Lawsuit Filed in Fatal I-55 Crash

***EFILED***
Case Number 2018L 000054

Transaction ID: 61581806
Date: Jan 18 2018 09:37AM
Mark Von Nida
Clerk of Circuit Court
IN THE CIRCUIT COURT Third Judicial Circuit, Madison County Illinois
THIRD JUDICIAL CIRCUIT
MADISON COUNTY, ILLINOIS LEMUEL KEVIN CARROLL,
)
as Special Administrator of the Estate of
)
TORI RENEE CARROLL, Deceased,
)
)
P
l
a
i
n
t
i
f
f
,
)
vs.
)
)
MOHAMED YUSSUF JAMA,
)
Case No. 18-L-
FORWARD AIR CORPORATION,
)
FORWARD AIR, INC.,
)
FAF, INC.,
)
FORWARD AIR SOLUTIONS, INC.,
)
CENTRAL STATES TRUCKING CO.,
)
TQI, INC.,
)
FORWARD AIR ROYALTY, LLC,
)
F
O
R
W
Page 1 of 19
No. 18-L-
ARD Air Solutions, Inc., Central
AIR
TECH States Trucking Co., TQI,
NOLO
GY Inc., Forward Air Royalty,
AND
LLC, Forward Air
) Technology and Logistical

LOGIS
TICAL Services, Inc., and Keller
SERVI
CES, Construction, Inc., states as
INC.,
and follows:
)
KELL
ER
CONS
TRUC
TION,
INC.,
)
)
Defenda
nts.
COMPLAINT
COMES NOW Plaintiff, Lemuel Kevin
Carroll, as Special Administrator of the Estate of
Tori Renee Carroll, Deceased, by and through his
attorneys, Kenneth L. Halvachs and Ronald J.
Abernathy, Jr., and the law firm of Halvachs &
Abernathy, LLC, and for his causes of actions
against Mohamed Yussuf Jama, Forward Air
Corporation, Forward Air, Inc., FAF, Inc., Forward
Page 2 of 19
No. 18-L-
ALLEGATIONS COMMON TO ALL COUNTS
1. Plaintiff, Lemuel Kevin Carroll, is the duly appointed Special Administrator of
the Estate of Tori Renee Carroll, deceased, and is a resident of Alhambra, Madison County,
Illinois.
2. Upon information and belief, Defendant Mohamed Yussuf Jama resides at 917 12th
Street, Apartment 103, Greeley, Colorado 80631.
3. Defendant Forward Air Corporation is a Tennessee corporation with its principal
place of business located at 1915 Snapps Ferry Road, Building N, Greeneville, Tennessee 37745-
3661. Its registered agent for service of process is Cogency Global, Inc., 992 Davidson Road,
Suite B, Nashville, Tennessee 37205.
4. Defendant Forward Air, Inc. is a Tennessee corporation licensed to conduct
business in the State of Illinois and conducting business in the state of Illinois. Its registered
agent for service of process is Cogency Global, Inc., 600 South 2nd Street, Suite 404, Springfield,
Illinois 62704.
5. Defendant FAF, Inc. is a Tennessee corporation licensed to conduct business and
conducting business in the State of Illinois. Its registered agent for service of process is Greg
Wolfe, 250 Wille Road, Des Plaines, Illinois 60018.
6. Defendant Forward Air Solutions, Inc. is a Tennessee corporation with its
principal place of business located at 1915 Snapps Ferry Road, Building N, Greeneville,
Tennessee 37745- 3661. Its registered agent for service of process is Cogency Global, Inc., 992
Davidson Road, Suite B, Nashville, Tennessee 37205.
7. Defendant Central States Trucking Co. is a Delaware corporation licensed to do
business in the state of Illinois and conducting business in the state of Illinois with its principal
place of business located at 1250 Millsdale Road, Joliet, Illinois. Its registered agent for service
of process is Cogency Global, Inc., 600 South Second Street, Springfield, Illinois 62704.
8. Defendant TQI, Inc. is a Michigan corporation with its principle place of business
located at 550 3 Mile Rd. NW, Suite D, Grand Rapids, Michigan 49544. Its registered agent for
service of process is Cogency Global, Inc., 229 Brookwood Drive, Suite 14, Grand Rapids,
Michigan 49544.
9. Defendant Forward Air Royalty, LLC is a Delaware corporation with its principle
place of business located at 1915 Snapps Ferry Road, Building N Greeneville, Tennessee 37745-
3661. Its registered agent for service of process is Cogency Global, Inc., 992 Davidson Road,
Suite B, Nashville, Tennessee 37205.
10. Defendant Forward Air Technology and Logistical Services, Inc. is a Tennessee
corporation with its principle place of business located at 1915 Snapps Ferry Road, Building N
Greeneville, Tennessee 37745-3661. Its registered agent for service of process is Cogency
Global, Inc., 992 Davidson Road, Suite B, Nashville, Tennessee 37205.
11. Defendant Keller Construction, Inc. is an Illinois corporation licensed to conduct
business and conducting business in the state of Illinois with its principle place of business at 22
Illini Drive, Glen Carbon, Illinois 62034. Its registered agent for service of process is Adam
Keller, 22 Illini Drive, Glen Carbon, Illinois 62034.
12. Venue is proper in Madison County, Illinois.
13. Upon information and belief, Defendant Mohamed Yusuf Jama is an employee of
one or more of the following Defendants: Forward Air Corporation, Forward Air, Inc. FAF, Inc.
Forward Air Solutions, Inc. Central States Trucking Co., TQI, Inc., Forward Air Royalty, LLC
and/or Forward Air Technologies and Logistical Services, Inc., and was acting at the direction
and
control of one or more of these defendants within the course and scope of his employment at the
time of the collision.
14. Defendant Keller Construction, Inc. is the general contractor performing repairs
and construction of an asphalt crossover on United States Interstate Highway 55 and installed the
construction zone traffic control devices preceding and within the construction zone.
15. On November 21, 2017, Plaintiff’s decedent was a front seat passenger in a 2010
Kia Forte, when this vehicle slowed as a result of lane restrictions in a construction zone in the
southbound lanes of interstate highway 55 near Hamel, Madison County, Illinois.
16. On November 21, 2017, Defendant Mohamed Yusuf Jama was the driver of a
2016 Freightliner Cascadia tractor trailer owned and operated by or for the benefit of one or
more of the following defendants: Forward Air Corporation, Forward Air, Inc., FAF, Inc.
Forward Air Solutions, Inc., Central States Trucking Co., TQI, Inc., Forward Air Royalty, LLC,
and/or Forward Air Technologies and Logistical Services, Inc.
17. Defendant Jama crashed his 2016 Freightliner Cascadia into the 2010 Kia Forte in
which plaintiff’s decedent was a passenger and drove his truck and trailer over the top of the Kia,
severely injuring plaintiff’s decedent, and ultimately causing her death on November 30, 2017.
COUNT I
(Wrongful Death as to Defendant Mohamed Yusuf Jama)
COMES NOW the Plaintiff, Lemuel Kevin Carroll, as Special Administrator of the Estate
of Tori Renee Carroll, by and through his undersigned attorneys, and for his cause of action
against the Defendant Mohamed Yusuf Jama (hereinafter “Defendant Jama”), states:
1-17. Plaintiff re-alleges and incorporates Paragraphs 1-17 of Facts Common to All
Counts above as and for his allegations as Paragraphs 1-17 of Count I.

