IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. COMPLAINT AT LAW

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1 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION INJURED PERSON, Plaintiff, v. RESPONSIBLE PARTIES Defendants. No. COMPLAINT AT LAW COUNT ONE NEGLIGENCE-RESPONSIBLE PARTY NOW COMES the Plaintiff, INJURED PERSON, by and through her attorneys, ROSENFELD INJURY LAWYERS., and for her Count One of her Complaint at Law against defendant, RESPONSIBLE PARTY, states: 1. On and before April 23, 2012, the Plaintiff, INJURED PERSON resided at Elm Street, City of Blue Island, County of Cook and State of Illinois. 2. On and before April 23, 2012, defendant, RESPONSIBLE PARTY, resided at Rexford, City of Blue Island, County of Cook and State of Illinois. 3. On April 23, 2012, at approximately 6:00 p.m., and at all times relevant to this claim, defendant, RESPONSIBLE PARTY, was operating a vehicle, a 1985 GMC Jimmy, in a southbound direction on Gregory Street, at or near its intersection with New Street, in Blue Island, Illinois. 1

2 4. On April 23, 2012, at approximately 6:00 p.m., Plaintiff, INJURED PERSON was riding her bicycle in an eastbound direction on New Street, at or near its intersection with Gregory Street, in the City of Blue Island, County of Cook and State of Illinois. 5. At that same time and place, defendant RESPONSIBLE PARTY owed a duty of reasonable care in the operation of his vehicle in order to avoid colliding with, striking or contacting pedestrians, cyclists, or other vehicles on the roadway, including INJURED PERSON on her bicycle. 6. Notwithstanding that duty, at that same time and place, the vehicle being driven by defendant RESPONSIBLE PARTY collided with, struck and/or contacted INJURED PERSON as she rode her bicycle. 7. On April 23, 2012, INJURED PERSON was injured. 8. At that same time and place, defendant RESPONSIBLE PARTY, was then and there guilty of one or more of the following acts and/or omissions: (a (b (c (d (e Failed to exercise that degree of care and caution that a reasonable person under similar circumstances would have exercised in the operation of his vehicle; Failed to keep an adequate or any lookout while driving his vehicle; Operated his vehicle at a speed that was greater than was reasonable given the traffic conditions and the use of the highway, in violation of 625 ILCS 5/11-601; Failed to sound the horn while driving his vehicle when the use of the horn was reasonably necessary to ensure the safety of others on the road, in violation of 625 ILCS 5/12-301; Failed to yield the right of way to INJURED PERSON; OR (f Was otherwise careless and negligent. 2

3 9. One or more of these acts and/or omissions of defendant RESPONSIBLE PARTY was a proximate cause of the collision between the vehicle being driven by defendant RESPONSIBLE PARTY and INJURED PERSON. 10. As a direct and proximate result of one or more of these acts and/or omissions by defendant RESPONSIBLE PARTY, Plaintiff, INJURED PERSON has been injured, damaged and incapacitated; has in the past and will in the future, incur legal obligations for hospital, medical, nursing, rehabilitative and related services and treatment; has lost wages and will stand to lose wages in the future; has been caused to suffer pain, disability, disfigurement and inconvenience; all of which injuries and conditions are permanent. WHEREFORE the Plaintiff, INJURED PERSON, demands judgment against defendant RESPONSIBLE PARTY, in a sum in excess of FIFTY THOUSAND AND 00/100 DOLLARS ($50,000.00, plus costs. COUNT TWO NEGLIGENCE-RESPONSIBLE PARTY NOW COMES the Plaintiff, INJURED PERSON, by and through her attorneys, ROSENFELD INJURY LAWYERS., and for her Count Two of her Complaint at Law against defendant, RESPONSIBLE PARTY, states: 11. On and before April 23, 2012, the Plaintiff, INJURED PERSON resided at Elm Street, City of Blue Island, County of Cook and State of Illinois. 12. On and before April 23, 2012, defendant, RESPONSIBLE PARTY, resided at 3012 W. 135 th Place, City of Robbins, County of Cook and State of Illinois. 3

4 13. On April 23, 2012, at approximately 6:00 p.m., and at all times relevant to this claim, defendant, RESPONSIBLE PARTY, was operating a vehicle, a 2001 Ford Focus, in a southbound direction on Gregory Street, at or near its intersection with New Street, in Blue Island, Illinois. 14. On April 23, 2012, at approximately 6:00 p.m., Plaintiff, INJURED PERSON was riding her bicycle in an eastbound direction on New Street, at or near its intersection with Gregory Street, in the City of Blue Island, County of Cook and State of Illinois. 15. At that same time and place, defendant RESPONSIBLE PARTY owed a duty of reasonable care in the operation of her vehicle in order to avoid colliding with, striking or contacting pedestrians, cyclists, or other vehicles on the roadway, including INJURED PERSON on her bicycle. 16. Notwithstanding that duty, at that same time and place, the vehicle being driven by defendant RESPONSIBLE PARTY collided with, struck and/or contacted INJURED PERSON as she rode her bicycle. 17. On April 23, 2012, INJURED PERSON was injured. 18. At that same time and place, defendant RESPONSIBLE PARTY, was then and there guilty of one or more of the following acts and/or omissions: (a (b (c (d Failed to exercise that degree of care and caution that a reasonable person under similar circumstances would have exercised in the operation of her vehicle; Failed to keep an adequate or any lookout while driving her vehicle; Operated her vehicle at a speed that was greater than was reasonable given the traffic conditions and the use of the highway, in violation of 625 ILCS 5/11-601; Failed to sound the horn while driving her vehicle when the use of the horn was reasonably necessary to ensure the safety of others on 4

5 the road, in violation of 625 ILCS 5/12-301; (e Failed to yield the right of way to INJURED PERSON; OR (f Was otherwise careless and negligent. 19. One or more of these acts and/or omissions of defendant RESPONSIBLE PARTY was a proximate cause of the collision between the vehicle being driven by defendant RESPONSIBLE PARTY and INJURED PERSON. 20. As a direct and proximate result of one or more of these acts and/or omissions by defendant RESPONSIBLE PARTY, Plaintiff, INJURED PERSON has been injured, damaged and incapacitated; has in the past and will in the future, incur legal obligations for hospital, medical, nursing, rehabilitative and related services and treatment; has lost wages and will stand to lose wages in the future; has been caused to suffer pain, disability, disfigurement and inconvenience; all of which injuries and conditions are permanent. WHEREFORE the Plaintiff, INJURED PERSON, demands judgment against defendant RESPONSIBLE PARTY, in a sum in excess of FIFTY THOUSAND AND 00/100 DOLLARS ($50,000.00, plus costs. ROSENFELD INJURY LAWYERS ROSENFELD INJURY LAWYERS 33 North Dearborn Street, #1930 Chicago, IL Tel: ( Fax: ( By: Jonathan Rosenfeld 5