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3. Plaintiff, Creighton Mims, is an adult individual, residing at all times relevant herein
in Chicago, Illinois.
4. Plaintiff, Valerie Battle-Dugger, is an adult individual, residing at all times relevant
herein in Chicago, Illinois.
5. Plaintiff, Lennell Sorrels, is an adult individual, residing at all times relevant herein
in Chicago, Illinois.
6. Defendant, Megabus USA, LLC, is a Delaware limited liability company with its
principal place of business at 400 South Racine Avenue, Chicago, Illinois, 60609. Megabus USA,
LLC conducts systematic and continuous business activity within the State of Illinois.
7. Defendant, Megabus Southeast, LLC, is a Delaware limited liability company with
its principal place of business at 705 Lively Avenue, Norcross, Georgia, 30091. Megabus
Southeast, LLC conducts systematic and continuous business activity within the State of Illinois.
8. Defendant, Coach Leasing, Inc., is an Illinois corporation with a registered agent
located at 208 South LaSalle Street, Chicago, Illinois, 60604. Coach Leasing, Inc. conducts
systematic and continuous business activity within the State of Illinois.
9. Defendant, Coach USA, Inc., is a Delaware corporation with its principal place of
business at 160 South State Route 17, Paramus, New Jersey 07652. Coach USA, Inc. conducts
systematic and continuous business activity within the State of Illinois.
10. Based on information and belief, Defendants Coach Leasing, Inc., Megabus USA,
LLC, and Megabus Southeast LLC, are subsidiaries of Defendant Coach USA, Inc.
JURISDICTION AND VENUE
11. The Circuit Court of Cook County has subject matter jurisdiction over this matter,
pursuant to Article 6 of the Constitution of the State of Illinois.
12. The Circuit Court of Cook County has personal jurisdiction over the Plaintiffs, as
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they have entered a general appearance in this matter and voluntarily submitted themselves to the
jurisdiction of the Court.
13. The Circuit Court of Cook County has personal jurisdiction over the Defendants,
pursuant to 735 ILCS 5/2-209(a)(1), because Defendants conduct business transactions in the State
of Illinois.
14. Venue is proper, pursuant to 735 ILCS 5/2-101, as this is the county where
Defendant Megabus USA, LLC resides.
FACTUAL ALLEGATIONS
15. On or about October 13, 2014, Defendants owned, managed, maintained, leased
and/or operated a certain passenger bus travelling from Atlanta, Georgia, to Chicago, Illinois (the
Bus).
16. At all times relevant hereto, Defendants were a common carrier for hire, in operation
of passenger busses, including the Bus travelling from Atlanta to Chicago.
17. At all times relevant hereto, there were numerous other authorized agents and/or
employees of Defendants, charged with the responsibility of inspecting, maintaining and assuring
that its passenger buses, including the subject Bus, were in a reasonably safe and road-ready
condition.
18. On or about October 13 and 14, 2014, Plaintiffs were travelling home to Chicago
from Atlanta on Defendants Bus.
19. Plaintiffs were picked up by Defendants Bus in Atlanta as part of a charter service
to Chicago.
20. During the early morning of October 14, 2014, the Defendants, by and through their
employee and/or agent, operated, managed, maintained and controlled the Bus in a northbound
direction on Interstate 65 near Indianapolis, Indiana.
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21. The Defendants Bus had between 50 and 60 passengers at this time. Plaintiffs were
fare-paying passengers on the Bus.
22. It was raining during the ride to Chicago, and the Bus driver announced that there
was a malfunction with the windshield wipers.
23. At approximately 4:30 a.m., the driver of Defendants Bus lost control of the vehicle
causing it to rollover and come to rest on its side.
24. At least 20 to 30 passengers were injured, including all of the Plaintiffs.
25. As a result of the crash, the Plaintiffs suffered severe personal injuries, financial
injuries, and subsequent medical expenses.
COUNT I
(Negligence against all Defendants)

26. Plaintiffs repeat and reallege paragraphs 1 through 25 above with the same force and
effect as though fully set forth herein.
27. At all relevant times complained of herein, Defendants had a duty to exercise
ordinary care in managing and operating their Bus service, a duty avoid placing others in danger,
and a duty to exercise ordinary care at all times to avoid an accident. In this case, Defendants duty
to exercise ordinary care amounts to the highest degree of care because Defendants are common
carriers.
28. In breach of said aforementioned duties, Defendants acted or failed to act in one or
more of the following ways:
a. Failed to exercise reasonable care in selecting a driver to safely and properly
operate Defendants Bus;
b. Failed to implement an adequate program or policy to properly instruct and
train bus drivers to ensure they can safely and properly operate Defendants
Bus;
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c. Failed to create and adopt policies and procedures to avoid rollover accidents,
such as the one involved here;
d. Failed to properly inspect, maintain, and/or repair the Bus in order to ensure
the Defendants Bus could be safely and properly operated;
e. Failed to otherwise exercise reasonable care in transporting passengers along
Defendants Bus route.
29. Said aforementioned actions or failures to act directly and proximately caused
Plaintiffs to suffer (a) physical injuries and the pain and suffering and emotional distress associated
therewith, (b) financial damage, (c) medical bills, and (d) other miscellaneous incidental and
consequential damages.
WHEREFORE, Plaintiffs pray that the Court enter judgment for them and against
Defendants, jointly and severally, in a fair and reasonable sum in excess of fifty thousand dollars
($50,000.00), plus costs, and such other relief as this Court may deem to be just and proper.
COUNT II
(Respondeat Superior against all Defendants)

30. Plaintiffs repeat and reallege paragraphs 1 through 25 above with the same force and
effect as though fully set forth herein.
31. At all relevant times complained of herein, the driver of Defendants Bus had a duty
to exercise ordinary care in driving and operating the Bus, a duty avoid placing others in danger,
and a duty to exercise ordinary care at all times to avoid an accident. In this case, Defendants duty
to exercise ordinary care amounts to the highest degree of care because Defendants are common
carriers.
32. In breach of said aforementioned duties, the driver of Defendants Bus acted or
failed to act in one or more of the following ways:
a. Failed to exercise reasonable care operating the Bus;
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b. Failed to exercise due care in controlling the Bus and to avoid a collision and
rollover of the Bus;
c. Failed to travel at or below a safe speed in light of the conditions;
d. Failed to properly watch for and avoid traffic and/or other obstructions on the
roadway;
e. Failed to otherwise exercise reasonable care in transporting passengers on the
Bus.
33. Based on information and belief, the driver of Defendants Bus was Defendants
employee who was acting within the course and scope of the drivers employment when the driver
acted or failed to act as described above.
34. Defendants are vicariously liable, under the doctrine of respondeat superior, for their
employees acts that are performed within the course and scope of employment.
35. Defendants are vicariously liable to Plaintiffs, under the doctrine of respondeat
superior, for the acts or omissions of their Bus driver, when the driver acted or failed to act as
described above.
36. Said aforementioned actions or failures to act directly and proximately caused
Plaintiffs to suffer (a) physical injuries and the pain and suffering and emotional distress associated
therewith, (b) financial damage, (c) medical bills, and (d) other miscellaneous incidental and
consequential damages.
WHEREFORE, Plaintiffs pray that the Court enter judgment for them and against
Defendants, jointly and severally, in a fair and reasonable sum in excess of fifty thousand dollars
($50,000.00), plus costs, and such other relief as this Court may deem to be just and proper.