18. Plaintiff brings this action pursuant to the Illinois Wrongful Death Act, 740 ILCS
180/1 et seq., for the benefit of the next of kin of Tori Renee Carroll.
19. At all times herein relevant, Defendant Jama was the driver of a 2016 Freightliner
Cascadia tractor trailer traveling on southbound U.S. Interstate 55 near Hamel, Madison County,
Illinois and was acting within the course and scope of his employment.
20. Defendant Jama had at all times, while operating his tractor trailer on the
interstate highway, a duty to operate said tractor trailer in a safe and reasonable manner and
exercise a reasonable duty of care to others on the interstate, such as plaintiff’s decedent.
21. Notwithstanding the aforementioned duty, Defendant Jama, breached his duty to
plaintiff’s decedent in one or more of the following ways:
a. Negligently and carelessly failed to operate his vehicle in a safe and proper
manner;
b. Negligently and carelessly failed to keep a proper lookout;
c. Negligently and carelessly proceeded at a speed which was greater than
reasonable and proper with regard to traffic conditions at the time, or which
endangered the safety of persons or property in violation of Section 11-601 of
the Illinois Vehicle Code, 625 ILCS 5/11-601;
d. Negligently and carelessly failed to decrease his speed, stop or swerve so as to
avoid colliding with the vehicle in which Plaintiff’s decedent was a passenger
in violation of Section 11-601 of the Illinois Vehicle Code, 625 ILCS 5/11-
601;
e. Negligently and carelessly failed to decrease his speed when approaching a
highway construction zone in violation of Section 11-605.1 of the Illinois

