AttomeyNo. IN TI{E CIRCUIT COI.JRT OF COOK COIJNTY.

ILLINOIS
COTJNTY DEPARTMENT - LAW DIVISTON

12345

JT'LIET

CAPULET Plaintiff ')

) )

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:

ofthe Defendant, ETHEL MONTAGUE, respectfrrlly

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.

her vehicle at tlte intcrsction of Ashland Avenue and Montrose

3. Thc Plaintiffstopped

Avsnue when the stoplight st the intersction turned red.

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.

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. on a cell phone while driving her automobile

c. Talking d. 7.

Failing to pay attention to the traffic laws.

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 states as follows:

MONTAGUE, respectfulty

1. Plaintiffrealleges Paragraphs I through 4 ofCount I

ofCount II.

as and

for Paragraphs I th'rough 4

5 That the automobile

ROMEO MONTAGI.IE.

driven by ETHEL MONTAGLIE was owned by her brother,

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.
have known that

8. That the Defendant knew or should

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, states as follows:
I

EHTEL MONTAGUE, respecttully

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

MONTAGUE.

caused by the Defendant,

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

Plaintiffin the face.

slap was a harmful and offensive touching to the Plaintiff.

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

red with a palm irnprint on her chesk.

WHEREFORE, the Plaintiffprays that

amount of $10,000.00.

Judgment be enrcred against the Defendant in

t}e

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 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
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AttorneyNo.

VERMCATIOI.I

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