IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL 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 its principal place of business in St. Luis, Missouri and carries on business in the state of Illinois.

3.This court has subject matter jurisdiction over the claims presented in this complaint under 28 U.S.C. § 1332 because plaintiff …show more content…
That King won the National Idol Regional Contest in Chicago last year, three days prior to the accident.

12. That King signed a three year record contract with MCI Records, with a guarantee of $275,000 a year, and a percentage of sales, as a result of winning the contest.

13. That King’s record contract with MCI was cancelled and he was forced to withdraw from the National Idol Contest.

14. The Defendant had a duty to comply with all applicable state and federal regulations intended to ensure the safety of other drivers.

15. The defendant breached the duty of due care by operating a vehicle in violation of 625 ILCS 5/ Illinois Vehicle Code covering the operation of motor vehicles on the streets and roads of the State of Illinois. The statutes are set out in Illinois Vehicle Code Annotated, which are incorporated herein by reference and will be read by their entirety at the trial of this cause of action, said code sections being:

Ill. Code Ann. 625 ILCS 5/ Ch. 6, Art. V. Sec. (6)(A)(1), “Commercial Motor Vehicle Operators”;

Ill. Code Ann. ILCS 5/ Ch. 11, Art. II. “Obedience to and Effect of Traffic laws”;

Ill. Code Ann. ILCS 5/ § 11-705 “Limitations on Overtaking on the Left”;

Ill. Code Ann. ILCS 5/ § 11-709 (a)(b)(c) “Driving on Roadways Laned for …show more content…
Code Ann. ILCS 5/ § 15-109 (a)(b)(c) “Spilling loads on highways prohibited”

16. 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:

17. That the Plaintiff, sustained permanent injuries to his face and jaw. The Plaintiff was admitted and spent two days in the Intensive Care Unit at Paxton Hospital prior to the accident.

18. That the Plaintiff while at Paxton Hospital, was under severe duress and acute pain, as a result, he tried to loosen the wires from his jaw. The attending physician and nurse had to sedate the plaintiff and handcuff him to the bed.

19. Upon awakening from a sedated state, the plaintiff, requested to be transported to another hospital.

20. That the Plaintiff was transported to Metropolitan Memorial Hospital where he endured multiple unsuccessful attempts to reset his jaw. As a result the left side of the plaintiff’s face remains higher than the right side.

21. That the plaintiff’s medical bills are currently at $145,000, and that the, future medical bills, plastic surgery, and, counseling are estimated to be $100,000 or