Vehicle Code, 625 ILCS 5/11-605.1;
22. As a direct and proximate result of one or more of the foregoing acts and/or
omissions of Defendant Jama, the heirs of Tori Renee Carroll have been caused pecuniary loss.
WHEREFORE, Plaintiff, Lemuel Kevin Carroll, Special Administrator of the Estate of
Tori Renee Carroll, Deceased, prays judgment be jointly and severally entered against Defendant
Mohamed Yusuf Jama for a sum in excess of FIFTY THOUSAND ($50,000.00) DOLLARS,
plus the costs of this suit and any other such relief the Court finds just and proper.
COUNT II
(Respondeat Superior Wrongful Death as to Defendants Forward Air
Corporation, Forward Air, Inc., FAF, Inc., Forward Air Solutions, Inc.,
Central States Trucking Co., TQI, Inc., Forward Air Royalty, LLC,
Forward Air Technology and Logistical Solutions, Inc.)
COMES NOW Plaintiff, Lemuel Kevin Carroll, as Special Administrator of the Estate of
Tori Renee Carroll, by and through his undersigned attorneys, and for his cause of action against
Defendants Forward Air Corporation, Forward Air, Inc., FAF, Inc., Forward Air Solutions, Inc.,
Central States Trucking Co., TQI, Inc., Forward Air Royalty, LLC, Forward Air Technology and
Logistical Solutions, Inc. (hereinafter “Defendants”), states as follows:
Counts above as and for his allegations as Paragraphs 1-17 of Count II.
180/1 et seq.
19. Defendant Jama is an employee of one or more of the following Defendants:
Forward Air Corporation, Forward Air, Inc., FAF, Inc., Forward Air Solutions, Inc., Central
States Trucking Co., TQI, Inc., Forward Air Royalty, LLC, Forward Air Technology and
Logistical Solutions, Inc. and was acting within the course and scope of his employment at the
time of the
accident.
20. At all times herein relevant, Defendant Jama was operating a 2016 Freightliner
Cascadia tractor trailer traveling on southbound United States Interstate Highway 55 at or near
Mile Marker 27 at the direction and control of his employer(s) and within the course and scope
of his employment.
21. While operating said tractor trailer at the direction and control of his employer(s),
Defendant Jama collided with a vehicle in which Plaintiff’s decedent was a passenger, causing
her great pain and suffering, severe injury, and her ultimate death on November 30, 2017.
22. At all times herein relevant, Defendants, by and through their agents and
employee Mohamed Yusuf Jama had at all times, had a duty to operate said tractor trailer in a
safe and reasonable manner and exercise a reasonable duty of care to others on the interstate,
such as plaintiff’s decedent. Notwithstanding the aforementioned duty, Defendants breached that
duty by and through the acts of their agent and employee Defendant Jama, decedent in one or
more of the following ways:
a. Negligently and carelessly failed to operate the vehicle in a safe and proper
manner;
d. Negligently and carelessly failed to decrease the vehicle speed, stop or swerve
so as to avoid colliding with the vehicle in which Plaintiff’s decedent was a

