pa110 unit 3 assignment
Tanya Buckmaster
PA101 Unit 3
Kaplan University
December 2, 2014
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: __Negligence______
On or about April 8, 2011 plaintiff Justin King was traveling on his motorcycle south on the on Interstate 57 in Ford County, Paxton, Illinois.
On the occasion in question, defendant, Frank Cuellar driver for ANHEUSER-BUSCH COMPANIES, INC., Cueller was traveling behind King and signaled, using his headlights, to allow him to pass King. King moved to the center lane. As Cueller passes King, a load of beer fell onto King’s path.
King, having no other choice, veered into the left lane to avoid the cases of beer and hit the back distributed.
Defendant had a duty to comply with all applicable state and federal regulations intended to ensure the safety of other drivers. Further, the defendant’s driver operated his vehicle in violation of 625 ILCS 5/ Illinois
PA101 Unit 3
Kaplan University
December 2, 2014
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: __Negligence______
On or about April 8, 2011 plaintiff Justin King was traveling on his motorcycle south on the on Interstate 57 in Ford County, Paxton, Illinois.
On the occasion in question, defendant, Frank Cuellar driver for ANHEUSER-BUSCH COMPANIES, INC., Cueller was traveling behind King and signaled, using his headlights, to allow him to pass King. King moved to the center lane. As Cueller passes King, a load of beer fell onto King’s path.
King, having no other choice, veered into the left lane to avoid the cases of beer and hit the back distributed.
Defendant had a duty to comply with all applicable state and federal regulations intended to ensure the safety of other drivers. Further, the defendant’s driver operated his vehicle in violation of 625 ILCS 5/ Illinois