By: Chris Coln

CIVIL LITIGATION | PA110

Prof. David Rakowski, Esq.
April 9, 2013
IN THE UNITED STATES DISTRICT COURT FOR
THE NORTHERN DISTRICT OF ILLINOIS


JUSTIN WILLIAM KING, )
)
Plaintiff. )
)
v. ) Case No.
)
)
ANHEUSER-BUSCH COMPANIES, INC. )
)
Defendant. )
_______________________________________)

COMPLAINT
COMES NOW, the Plaintiff, JUSTIN WILLIAM KING, by and through his
undersigned attorney of record, and alleges as follows:
PARTIES
1. Plaintiff, JUSTIN WILLIAM KING, for all times mentioned herein, was and is a
resident of Kansas City, Missouri.
2. Defendant, ANHEUSER-BUSCH COMPANIES, INC., is a corporation with is
principal place of business in Missouri and carries on business in Illinois.
JURISDICTION AND VENUE
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 Missouri 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 the United States
District for the Northern District of Illinois.
COUNT I: NEGLIGENCE
1. Plaintiff Justin King is a resident of Kansas City, Missouri.
2. Defendant Anheuser-Busch is a Missouri-based corporation and does business in
the State of Illinois.
3. On or about April 8, 2004, Plaintiff was driving a 2006 black Harley Davidson
motorcycle, License No. 07 MO 327-HP8, owned by Plaintiff.
4. On or about April 8, 2004, Frank Cuellar, an employee of Defendant, was
operating a 1992 White Nissan beer truck, License No. 07 MO 968-7RL, owned by defendant.
5. Frank Cuellar at all times material herein was employed by Defendant Anheuser-
Busch as a truck driver.
6. On the occasion in question, Plaintiff was driving his motorcycle traveling
southbound on Interstate 57 in Ford County, Paxton, Illinois.
7. On the occasion in question, Frank Cuellar, employee of Defendant, was
operating his employers beer truck, traveling southbound on Interstate 57 in Ford County,
Paxton, Illinois.
8. On the occasion in question, Defendant was traveling behind Plaintiff in the left
hand lane of Interstate 57 when Plaintiff noticed Defendants lights flashing.
9. Plaintiff moved over to the right hand lane to allow Defendant to pass, at which
time he saw beer cases falling from Defendants truck towards him.
10. Plaintiff swerved left in an attempt to avoid the beer cases when the accident
occurred.
11. On or before the date in question, Defendant, Anheuser-Busch, negligently and in
violation of proper safety standards failed to employ competent and careful employees to load,
secure and inspect the cargo, resulting in the freight to disembark from the truck while in transit.
12. It was the duty of the Defendant to ensure safe and proper loading, securing and
inspection of cargo prior to transit.
13. Defendant breached that duty of due care by failing to use proper procedures and
failed to ensure safe conditions for the shipment of their freight.
14. As a direct and proximate cause of the negligent acts of Defendant Anheuser-
Busch or its employees as set forth above, Plaintiff has suffered serious and permanent injuries to
his face and jaw.
15. The left side of his face is permanently higher than the right side.
16. Plaintiff has also incurred the loss of a recording contract, incurred medical bills
and suffered pain in an amount to be determined at trial.
17. As a direct and proximate cause of the negligent acts of Defendant Anheuser-
Busch or its employees as set forth above, Plaintiff has incurred the following expenses for
medical care and attention:
a. Physicians' fees: amount to be determined at trial;
b. Medical supplies, appliances, and medicine: amount to be determined at trial;
c. Hospitalization: amount to be determined at trial;
d. Physical therapy: amount to be determined at trial;
e. Nursing services: amount to be determined at trial;
All of the above charges are reasonable and customary in the City of Paxton, Ford
County.
18. As a further result of the injuries sustained by Plaintiff, there is a reasonable
probability that Plaintiff will require further medical care and attention and will incur future
reasonable and necessary expenses for medical care and attention.
19. Plaintiffs doctors estimated over $100,000 in future medical bills, plastic surgery,
and counseling to be incurred by Plaintiff.
DEMAND FOR JURY TRIAL
Plaintiff demands a trial by jury.
PRAYER FOR RELIEF
WHEREFORE, plaintiff requests judgment against defendant as follows:
A. General damages in an amount to be determined at trial.
B. Interest on such damages awarded as allowed by law;
C. Costs of suit; and
D. Such other and further relief as the Court may deem just and proper.

DATED: April 9, 2013
LAW OFFICES OF EDWARD P. CABALL, P. L.


______________________________________
EDWARD P. CABALL/Illinois Bar # 12345
1234 Sesame Street
Any Town, USA 1234
Tel: (813) 555-8660
Fax: (813) 555-0559
E-Mail: Edward.Caballe@CaballeLaw.com
Attorney for Plaintiff