passenger in violation of Section 11-601 of the Illinois Vehicle Code, 625
ILCS 5/11-601;
e. Negligently and carelessly failed to decrease the vehicle speed when
approaching a highway construction zone in violation of Section 11-605.1 of
the Illinois Vehicle Code, 625 ILCS 5/11-605.1;
23. Defendants are vicariously liable for the acts and omissions of their employee,
Defendant Jama, while acting within the course and scope of his employment.
24. As a direct and proximate result of one or more of these the foregoing negligent
acts and/or omissions of Defendants, the heirs of Tori Renee Carroll have been caused to suffer
pecuniary loss.
Tori Renee Carroll, Deceased, prays judgment be jointly and severally entered against
Logistical Solutions, Inc. for a sum in excess of FIFTY THOUSAND ($50,000.00) DOLLARS
COUNT III
(Wrongful Death as to Defendant Keller Construction, Inc.)
Defendant Keller Construction, Inc. (hereinafter “Defendant Keller”), states as follows:
Counts above as and for his allegations as Paragraphs 1-17 of Count III.
18. Plaintiff Lemuel Kevin Carroll is the duly appointed Special Administrator of the
Estate of Tori Renee Carroll, deceased.
180/1 et seq.
20. At all times herein relevant, Defendant Keller was the general contractor
performing construction work, repairs, and/or maintenance of and within a construction zone
near Mile Marker 27 on United States Interstate Highway 55 wherein a collision between
Defendant Jama and the vehicle in which Plaintiff’s decedent was a passenger.
21. At all times herein relevant, Defendant Keller owed a duty to the public, including
Tori Renee Carroll, deceased, to design and maintain a highway construction work zone in a
manner that provided for the safe travel of the general public.
22. At all times herein relevant, Defendant Keller owed a duty to the traveling public
to provide warnings of work zone traffic speeds, lane closures, and slowed and/or stopped traffic
resulting from the construction work being performed by itself and lane closures instituted in the
performance of said construction and maintenance.
23. That all times herein relevant, Defendant Keller knew or should have known that
as a result of the work being performed by itself and/or its subcontractors, that traffic would
severely slow or stop within and preceding the construction work zone creating a dangerous
condition to the traveling public such as plaintiff’s decedent.
24. Notwithstanding the foregoing knowledge and duties, Defendant Keller breached
these duties in one or more of the following ways:

a. Negligently failed to properly design a highway construction work zone to
ensure the safe and proper control of traffic within the work zone and
preceding the work zone;
b. Negligently failed to install proper electronic traffic monitoring and warning
devices, failed to erect traffic control devices in a manner that would prevent
traffic from slowing or stopping on a United States Interstate highway;
c. Negligently failed to install proper electronic traffic monitoring and warning
devices to alert the traveling public of severely slowed or stopped traffic
within or preceding the construction work zone;
d. Negligently failed to warn the traveling public of stopped and/or severely
slowed traffic within and preceding the construction work zone;
e. Negligently failed to re-open the closed lanes of the interstate highway during
times when work was not being performed;
f. Negligently failed to re-open the closed lanes of the interstate highway
preceding the Thanksgiving holiday when it knew or should have known of
the likelihood of increased traffic due to holiday travel;
acts and/or omissions of Defendant Keller, the heirs of Tori Renee Carroll have been caused to
suffer pecuniary loss.
Keller Construction, Inc. for a sum in excess of FIFTY THOUSAND ($50,000.00) DOLLARS
COUNT IV
(Negligence as to Defendant Mohamed Yusuf Jama
Pursuant to the Survival Act, 755 ILCS 5/27-6)
Defendant Mohamed Yusuf Jama (hereinafter “Defendant Jama”), states as follows:
Counts above as and for his allegations as Paragraphs 1-17 of Count IV.
18. Plaintiff brings this Count pursuant to the Illinois Survival Act, 755 ILCS 5/27-6.
19. At all-time relevant herein, Defendant Jama was the driver of a 2016 Freightliner
Cascadia tractor trailer traveling southbound on United States Interstate Highway 55 near Hamel,
Madison County, Illinois.
20. Defendant Jama had at all times, while operating his tractor trailer on the
interstate highway, a duty to operate said tractor trailer in a safe and reasonable manner and
exercise a reasonable duty of care to others on the interstate, such as plaintiff’s decedent.
21. Notwithstanding the aforementioned duty, Defendant Jama, breached his duty to
plaintiff’s decedent in one or more of the following ways:
a. Negligently and carelessly failed to operate his vehicle in a safe and proper
manner;

