PA110 Complaint Form 1

Topics: Illinois, Jurisdiction, Anheuser-Busch Pages: 4 (707 words) Published: May 3, 2015


IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL 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 its 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.

COUNT I: ________

5. On or about April 8, 2013, Justin King won the national regional idol MCI contest in Chicago. A few days later, King met with his agent to discuss signing a legal document three year contract for over 275,000 dollars. After leaving the meeting with his agent, King took interstate 57 just South of Chicago. Plaintiff Justin King, while in the exercise of due care, was operating his motorcycle on Interstate 57, heading in a south direction, in the City of Paxton, Illinois. On the same occasion, defendant, Frank Cuellar, a resident of Illinois, was operating a beer truck owned by Anheuser- Busch, and was traveling in a south direction on Interstate 57, a highway in the City of Paxton, Illinois. On occurrence, plaintiff Justin King...
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