STATE OF ILLINOIS CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT COUNTY OF LAKE MARY RICHARDS,

) ) ) ) ) ) ) ) )

Plaintiff, v. ANDREW WILKIN, Defendant.

Case No.

COMPLAINT AT LAW NOW COMES Plaintiff, MARY RICHARDS, by and through her attorney, JAMES STICKUM, and for her Complaint against Defendant, ANDREW WILKIN, states as follows:

1. On or about July 17th 2011, at approximately 9:00 AM, Plaintiff was the owner and operator of a motor vehicle slowing to a stop south bound Lewis Avenue at or near the intersection of Wadsworth Road and Lewis Avenue, in the town of Wadsworth, County of Lake, state of Illinois.

2. At the above time and date the defendant was operating his motor vehicle south bound on Lewis Avenue to the North and rear of the vehicle driven by the plaintiff.

3. That at all times material hereto it was the duty of the defendant to so operate maintain and control her vehicle so as to avoid colliding with other traffic upon the roadway including the vehicle being operated by the plaintiff.

4. At the aforementioned time and place, Defendant fell asleep while operating his motor vehicle

which allowed him to collide with the motor vehicle driven by the plaintiff.

5. It was the duty of Defendant to drive, operate, manage, and control his vehicle in a prudent manner so as not to endanger the life, limb, or property of any persons lawfully then on the highway, including Plaintiff. In breach of that duty, Defendant was then and there guilty of one or more of the following acts or omissions:

a.Failure to reduce speed to avoid a collision in violation of 625 ILCS 5/11-601(b) b.Following to close to the vehicle in front of him, in violation of 625 ILCS 5/11-710 c.Was otherwise negligent in operation of his motor vehicle.

6. That as a direct and proximate result of one or more of the above and foregoing negligent and/or wrongful acts or omissions the plaintiff was severely and permanently injured and in seeking to be cured from those injuries has incurred and will in the future incur substantial; hospital and medical bills And suffering other damages including but not limited to great pain and suffering.

WHEREFORE, Plaintiff MARY RICHARDS, prays for judgment against Defendant, ANDREW WILKIN, in an amount in excess of fifty thousand dollars ($50,000) plus costs of suit. MARY RICHARDS, Plaintiff, by:

Jame Stickum ARDC 1234567 Dewey, Stickum, & Howe, Ltd. 100 Legal Way, Waukegan, Illinois., 60085

_________________________________ Attorney

STATE OF ILLINOIS CIRCUIT COURT OF THE ...

STATE OF ILLINOIS. CIRCUIT COURT OF THE ... substantial; hospital and medical bills And suffering other damages including but not limited to great pain and ...

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