d. Negligently and carelessly failed to decrease his speed, stop or swerve so as to
avoid colliding with the vehicle in which Plaintiff’s decedent was a passenger
in violation of Section 11-601 of the Illinois Vehicle Code, 625 ILCS 5/11-
601;
e. Negligently and carelessly failed to decrease his speed when approaching a
highway construction zone in violation of Section 11-605.1 of the Illinois
Vehicle Code, 625 ILCS 5/11-605.1;
22. As a direct and proximate result of one or more of the foregoing acts and/or
omissions of Defendant Jama, the Estate of Tori Renee Carroll became liable for large sums
money for medical bills and funeral expenses.
23. As a direct and proximate result of the one or more of the foregoing acts and/or
omissions of Defendant Jama, Tori Renee Carroll suffered pain and suffering from the time of
the collision until her death.
Mohamed Yusuf Jama for a sum in excess of FIFTY THOUSAND ($50,000.00) DOLLARS
which will fairly and reasonably compensate Plaintiff for Plaintiffs decedent's injuries, plus the
costs of this suit and any other such relief the Court finds just and proper.
COUNT V
(Respondeat Superior Negligence as to Defendants Forward Air Corporation, Forward
Air, Inc., FAF, Inc., Forward Air Solutions, Inc., Central States Trucking Co., TQI, Inc.,
Forward Air Royalty, LLC, Forward Air Technology and Logistical Solutions, Inc.
Pursuant to the Illinois Survival Act 755 ILCS 5/27-6)
Logistical Solutions, Inc. (hereinafter “Defendants”), states as follows:
Counts above as and for his allegations as Paragraphs 1-17 of Count V.
18. Plaintiff brings this action pursuant to the Illinois Survival Act, 755 ILCS 5/27-6.
19. Defendant Jama is an employee of one or more of the following Defendants:
Forward Air Corporation, Forward Air, Inc., FAF, Inc., Forward Air Solutions, Inc., Central
States Trucking Co., TQI, Inc., Forward Air Royalty, LLC, Forward Air Technology and
Logistical Solutions, Inc.
20. At all times herein relevant, Defendant Jama was operating a 2016 Freightliner
Cascadia tractor trailer on southbound interstate highway 55 at or near Mile Marker 27 at the
direction and control of his employer(s) and within the course and scope of his employment.
21. While operating said tractor trailer at the direction and control of his employer(s),
Defendant Jama collided with a vehicle in which Plaintiff’s decedent was a passenger, causing
her great pain and suffering, severe injury, and her ultimate death on November 30, 2017.
22. At all times herein relevant, Defendants, by and through its agent and employee
Defendant Jama, had a duty to operate said tractor trailer in a safe and reasonable manner and
exercise a reasonable duty of care to others on the interstate, such as Plaintiff’s decedent.
23. Notwithstanding the aforementioned duty, Defendants breached their duty to
Plaintiff’s decedent by and through its agent and employee in one or more of the following ways:
a. Negligently and carelessly failed to operate the vehicle in a safe and proper
manner;

d. Negligently and carelessly failed to decrease the vehicle speed, to stop or
swerve so as to avoid colliding with the vehicle in which Plaintiff’s decedent
was a passenger in violation of Section 11-601 of the Illinois Vehicle Code,
625 ILCS 5/11-601;
e. Negligently and carelessly failed to decrease the vehicle speed when
approaching a highway construction zone in violation of Section 11-605.1 of
the Illinois Vehicle Code, 625 ILCS 5/11-605.1;
24. Defendants are vicariously liable for the acts and omissions of their employee,
Defendant Jama, acting within the course and scope of his employment.
acts and/or omissions of Defendants, by and through its employee, Defendant Jama, the Estate of
Tori Renee Carroll became liable for large sums money for medical bills and funeral expenses.
omissions of Defendants, Tori Renee Carroll suffered pain and suffering from the time of the
collision until her death.
Central States
Trucking Co., TQI, Inc., Forward Air Royalty, LLC, Forward Air Technology and Logistical
Solutions, Inc. for a sum in excess of FIFTY THOUSAND ($50,000.00) DOLLARS plus the
costs of this suit and any other such relief the Court finds just and proper.
COUNT VI
(Negligence as to Defendant Keller Construction, Inc.
Pursuant to the Illinois Survival Act 755 ILCS 5/27-6)
Tori Renee Carroll, by and through his undersigned attorneys, and for his cause of action
Defendant Keller Construction, Inc. (hereinafter “Defendant Keller”), states as follows:
Counts above as and for his allegations as Paragraphs 1-17 of Count VI.
18. Plaintiff is the duly appointed Special Administer of the Estate of Tori Renee
Carroll pursuant to 735 ILCS 5/13-209.
19. Plaintiff brings this action pursuant to the Illinois Survival Act 755 ILCS 5/27-6.
20. At all times herein relevant, Defendant Keller was the general contractor
performing construction work, repairs, and/or maintenance of and within a construction zone
near Mile Marker 27 on United States Interstate Highway 55 wherein a collision between
Defendant Jama and the vehicle in which Plaintiff’s decedent was a passenger.
21. At all times herein relevant, Defendant Keller owed a duty to the public, including
Tori Renee Carroll, deceased, to design and maintain a highway construction work zone in a
manner that provided for the safe travel of the general public.
22. At all times herein relevant, Defendant Keller owed a duty to the traveling public
to provide warnings of work zone traffic speeds, lane closures and slowed and/or stopped traffic
resulting from the construction work being performed by itself and lane closures instituted in the
performance of said construction and maintenance.

