Justin King Complaint

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, complains of defendant, Anheuser-Busch Companies, INC.,

PARTIES AND JURISDICTION

1. Plaintiff, for all times mentioned herein, was and is a resident of County of Paxton, State of Illinois.

2. Plaintiff is informed and thereon alleges that defendant, Anheuser Busch, is a business place primarily operating out of the County of St. Louis, State of Missouri.

3. This action is of damages that exceeds $75,000, as required by 28 USC 1332.

4. At the time plaintiff was the owner of a certain Harley Davidson, motorcycle.

5. At all times herein mentioned Interstate 57 is a public highway running in a general north and south direction.

6. Around April 8, 2004, plaintiff was operating his automobile in a prudent and careful manner. Headed the direction of South on Interstate 57.

7. At the time and place where the defendant with gross negligence and wanton disregard for the safety of others drove and operated his vehicle caused the loss of his load, making the roadway hazardous to the plaintiff.

8. Defendant that was driving the vehicle in a reckless manner was in violation of several Illinois State Statues.

Subpart I- Protections against shifting and falling cargo §393.102(a) Performance criteria.-(1) Breaking strength. Tie down assemblies (chains, wire rope, steel strapping, synthetic webbing, ect,.)

9. Plaintiff was injured as a direct result of the accident, the same having been directly and proximately caused by the negligence of the defendant.

10. Plaintiff is informed that the injuries will result in some disability to him, all to the damage that he sustained in the amount of $75,000.

This court has jurisdiction...