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Complaint Essay

460 words - 2 pages

|Unit 3: Assignment |
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|PA110: Civil Litigation I |
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|10/14/2013 |
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|Tajada Anderson ...view middle of the document...

The plaintiff was riding his motorcycle southbound on Highway 57 going a speed of 60-65 miles per hour. The defendant’s driver flashed his lights signaling the need to pass which the plaintiff obliged to. The plaintiff swerved to avoid falling cases of beer but was struck.

On the occasion in question, defendant, Anheuser-Busch Companies, Inc., the defendant failed to secure the cargo on his truck causing them to fall into the plaintiff’s path.

The load that fell off of the defendant's truck caused the plaintiff to swerve and be struck by a beer case.

Defendant had a duty to secure the load to their truck.

Defendant breached the duty of due care by failing to properly secure the load.

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:

The plaintiff’s motorcycle was totaled in the accident. Also his medical expenses are currently $145,000 and will exceed $100,000 for future plastic surgery and counseling.

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 $245,000.00

2. Interest on such damages awarded as allowed by law.

3. Cost of suit; and attorney fees.

4. Such other and further relief as the Court may deem just and proper.

Dated:

Tajada Anderson
IL Attorney License # 12345
Law Office of Taylor Bailey and Associates
123 Main Street
Chicago, IL 60601

Attorney for Plaintiff

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