveling.
Defendant breached the duty of due care by making sure shipment was loaded securely.[describe negligent conduct as a breach of duty of care]
As a direct and proximate cause of defendant's negligent activity, as set forth above, plaintiff has incurred the following expenses for medical care and attention:
Ongoing medical mentally and physically care with date. Damages for vocal contract denied. Physical and emotional damages. Motorcyle damages.
DEMAND FOR JURY TRIAL
Plaintiff demands a trial by jury.
PRAYER FOR RELIEF
WHEREFORE, plaintiff