Complaint: Jury and United States District
FOR THE NORTHERN DISTRICT OF ILLINOIS
JUSTIN WILLIAM KING, ) )
Plaintiff. ) ) )
v. ) )
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 Illinois and carries on business in United States District Court for the Northern District of 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 Illinois and the defendant is a citizen of Missouri 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: ___Negligence_____
On or about April 8, 2011 plaintiff, Justin King was driving south on highway 57 on his motorcycle.
On the occasion in question, defendant Anheuser Busch, breeched a duty to all those driving on the highway when he failed to ensure the safety of his vehicle and its contents.
As a result my client has sustained injuries both mentally and physically due to “product” (cases of beer) falling off of his truck and hitting my client. This all caused a major motor vehicle accident on Highway 57 South in Paxton.
Defendant had a duty to ensure the safety of his vehicle while driving on the roadways with others.
Defendant breached the duty of due care by not following proper safety protocol and ensuring that everything on his truck was safe and all product on the truck was safely locked in to the truck, as