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 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 Illinois 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 Northern District of Illinois.

COUNT I: ________

On April 8, 2011, plaintiff was traveling south on Interstate 57 just south of Chicago traveling on a motorcycle going about 60-65 MPH when a beer truck comes up behind him and flashes his lights. The client then moves into the right lane and shortly after beer cases fall off the truck and the client starts to swerve to miss the cases.

On the occasion in question, defendant, Anheuser-Busch Companies, Inc., the beer truck came up from behind the plaintiff, wanted to pass him. He saw the trucks flashing lights, came up behind the plaintiff flashing his lights at him.

The plaintiff saw a couple of cases of beer coming at me, so he swerved left to get out of the way.

Defendant had a duty to make sure the cases are secure and all doors are securely locked. The defendant also has a duty to maintain safe driving speeds and distances while on the road.

Defendant breached the duty of due care by moving through traffic at an unsafe speed.

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:

The plaintiff knew he was in a small hospital emergency room in Paxton. The plaintiff had 9 broken facial bones, jaw wired shut and spent two days in Paxton ICU. The plaintiff was unable to eat solid food and had a tube down his throat so he could eat for three days. He tries to undue his wires on his mouth to speak and the doctor and nurse sedate him and handcuff him to the bed so he will not further his injuries to his face. Couples of days later a doctor said his jaws were moving and the wires were loose with the left side of the clients face higher than the right. Another doctor tried to fix his face by resetting the bones with no success so they proceeded to try again with the same results no change and the plaintiff was left in more pain. After this the client was so depressed he tried to commit suicide they sent him to the psych ward at the Kansas City hospital. The plaintiff remained at the hospital under their care for over a year; he is now on anti-depressants to maintain a level head. He has outstanding medical bills in the amount of $145,000.00 and will have more to come for the plastic surgery to fix his face. The plastic surgery will cost upwards of $100,000.00. Client wants to sue the doctors and person(s) liable for his injuries for $100 million dollars.

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 $1,000,000.00.

2. Interest on such damages awarded as allowed by law;

3. Costs of suit; and

4. Such other and further relief as the Court may deem just and proper.

Dated: June 5, 2012

Jane Doe
IL Attorney License # 12345
Law Office of Jane Doe
123 Main Street
Chicago, IL 60601

Attorney for Plaintiff