Complaint of Justin King

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

JUSTIN WILLIAM KING, )

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Plaintiff. )

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v. )

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ANHEUSER-BUSCH COMPANIES, INC. )

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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 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, IL where a substantial part of the events or omissions giving rise to the plaintiffs claim and causes of action occurred in this judicial district, and because the defendants Anheuser-Busch Companies, Inc., were subject to personal jurisdiction in this judicial district at the time of the commencement of this action.

I

FACTUAL BACKGROUND

Justin King suffered severe head trauma and facial injuries, in a motor vehicle accident, due to the negligence of Anheuser-Busch Company, Inc.:

1.1     That on April 8, 20011, King was traveling on his motorcycle south on Interstate 57, in Ford County, Paxton, Illinois.

1.2      That Frank Cuellar, truck driver for Anhueser-Busch, was transporting a load of beer cases in the back of his Anheuser- Busch truck.

1.3      That Cuellar was traveling behind King and signaled, using his headlights, to allow him to pass. King moved to the left lane and then back to the...