Complaint

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN 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 is principal place of business in [name of state] and carries on business in [state where court is located].

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 [name of state] and the defendant is a citizen of [name of state] 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 [name of county], in [name of district] of [name of state].

COUNT I: ________

On or about [date of injury], plaintiff [description of plaintiff's activity].

On the occasion in question, defendant, [name of defendant], [description of defendant's negligent activity].

[Description of nature of accident.]

Defendant had a duty to [describe the existence of a duty]

Defendant breached the duty of due care by [describe negligent conduct as a breach of duty of care]

As a direct and proximate cause of defendant's negligent activity, as set forth above, plaintiff has incurred the following expenses for medical care and attention:

[Description of damages]

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury.

PRAYER FOR RELIEF

WHEREFORE, plaintiff requests judgment against defendant as follows:

1. General damages in the sum of $[dollar amount of general...