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 is principal place of business in Missouri and carries on

business in Illinois.

3. 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.

4. 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: ________

5. On or about April 8, 2013, the plaintiff was returning home after signing a contract with MCI
Records. He was traveling southbound on Interstate 57 on his motorcycle and was going about
60 65 MPH when he saw flashing lights behind him belonging to a beer truck. The client
moved into the right lane to allow the truck to pass, but as he was doing so beer cases fell off of
the truck. The client had to swerve to avoid the cases.

6. On the occasion in question, defendant, Anheuser-Busch Companies, Inc., failed to secure his
cargo, which fell from his truck and into the plaintiffs path.

7. Because the defendants load fell from the truck, the plaintiff swerved left to avoid the load
and was hit by the truck.

8. Defendant had a duty to ensure that his cargo was secure and that all doors were firmly shut
and locked.

9. Defendant breached the duty of due care by failing to properly secure his cargo.

10. 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:

11. Plaintiff was injured as a direct result of the incident. Plaintiffs jaw was wired shut due to
nine broken bones in his face. He was unable to eat solid food for three days because he had a
feeding tube down his throat. Plaintiff tried to loosen the wires on his jaw and as a result had to
go through the painful process of having to have his bones reset. As a direct result of the
incident, the plaintiff was left disfigured and now has to undergo facial reconstruction. The
injuries received by the plaintiff have caused him great physical and mental pain. The incident
has left the plaintiff so depressed that he attempted suicide and as a result was admitted to a
psychiatric facility at the Kansas City Hospital, where he remained for over a year. Plaintiff now
takes anti-depressants and visits a psychiatrist regularly. His current outstanding medical bills
total $145,000.00 and doctors anticipate his facial reconstruction and counseling will total more
than $100,000.00. Plaintiff wishes to sue the persons 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: February 17, 2015

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

Attorney for Plaintiff