AttomeyNo. 12345

IN TI{E CIRCUIT COI.JRT OF COOK COIJNTY. ILLINOISCOTJNTY DEPARTMENT - LAW DIVISTON

JT'LIET CAPULET )Plaintiff )

). vs. ')

)ETHELMoNTAGUE ) No.

and l)

ROMEOMONTAGUE )Defendants )

COMPLAINT

COUNT I.NEGLIGENCE

NOW COMES the Plaintiff, IULIET CAPULET, by and throtrgh her attorneys,

Shakcspcare ard Bacon, and complaining ofthe Defendant, ETHEL MONTAGUE, respectfrrlly

statcs as follows:

l. That on April 1,2006 at approximately 10:30 a.m., Plaintiffuns driving northbound on

Ashland Avenug Chicago, IL.

2. ThatonApril 1,2@6atapproximately10:30a.m.,DefendEntwasdrivingnorthbound

on Aslrland Avenug Chicago, IL directy behind the Plaintiffs automobile.

3. Thc Plaintiffstopped her vehicle at tlte intcrs€ction of Ashland Avenue and Montrose

Avsnue when the stoplight st the inters€ction turned red.

4. That De,fendant failed to stop her automobile at the red light and hit Plaintiffs

urtomobile. Plaintiffcould see prior to being hit, that the Defendant was talking on her cell

phone.

t

6. That the Defendant breached that duty of care by

a. Failing to stop at the red light and hitting Plaintiffs automobile.

b. Failing to use reasonable care while driving her automobile.

c. Talking on a cell phone while driving her automobile

d. Failing to pay attention to the traffic laws.

7. The Plaintiffsuffered personal injuries in the form of whiplaslq cuts, scratches and

bruises. She needed chiropractic treatment for a period of time after the accident.

8. The Plaintiffsuffered property damage in the her automobile was damaged in that it is

completely inoperable. The automobile will need to be replaced.

9. The Defendant's negligence with the proximate cause of Plaintiffs injuries.

WHEREFORE, the Plaintiffprays that a Judgment be enterd against the Defendant in

excess of$30,000.00.

COUNT II - NEGLIGENCE

NOW COMES the Plaintifi, JULIET CAPLILET, by and through her attorneys,

Shakespeare and Bacon, and complaining of the Defendant, ROMEO MONTAGUE, respectfulty

states as follows:

1. Plaintiffrealleges Paragraphs I through 4 ofCount I as and for Paragraphs I th'rough 4

ofCount II.

5 That the automobile driven by ETHEL MONTAGLIE was owned by her brother,

ROMEO MONTAGI.IE.

6. The Defendant, ROMEO MONTAGUE, owed a duty of care to insure his automobile

was driven by responsible drivers.

7. The Defendanf breached that duty in that he negligently entrusted his S(JV to his sister.

("

7. The Defendant breached that duty in that he negligently entrusted his SUV to his sister.

8. That the Defendant knew or should have known that ETHEL had been stopped on two

different occasions by the police for driving negligently while talking on the cell phone.

9. That Plaintiffsuffered personal injuries in the form of whiplash, cuts, scratches and

bruises. She needed chiropractic treatment for a period of time after the accident.

10. The Plaintiffsuffered property damage in that her automobile was totally damaged

and will need to be replaced.

I l. The Defendant's negligence was the proximate cause of Plaintiffs injuries.

WHEREFORE, the Plaintiffprays that a Judgment be entered against the Defendant in an

amount in excess of$30,000.00.

COUNT III - BATTERY

NOW COMES the Plaintifl JULIET CAPULET, by and through her attorneys'

Shakespear and Bacon, and complaining of the Defendant, EHTEL MONTAGUE, respecttully

states as follows:

I . That on April l, 2006 at approximately 10:30 a.m. the Plaintiffwas stopped at the

intersection of Ashland Avenue and Montrose Avenue, Chicago, IL.

2. That the Plaintiffexited her car to inspect damage caused by the Defendant, ETIIEL

MONTAGUE.

3 That the Defendent stepped out of her car to inspect the damage to the automobile.

4. That an argument ensued and the Defendant slapped the Plaintiffin the face.

5. That this slap was a harmful and offensive touching to the Plaintiff.

6. That the Defendant intended to harm the Plaintiff.

7. That the Defendant's actions cause physical injury to the Plaintiffin that her face was

red with a palm irnprint on her chesk.

WHEREFORE, the Plaintiffprays that a Judgment be enrcred against the Defendant in t}e

amount of $10,000.00.

JTJLIET CAPI.JLET

One of Plaintiff s Attorneys

CERTIFICATION

Under penalties as provided by law purzuant to Section l-190 of the Illinois Compiled Statutes,

thc undcrsigned certifies that the statements set forth in this instnrment are true and correct,o(cept aE to rnatters thcrein stated to be in information and belief as to qrch mattors theundersigned certifies as aforesaid that he verity believe

JULIETCAPULET

Shakespeare and BaconAttorney for Plaintiff1234 Main StreetChicago, IL 606013 r2-555-1234AttorneyNo. 12345

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VERMCATIOI.I

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Notary Public

My connirrion orpircc:

tmanqy infornrtiqrl

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