23. At all times herein relevant, Defendant Keller knew or should have known that as
a result of the work being performed by itself and/or its subcontractors, that traffic would
severely slow or stop within and preceding the construction work zone creating a dangerous
condition to the traveling public such as plaintiff’s decedent.
24. Notwithstanding the foregoing knowledge and duties Defendant Keller
Construction, Inc. breached these duties in one or more of the following ways:
a. Negligently failed to properly design a highway construction work zone to
ensure the safe and proper control of traffic within the work zone and
preceding the work zone;
b. Negligently failed to install proper electronic traffic monitoring and warning
devices, failed to erect traffic control devices in a manner that would prevent
traffic from slowing or stopping on a United States Interstate highway;
c. Negligently failed to install proper electronic traffic monitoring and warning
devices to alert the traveling public of severely slowed or stopped traffic
within or preceding the construction work zone;
d. Negligently failed to warn the traveling public of stopped and/or severely
slowed traffic within and preceding the construction work zone;
e. Negligently failed to re-open the closed lanes of the interstate highway during
times when work was not being performed;
f. Negligently failed to re-open the closed lanes of the interstate highway
preceding the Thanksgiving holiday when it knew or should have known of
the likelihood of increased traffic due to holiday travel.

acts and/or omissions of Defendant Keller, the Estate of Tori Renee Carroll has been caused to
suffer large sums of money for medical, hospital and funeral expense.
omissions of Defendant Keller, Tori Renee Carroll suffered pain and suffering from the time of
the collision until her death.
Keller Construction, Inc. for a sum in excess of FIFTY THOUSAND ($50,000.00) DOLLARS,
COUNT VII
(Wrongful Death Wilful and Wanton as to Defendants Forward Air
Corporation, Forward Air, Inc., FAF, Inc., Forward Air Solutions, Inc.,
Central States Trucking Co., TQI, Inc., Forward Air Royalty, LLC, Forward
Air Technology and Logistical Solutions, Inc.)
COMES NOW Plaintiff, Lemuel Kevin Carroll, by and through his undersigned
attorneys, and for his cause of action Defendants Forward Air Corporation, Forward Air, Inc.,
FAF, Inc., Forward Air Solutions, Inc., Central States Trucking Co., TQI, Inc., Forward Air
Royalty, LLC, Forward Air Technology and Logistical Solutions, Inc. (hereinafter
“Defendants”), states as follows:
Counts above as and for his allegations as Paragraphs 1-17 of Count VII.
18. Plaintiff brings this Count pursuant to Illinois Wrongful Death Act, 740 ILCS
180/1, et seq.
19. Defendants are guilty of one or more of the following acts or omissions
amounting to wilful and wanton misconduct:
a. Intentionally or with reckless disregard for the safety of Plaintiff’s decedent,
entrusted its employee, Defendant Jama, with a company owned 2016
Freightliner Cascadia tractor trailer to operate when it was completely
foreseeable and could or should have been anticipated that persons such as
Plaintiff’s decedent, was in danger of being struck by Defendants'
employee/co- defendant with said truck;
b. Intentionally or with reckless disregard for the safety of Plaintiff’s decedent
failed to properly train Defendant Jama on the safe operation of a tractor
trailer when in or approaching a construction zone on an interstate highway;
c. Intentionally or with reckless disregard for the safety of Plaintiff’s decedent
failed to install dash cameras or other devices to deter its drivers, such as
Defendant Jama from using their cellular phones or other electronic devices
while operating its equipment;
20. As a direct and proximate result of the foregoing acts and omissions of
Defendants, Plaintiff’s decedent suffered great bodily injury and death causing decedent’s heirs
to suffer immense grief and pain, pecuniary loss and loss of consortium.
Central States Trucking Co., TQI, Inc., Forward Air Royalty, LLC, Forward Air Technology
and Logistical
Solutions, Inc. for a sum in excess of FIFTY THOUSAND ($50,000.00) DOLLARS which will
fairly and reasonably compensate Plaintiff for Plaintiffs decedent's death, plus the costs of this suit
and any other such relief the Court finds just and proper.
Date: January 17, 2018 Respectfully submitted,
HALVACHS & ABERNATHY, LLC
BY: /s/Ronald J. Abernathy, Jr.

