! ! "#$#%!&'!())(*&("! ! ! ! -./$0%!1&.*#2! !

+! +! +!

"",!

!"#$%&#'!(')!$#'*)($#+*(#$%&#&!,%$&&"$%#-).!'!/0#'!(')!$# .)1/,&#'*)"$23#!00!"*!4!
! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! +! +! +! +! +! +! +! +! +! +! +! +! +! +! +! +! ! !

3&"(%!03%%*! ! ! ! ! ! ! ! /45678699:!! ! ! ! ! ! ! ! ;,! ! ! ! ! ! ! ! ! ! ($D!"/%%-2! ! ! (7E6;6EF544G:!57E! ! ! ! ! ! EHIH5! ! ! ! ! ! ! ! "/%%-2!$DJ.)$*1%!$*-! /(LL$!-%)(M%32:!(*1,! ! ! ! ! ! ! -N9N7E578O,! ! !

*<,!=>?@!)!?=@ABC!

! !

K.32!#3($)! -%D$*-%-!

Complaint At Law
NOW COMES Plaintiff, Rosie Green, by and through her attorney, Burns and Smith Law Office, P.C., and for her complaint at law against Defendant Iam Speedy, individually and doing business as Speedy Ambulance and Pizza Delivery, Inc., states as follows: 1. On or about January 2, 2011, Plaintiff was the owner and operator of a duly licensed vehicle, a horse-drawn carriage, in the City of Glen Ellyn, DuPage County, Illinois. In the same time and place, Defendant, individually or as agent and servant of Speedy Ambulance and Pizza Delivery, Inc., authorized to do business in the State of Illinois, owned and operated a motor vehicle. In the same time and place, Defendant collided into Plaintiff at or near the intersection of Fawell Boulevard and Scholars Drive in said City of Glen Ellyn, Illinois.

2.

3.

4.

At all times herein, Defendant owed Plaintiff duties of care as follows: a. To pay attention to other vehicles on the road; b. To maintain control of his own vehicle to avoid accidents; c. To exercise greater care due to the dangerous road conditions at the time of the collision; d. Under 625 ILCS 5/11-804, providing: The electric turn signal device must be used to indicate an intention to turn; e. Under 625 ILCS 5/11-902, providing: The driver of a vehicle intending to turn to the left within an intersection or into an alley, private road, or driveway shall yield the right-of-way to any vehicle approaching from the opposite direction which is so close as to constitute an immediate hazard. Defendant violated one or more of his duties to the Plaintiff in that he: a. Failed to pay attention to other vehicles on the road; b. Failed to maintain control of his own vehicle; c. Failed to exercise great care due to dangerous road conditions; d. Failed to operate his turn signal in violation of 625 ILCS 5/11-804; e. Failed to yield to oncoming traffic in violation of 625 ILCS 5/11-902. As a direct and proximate result of Defendants negligence, Plaintiff sustained injury to her person and her property and will continue to suffer further such injuries.

5.

6.

WHEREFORE, Plaintiff moves for judgment in her favor and against Defendant, individually and doing business as Speedy Ambulance and Pizza Delivery, Inc., and each of them, in an amount not less than $50,000, exclusive of costs and attorney fees.

Seymour Burns
Seymour Burns Attorney for Plaintiff ARDC#: 987654 Burns and Smith Law Office, P.C. 3500 Ridgewood Ave Bensenville, IL 60106 (630) 555-0123