1. Justin King filed a complaint against Anheuser-Busch Companies and driver Frank Cuellar for negligence stemming from a motorcycle accident. 2. According to the complaint, in April 2011 King was driving on the highway when a beer delivery truck driven by Cuellar started losing its cargo of beer cases, causing King to crash and sustain severe facial fractures requiring hospitalization. 3. King alleges Cuellar breached his duty to properly secure the load and is seeking $245,000 to cover past and future medical expenses.

1. IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
JUSTIN WILLIAM KING, )
)
Plaintiff. )
)
)
v. )
)
ANHEUSER-BUSCH COMPANIES, INC.
Frank Cuellar
)
Defendant. )
____________________________________)
COMPLAINT
Comes now the plaintiff, Justin King, by and through his attorney, states as follows:
PARTIES AND JURISDICTION
1. Plaintiff, for all times mentioned herein, was and is a resident of Cook County, State of
Illinois.
2. Defendant is a corporation with its principal place of business in Missouri and carries on
business in Northern District of Illinois.
3. This court has subject matter jurisdiction over the claims presented in this complaint under 28
U.S.C. § 1332 because plaintiff is a resident of Illinois and the defendant is a citizen of Illinois
and the amount in controversy exceeds $75,000, exclusive of fees and costs.
4. Personal jurisdiction and venue are proper in this District pursuant to 28 U.S.C. § 1391
because the acts of defendant caused harm to plaintiff in Ford County, in Paxton of Illinois.
COUNT I: Negligence
1. On or about April 8th, 2011, plaintiff was driving on I 57 South from Chicago, Illinois.
2. When an Anheuser-Busch beer delivery truck flashed the lights to pass the plaintiff.
3. Plaintiff, moved to center lane to let the said delivery truck pass.
4. Plaintiff, moved back to the right, when said delivery truck started losing cargo.

2. 5. Several cases of beer flew out causing the plaintiff to crash while on a motorcycle.
6. Plaintiff, woke up in Paxton Hospital with wires in face, from 9 facial bone fractures.
7. Plaintiff spent 2 days in Paxton Hospital ICU.
8. Plaintiff, was transferred to Metropolitan Memorial Hospital (MMH) in Chicago, Illinois,
by AAA Ambulance Service out of Bloomington, Illinois.
9. Plaintiff was told his face had to be reset, with 2 failed attempts.
10. Plaintiffs, left side of face is higher than the right.
11. Plaintiff, was released from hospital to be admitted into mental ward in Kansas City,
Kansas.
12. Plaintiff was hospitalized for up to a year, released on anti-depressants and life time of
counseling.
13. Plaintiff, lost his 3 year music contract with MCI records, due to accident,
That he was offered after winning National Idol in Chicago, Illinois on April 5th, 2011.
On the occasion in question, defendant, Frank Cuellar, driver of the delivery truck, breached his
duty to secure the said delivery truck of its load.
Defendant had a duty to secure each and every load before driving off to next destination.
Defendant breached the duty of due care by not securing the load per D.O.T and Anheuser-
Busch driver and delivery protocol.
As a direct and proximate cause of defendant's negligent activity, as set forth above, plaintiff has
incurred the following expenses for medical care and attention:
1. $145,000 for past medical bills.
2. $100,000 for future facial surgery’s and counseling.
DEMAND FOR JURY TRIAL
Plaintiff demands a trial by jury.
PRAYER FOR RELIEF

3. WHEREFORE, plaintiff requests judgment against defendant as follows:
General damages in the sum of $245,000 for medical bills past due and future.
Interest on such damages awarded as allowed by law;
Costs of suit; and
Such other and further relief as the Court may deem just and proper.
Dated: 11/4/2014
Jane Doe
IL Attorney License # 12345
Law Office of Jane Doe
123 Main Street
Chicago, IL 60601
Attorney for Plaintiff