Kenneth L. Halvachs, #06188276
Ronald J. Abernathy, Jr., #6295730
5111 West Main Street
Belleville, IL 62226
(618)235-0020/ Fax: (618)236-2728
khalvachs@abernathyfirm.com
rjabernathy@abernathyfirm.com
Attorneys for Plaintiff

Lawsuit Filed in Fatal I-55 Crash

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***EFILED***

Case Number 2018L 000054

) Technology and Logistical

COMES NOW Plaintiff, Lemuel Kevin

Carroll, as Special Administrator of the Estate of

Tori Renee Carroll, Deceased, by and through his

attorneys, Kenneth L. Halvachs and Ronald J.

Abernathy, Jr., and the law firm of Halvachs &

Abernathy, LLC, and for his causes of actions

against Mohamed Yussuf Jama, Forward Air

Corporation, Forward Air, Inc., FAF, Inc., Forward

1. Plaintiff, Lemuel Kevin Carroll, is the duly appointed Special Administrator of

Street, Apartment 103, Greeley, Colorado 80631.

3. Defendant Forward Air Corporation is a Tennessee corporation with its principal

Suite B, Nashville, Tennessee 37205.

4. Defendant Forward Air, Inc. is a Tennessee corporation licensed to conduct

5. Defendant FAF, Inc. is a Tennessee corporation licensed to conduct business and

Wolfe, 250 Wille Road, Des Plaines, Illinois 60018.

6. Defendant Forward Air Solutions, Inc. is a Tennessee corporation with its

Davidson Road, Suite B, Nashville, Tennessee 37205.

7. Defendant Central States Trucking Co. is a Delaware corporation licensed to do

Suite B, Nashville, Tennessee 37205.

Global, Inc., 992 Davidson Road, Suite B, Nashville, Tennessee 37205.

11. Defendant Keller Construction, Inc. is an Illinois corporation licensed to conduct

Keller, 22 Illini Drive, Glen Carbon, Illinois 62034.

12. Venue is proper in Madison County, Illinois.

time of the collision.

southbound lanes of interstate highway 55 near Hamel, Madison County, Illinois.

and/or Forward Air Technologies and Logistical Services, Inc.

Counts above as and for his allegations as Paragraphs 1-17 of Count I.

plaintiff’s decedent in one or more of the following ways:

b. Negligently and carelessly failed to keep a proper lookout;

c. Negligently and carelessly proceeded at a speed which was greater than

endangered the safety of persons or property in violation of Section 11-601 of

the Illinois Vehicle Code, 625 ILCS 5/11-601;

d. Negligently and carelessly failed to decrease his speed, stop or swerve so as to

e. Negligently and carelessly failed to decrease his speed when approaching a

highway construction zone in violation of Section 11-605.1 of the Illinois

WHEREFORE, Plaintiff, Lemuel Kevin Carroll, Special Administrator of the Estate of

Logistical Solutions, Inc. (hereinafter “Defendants”), states as follows:

19. Defendant Jama is an employee of one or more of the following Defendants:

more of the following ways:

b. Negligently and carelessly failed to keep a proper lookout;

c. Negligently and carelessly proceeded at a speed which was greater than

endangered the safety of persons or property in violation of Section 11-601 of

the Illinois Vehicle Code, 625 ILCS 5/11-601;

so as to avoid colliding with the vehicle in which Plaintiff’s decedent was a

e. Negligently and carelessly failed to decrease the vehicle speed when

approaching a highway construction zone in violation of Section 11-605.1 of

the Illinois Vehicle Code, 625 ILCS 5/11-605.1;

WHEREFORE, Plaintiff, Lemuel Kevin Carroll, Special Administrator of the Estate of

Defendant Keller Construction, Inc. (hereinafter “Defendant Keller”), states as follows:

Estate of Tori Renee Carroll, deceased.

performance of said construction and maintenance.

condition to the traveling public such as plaintiff’s decedent.

these duties in one or more of the following ways:

preceding the work zone;

b. Negligently failed to install proper electronic traffic monitoring and warning

traffic from slowing or stopping on a United States Interstate highway;

c. Negligently failed to install proper electronic traffic monitoring and warning

devices to alert the traveling public of severely slowed or stopped traffic

within or preceding the construction work zone;

d. Negligently failed to warn the traveling public of stopped and/or severely

EFILED