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ILLINOIS
COTJNTY DEPARTMENT - LAW DIVISTON
12345
JT'LIET
) )
vs.
)
)
ETHELMoNTAGUE
No.
and
ROMEOMONTAGUE Defendants
l
)
) )
COMPLAINT
COUNT I.NEGLIGENCE NOW COMES the Plaintiff, IULIET CAPULET, by and throtrgh her attorneys,
Shakcspcare ard Bacon, and complaining statcs as follows:
l.
2. ThatonApril 1,2@6atapproximately10:30a.m.,DefendEntwasdrivingnorthbound
on Aslrland Avenug Chicago,
3. Thc Plaintiffstopped
4.
That De,fendant failed to stop her automobile at the red light and hit Plaintiffs
see
urtomobile. Plaintiffcould
phone.
prior to being hit, that the Defendant was talking on her cell
6.
a. Failing to stop
Plaintiffs automobile.
b.
Failing to use reasonable care while driving her automobile. on a cell phone while driving her automobile
c. Talking d. 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
9.
COUNT II - NEGLIGENCE NOW COMES the Plaintifi, JULIET CAPLILET, by and through her attorneys,
Shakespeare and Bacon, and complaining of the Defendant, ROMEO states as follows:
MONTAGUE, respectfulty
as and
6.
The Defendant, ROMEO MONTAGUE, owed a duty of care to insure his automobile
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.
have known that
different occasions by the police for driving negligently while talking on the cell phone.
9. That Plaintiffsuffered
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
l.
COUNT
III - BATTERY
NOW COMES the Plaintifl JULIET CAPULET, by and through her attorneys'
Shakespear and Bacon, and complaining of the Defendant, states as follows:
I
That on April
l,
ETIIEL
That the Defendent stepped out of her car to inspect the damage to the automobile.
ensued and the Defendant slapped the
4. That an argument
5. That this
6. 7.
That the Defendant intended to harm the Plaintiff. That the Defendant's actions cause physical injury to the Plaintiffin that her face was
t}e
JTJLIET CAPI.JLET
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 the undersigned certifies as aforesaid that he verity believe
JULIETCAPULET
Shakespeare and Bacon Attorney for Plaintiff 1234 Main Street
Chicago, IL 60601
3
r2-555-1234
12345
AttorneyNo.
VERMCATIOI.I
bcilg fult duly :urca ttrE -d.r od ti.e *c fr p.rrdd Potitiors, lnowlodepoflhcfrcsrrdrtrleocatraltcgedinfufqglpegtlacdflorfrycdocwlrdere.t
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end
csrcct, [Potitiocr's
nre]
dry of
Notary Public
My connirrion orpircc:
tmanqy infornrtiqrl