IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION

SALLY CORBETT,

Plaintiff, v BOB RELTON AND THE CITY OF CHICAGO

Defendants. COMPLAINT

) ) No. 09L0078943 ) ) Return Date: ) ) Amount Claimed: $ 350,000.00 ) ) ) ) )

Comes now the Plaintiff, by and through her attorney Cheryl A. Kettler of Cheryl A. Kettler, Attorney-At-Law, and for cause of action against the Defendants, Bob Relton and the City of Chicago, complains and alleges as follows: COMMON ALLEGATIONS (Against All Defendants) I. Plaintiff is informed and believes and thereon alleges that each of the Defendants, Bob Relton and the City of Chicago, are responsible in some manner for the events and happenings herein referred to, caused injuries and proximate damages to the Plaintiff. II. Plaintiff is informed and believes that Defendant Bob Relton is and was a peace officer for the City of Chicago Police Department on June 04, 2009. III. Plaintiff is informed and believes that Defendant, Bob Relton is a resident and citizen of the State of Illinois, Cook County, and the City of Chicago.

IV. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned Defendant, City of Chicago was the owner emergency transportation vehicle #4312, IL Plate # M21 1234. V. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned Defendant Bob Relton was driving the aforesaid emergency transportation vehicle, with the permission and consent of Defendant City of Chicago. VI. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned, the Defendant Bob Relton was the agent, servant, and employee of the remaining Defendant City of Chicago, and at all times herein mentioned, he was acting within the time, place and scope of said agency and employment. VII. Plaintiff is informed and believes and thereon alleges that on June 04, 2009, Defendant Bob Relton was acting in his official police capacity for the City of Chicago Police Department. VIII. On or about June 04, 2009, Plaintiff was driving the aforesaid vehicle which was traveling southbound on a Cicero Avenue road at the intersection on Archer Avenue road in the County of Cook, State of Illinois. IX. On or about June 04, 2009, Defendant Bob Relton was driving the aforesaid emergency transportation vehicle southbound on Cicero Avenue at the intersection on Archer Avenue in the City of Chicago, County of Cook, and State of Illinois. X.

On or about June 04, 2009, Defendant Bob Relton was under the influence of prescription drugs while driving aforesaid emergency transportation vehicle.

XI. At all times herein mentioned, the intersection of Cicero Avenue and Archer Avenue is in the County of Cook, State of Illinois, was an open and public street. FIRST CAUSE OF ACTION (Negligence Per Se Against all Defendants) XII. Plaintiff hereby re-alleges and incorporates by reference Paragraphs I through XI, inclusive, as if set out in full herein. XIII. At said date, time and place, Defendants Bob Relton and the City of Chicago, inclusive, did so negligently and carelessly own, operate, maintain, manage, control, and entrust their respective emergency transportation vehicle to Defendant Bob Relton so as to cause the Defendant Bob Relton and Plaintiff to strike each other and thereby proximately caused the hereinafter described injuries and damages to Plaintiff. XIV. As a direct and proximate result of the aforesaid negligence and carelessness of the Defendants, and each of them, Plaintiff was injured in health, strength and activity, sustaining severe shock and injury to her nervous system and person, and causing Plaintiff mental, physical and nervous pain and suffering and resulting in her disability, all to her general damage in a sum which exceeds $350,000.00 and will be shown according to proof. XV. As a direct and proximate result of the aforesaid negligence and carelessness of the Defendants, and each of them, Plaintiff was compelled to and did incur expenses for medical care, hospitalization, and other incidental expenses and will have to incur additional like expenses in the future, all in amounts
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presently unknown to her. Plaintiff therefore asks leave of Court either to amend this complaint so as to show the amount of her medical expenses, when ascertained, or to prove said amount at the time of trial. XVI. As a direct and proximate result of the aforesaid negligence and carelessness of the Defendants, and each of them, Plaintiff was disabled and may be disabled in the future and thereby be prevented from attending to the duties of her usual occupation. Plaintiff has therefore lost earnings and may continue to lose earnings in the future, all in amounts presently unknown to her. Plaintiff asks leave of Court either to show the amount of her lost earnings, when ascertained, or to prove said amount at the time of trial. XVII. As a direct and proximate result of the aforesaid negligence and carelessness of the Defendants, and each of them, the Plaintiffs 2001 Saturn 400 automobile and other property owned and/or used by Plaintiff was damaged; and Plaintiff thereafter was denied the use of said vehicle and other property, to Plaintiff's further damage all in amounts which will be shown according to proof. XVIII. As a direct and proximate result of the aforesaid negligence and carelessness of the Defendants, and each of them, Plaintiff suffered emotional distress and mental anguish. XIX. It has been necessary for Plaintiff to retain the services of the law firm of Cheryl A. Kettler, Attorney-at-Law to prosecute this action, and Plaintiff is entitled to be awarded attorneys fees and costs, as well as prejudgment interest. SECOND CAUSE OF ACTION (Vicarious Liability Against All Defendants) XX. Plaintiff hereby re-alleges and incorporates by reference Paragraphs I through XIX, inclusive, as if set out in full herein. XXI.

Defendants and each of them owed a duty to the users of the public roadways to operate their vehicle in a safe and reasonable manner. XXII. Defendants, and each of them, breached that duty by acts and omissions including, but not limited to, inattentive driving and operating their vehicle at an unsafe speed in consideration of the traffic on the roadway, unsafe turning, and unsafe lane changes. XXIII. As a direct and proximate result of the acts and omissions of Defendants as herein alleged, said Defendants did cause their vehicles to collide, involving the vehicle in which Plaintiff, user of the public roadways, was riding. XXIV. As a direct and proximate result of the vehicular collision between Defendants vehicles and Plaintiffs vehicle, Plaintiff has been caused injury as alleged in Paragraphs XV through XIX.

WHEREFORE, Plaintiff prays for judgment against the Defendants, and each of them as follows: 1. 2. 3. For general damages in excess of $350,000.00 according to proof, For loss of earnings and earning capacity according to proof,

For medical expenses, future medical expenses and all incidental expenses according to proof, 4. 5. 6. 7. For interest from the date of accident to the time of judgment, For costs of suit incurred herein, For attorney fees incurred herein, and For such other and further relief as the Court deems proper and necessary. JURY DEMAND Plaintiff requests a trial by jury for all claims.

DATED this 11 day of January 2010

th

Respectfully Submitted,

Cheryl A. Kettler, Attorney for Plaintiff Cheryl A. Kettler, Attorney-At-Law 14 E. Jackson Boulevard, Suite 1003 Chicago, Illinois 60604 Office: (312) 565-0001 Fax: (312) 565-0002 Attorney No. 1901000