PA110-02: Civil Litigation
Unit 3 Assignment
Draft the Justin King Complaint
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
JUSTIN WILLIAM KING,
ANHEUSER-BUSCH COMPANIES, INC.
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 the County of St. Louis, State of Missouri and carries on business in the State of Illinois.
3. 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 the State of Missouri and the defendant is a citizen of the State of Illinois and the amount in controversy exceeds $75,000, exclusive of fees and costs.
4. 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, Illinois, in the United States District Court for the Northern District of Illinois.
On or about April 8, 2011, plaintiff Justin King, who signed a three year contract, in the amount of $275.000 a year, plus a percentage of sales with MCI Records, after he won the National Idol singing contest.
On the occasion in question, defendant, Anheuser-Busch, a truck driver and owner of Anheuser-Busch Companies, Inc., was involved on an accident going south on interstate 57, with Plaintiff Justin King, who was also driving his bike south on interstate 57, where plaintiff stated that the beer bottles started falling from the beer truck.
Defendant had a...
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