UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MISSOURI

CIVIL COMPLAINT
)

PLAINTIFF )
Justin King
)
123 Main
Street ) CASE
NO. 1234
Kansas City,
MO. )
VS.
)

Defendant
)
Coors
Brewery Company )
5400 Pecos
Street )
Denver, CO.
)

Plaintiff, Justin King, by his

attorneys Bohm & Bohm, against

Defendant alleges the following:

PARTIES:
1. The Plaintiff, Justin King, is

a citizen of the state of Missouri.

2. The Defendant, Coors

Distributing Company is a

corporation located in the state of

Colorado.

JURISTICTION:

3. The negligent acts set forth in

the complaint occurred in the state of

Illinois

4. The court has subject matter

jurisdiction under Title 28 U.S. §

1332(a)(1), due to the controversy

exceeding the sum of $75,000 and

both the Plaintiff and Defendant are

from different states.

5. The venue in the Western

District of Missouri is proper under

Title 28 U.S.C. § 1391(a)(3).

COUNT I: NEGLIGENCE
6. On April 8, 2004, the

Plaintiff, Justin King was traveling

southbound on Interstate 57 located

in Paxton, Illinois on his

motorcycle.

7. On the same day, a vehicle

driven by an employee for the

Defendant, Coors Brewery Company

was also traveling southbound on

Interstate 57, directly behind the

Plaintiff

8. The Defendants employee

signaled to the Plaintiff by flashing

his lights that he wanted to pass the

Plaintiff.

9. The Plaintiff switched lanes

allowing the driver for the Defendant

to pass at which time he noticed

product falling from the Defendants

vehicle.

10. The Defendant has a duty to

ensure employees are trained in

operating delivery vehicles in a safe

manner.

11. The Defendant must ensure

vehicle maintenance is kept up to

code and in working order.

12. Defendant was negligent in

failing to keep up the maintenance of

the tires as well as the security

device for the cargo being carried.

13. Defendant was negligent in

the matter of the employee having

reckless regard for the

A) Safety of others.

B) Failure to keep lookout.

C) Failure to observe location of

the Plaintiff’s vehicle.

D) Failure to avoid a collision.

14. As a result of the Defendants

negligence, the Plaintiff, Justin King,

suffered serious injuries, lost wages,

medical bills, and emotional distress.

COUNT II: NEGLIGENCE PER SE

15. Defendant violated U.S.

Department of Transportation

Federal Motor Carriers Safety Rules

by not ensuring the security devices

were in working condition.

16. As a direct and proximate

cause of the Defendant’s disregard

for safety, the Plaintiff suffered

serious injuries.

COUNT III: STRICT

LIABILITY

17. The Defendant participated in

the maintenance of the delivery

vehicle.

18. The Defendant was aware of

the repairs needed to the delivery

vehicle

19. The Defendant failed to

ensure all repairs were done in a

timely manner.
20. As a direct and proximate

cause of the Defendant’s failure to

keep up with the maintenance of the

delivery vehicle, the Plaintiff

suffered serious injuries.

RELIEF:

As a result of the collision, the

Plaintiff, Justin King demands

judgment against the Defendant,

Coors Brewery Company in the

amount of One Hundred Million

Dollars (100,000,000) in damages,

pain and suffering, emotional

distress, and medical bills.

Respectfully submitted,

April 10, 2005

Bohm & Bohm

Stanley Bohm
Lyndi Bohm

100 North Congress Ave.

Kansas City, Mo 64101

(123)555-3456

Counsel for Plaintiff