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: ________
On or about [date of injury], plaintiff [description of plaintiff's activity].
On the occasion in question, defendant, [name of defendant], [description of defendant's negligent activity].
[Description of nature of accident.]
Defendant had a duty to [describe the existence of a duty]
Defendant breached the duty of due care by [describe negligent conduct as a breach of duty of care]
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:
[Description of damages]
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 $[dollar amount of general damages or an amount to be determined at trial];
2.