Mike and Susan Blunder are suing Patsy Cline for injuries Mike sustained at a party at Cline's home. Mike was on Cline's backyard deck when the railing gave way, causing him to fall four feet and break his leg in two places. He also suffered a permanent limp. The complaint alleges Cline was negligent by failing to repair the railing, warn guests it was broken, block off access to it, reschedule the party, or ensure guest safety. Mike is seeking over $350,000 for medical costs, lost wages, and pain and suffering. Susan also claims loss of consortium and is seeking $20,000. The Blunders demand a jury trial.

1. Megan Shore
9/29/14
1
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
MUNICIPAL DEPARTMENT, FIRST DISTRICT
Mike Blunder and Susan Blunder
Plaintiff
v. No.
Patsy Cline
Defendant
COMPLAINT
Now comes, Mike Blunder and Susan Blunder, by and through their attorney, Houston, Lewis,
and Stone, L.L.C. demand damages from the Defendant, Patsy Cline, and in support thereof,
make the following allegations:
1. The jurisdiction of this court is based on the amount in controversy in the action, which
exceeds $3,000.00
2. The Plaintiffs, Mike Blunder and Susan Blunder, hereafter referred to as “The Plaintiff”,
are residents of the state of Illinois in the county of Cook at 4645 N Hermitage, Chicago,
60640.
3. The Plaintiff, Mike Blunder is a Commodities trader at the Chicago Board of Trade.
4. The Plaintiff, Susan Blunder is an FBI Agent with the Federal Bureau of Investigation.
5. The Defendant, Patsy Cline, hereafter referred to as the “The Defendant”, is a resident of
the state of Illinois in the county of Cook at 3258 N. Central Avenue, Chicago, 60632.
6. The Defendant, Patsy Cline is a Real Estate agent with Baird Warner.
7. On July 4, 2013 the Plaintiff was an invitee at a party at the residence owned by the
Defendant, at 3258 N Central Avenue, Chicago, IL 60632.
8. The Plaintiff was on a backyard deck, which was raised four feet off the ground.
9. On or about 6:00 pm the Plaintiff leaned against the deck railing, when the railing gave
way and he plunged four feet to the ground on.
10. As a result of the fall, the Plaintiff sustained a severe injury to his right leg, breaking his
leg in two places.

2. Megan Shore
9/29/14
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11. As a result of the injury, the Plaintiff also suffered a permanent limp, due to one leg being
shorter than the other.
12. The incident mentioned above occurred as a result of by the negligent and grossly
carelessness of the Defendant. The Defendant’s negligent and careless conduct
consisted of the following:
a) Failing to repair the broken railing on the deck in the backyard of the residence at
3258 N. Central Avenue, Chicago, IL 60632;
b) Failing to warn the guests at the party that the railing was in disrepair;
c) Failing to block off the area in front of the railing by use of caution tape, large
object or warning sign;
d) Failing to ensure the safety of the guests at the party by rescheduling the event to
a time until subsequent repair of the railing;
e) Failing to exercise the degree of care required by the defendant to her invitees
aforementioned circumstances; and
f) Otherwise being negligent.
13. As a result of the conduct stated above and the breach of duty of care caused by the
Defendant, Patsy Cline, Plaintiff sustained the injuries, loses and damages, which were
more fully described above, without any contributing negligence on the part of the
Plaintiff.
14. Solely as a result of the injuries mentioned above, the Plaintiff, Mike Blunder, has
incurred damages, including:
a) Hospital $50.000.00;
b) Physical Therapy $28,000.00;
c) Attending Physician $20,000.00;
d) Lost wages $183,333.33;
e) Home health care $20,000.00;
f) Household assistance $8,000.00;
g) Extreme pain and suffering $44,666.67.
WHEREFORE, the Plaintiff, Mike Blunder, is seeking judgment against the Defendant, Patsy
Cline, in the sum of THREE HUNDRED FIFTY FOUR THOUSAND AND ONE DOLLARS
($354,001.00), and costs and any such other relief as this court deems just and proper.

3. Megan Shore
9/29/14
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COUNT TWO
15. The Plaintiff, Susan Blunder incorporates herein by reference to the allegations of
paragraphs 1 through 14 and applies to the following:
16. Solely as the result of the above mentioned injuries, the Plaintiff has suffered the loss of
consortium, including:
a) Loss of husband’s assistance with household duties;
b) Loss of financial support;
c) Loss of social life with her husband;
d) Loss of sex life;
e) Postponement of the attempt to conceive a child and start a family.
17. As a result of the negligence, and the breach of duty on part of the Defendant, Patsy
Cline, the Plaintiff sustained a loss of martial relationship, as mentioned above.
WHEREFORE, the Plaintiff, Susan Blunder, is seeking judgment against the Defendant, Patsy
Cline, in the sum of TWENTY THOUSAND DOLLARS ($20,000.00), and costs and any such
other relief as this court deems just and proper.
Plaintiff demands Trial by Jury.
Phillips Stone
Plaintiff’s Attorney
208 N LaSalle St., Suite 1750
Chicago, IL 60604-1102
312-208-9936
We, Mike Blunder and Susan Blunder, certify Houston, Lewis, & Stone, L.L.C. will be
representing us as Plaintiffs in the above mentioned action. The allegations in this complaint are
true.
Subscribed and sworn to before me this 29th day of September, 2014.
Notary Public
My commission expires January 1, 2017.

4. Megan Shore
9/29/14
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