Complaint Piggly Wiggly

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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

NORTHERN DIVISION

__________________________________________)

Sammy Hoagge, Plaintiff )

v. ) Civil Action No. 06-CH-25866

__________________________________________)

Piggly Wiggly, LLC, Defendant )

COMPLAINT

The plaintiff, Sammy Hoagge (“Hoagge”), for its complaint against defendant, Piggly Wiggly, LLC (“Piggly Wiggly”), alleges as follows:

THE PARTIES

1. The plaintiff, Hoagge, is a resident of 1234 Main Street, Chicago, Illinois 60614.

2. The defendant, Piggly Wiggly is a corporation organized and existing under the laws of the State of Illinois and has a principal place of business at 5454 N. Broadway, Skokie, IL 60077.

JURISDICTION AND VENUE

1. Plaintiff for all times mentioned herein, was a resident of the County of Cook, State of Illinois.

2. Plaintiff is informed and believes that defendant Piggly Wiggly, own and operate businesses within the County of Cook, State of Illinois.

GENERAL ALLEGATIONS

1. Piggly Wiggly is a manufacturer of the Squealer I and Squealer II bacon slicer.

2. Squealer I was developed in 1985 and Squealer II was developed in 1990.

3. Piggly Wiggly was responsible for manufacturing, design, servicing and repair of the units, as well as making sure that proper warnings and instructions were present.

4. On June 1, 1995 Sammy Hoagge was was injured while operating the Squealer I bacon slicer at the place of his employment, Lindy’s supermarket. Mr. Hoagge lost his left arm and suffered post-traumatic stress disorder after the injury. He had to stay in hospital and he still receives therapy for his post-traumatic stress. Due to injuries Sammy was moved to different departments, however, they were unsuccessful, so he had to end his employment with the supermarket. Mr. Hoagge is unemployed and divorced with two daughters.

5. The Squealer I was the equipment that was brought into the...