State of Illinois

Attorney No.: 34466

) SS County of Cook )

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS> COUNTY DEPARTMENT - LAW DIVISIW4 JAN 2 i

.Q .' -

t: )

BRIANA RUSHING Plaintiff, vs. DJ'S SPORTS BAR & GRILL, INC., Defendant.

) ) ) ) ) ) ) )

PH ~: 04

No.

JURY DEMAND

COMPLAINT AT LAW

NOW COMES the Plaintiff, BRIANA RUSHING (hereinafter "Plaintiff'), by and through her attorneys, BELCHER LAW OFFICE, and for her complaint against the Defendant, DJ'S SPORTS BAR & GRILL, INC. (hereinafter "Defendant"), complains as follows: 1. On or about April 8, 2013, Defendant owned, operated, managed, maintained, and

controlled an establishment known as DJ'S Sports Bar & Grill (hereinafter the "Bar"), located at 14202 Cottage Grove Avenue, Dolton, Illinois 60419 (hereinafter the "subject premises"). 2. The Bar has a parking log, which was available to for use by patrons of the Bar

(hereinafter the "parking lot"). 3. 4. Defendant owned, operated, managed, maintained, and controlled the parking lot. On or about April 8, 2013, the parking lot had various potholes, cracks, and was

in a general state of disrepair, which constituted a dangerous condition. 5. At the time and place alleged above, the parking lot was not sufficiently lit to

allow customers and patrons of the Bar to see where they were walking. 6. At the time and place alleged above, Plaintiff was lawfully walking in the parking

lot as a customer and patron of the Bar. 7. At the time and place alleged above, Plaintiff was injured to due to the conditions

present in the parking lot. 8. At all times relevant, there was in the State of Illinois, in full force and effect, an

act commonly referred to as the Premises Liability Act, 740 ILCS 130, which states in relevant

part: "The duty owed to such entrants is that of reasonable care under the circumstances regarding the state of the premises or acts done or omitted on them." 740 ILCS 130/2. 9. At the time and place alleged above, Defendant had a duty to use reasonable care

in the ownership, operation, management, maintenance, and control of the subject premises, including the parking lot. 10. At the time and place alleged above, Defendant, in violation of such duty,

committed one or more of the following negligent acts or omissions a b Failed to provide adequate lighting in the parking lot of the subject premises. Failed to timely and properly maintain and repair the parking lot of the subject premises so as to provide a safe walking surface for the Bar's customers and patrons. c Failed to provide any type of warning for the Bar's customers and patrons concerning the unsafe condition ofthe parking lot when it knew, or in the exercise of ordinary care should have known, that a warning was necessary for the safety of the Bar's customers and patrons, including Plaintiff. d Was otherwise careless and/or negligent in the ownership, operation, maintenance, and management of the parking lot of the subject premises. 11. As a proximate result of one or more of the foregoing negligent acts or omissions

of Defendant, Plaintiff did suffer serious injuries of a personal and pecuniary nature including medical expenses, pain, suffering, permanent disability, and disfigurement, which have prevented her from attending to her usual affairs, occupations, and actives. 12. As a proximate result of one or more of the foregoing negligent acts or omissions

of Defendant, Plaintiff was unable to work in her normal occupation, causing Plaintiff to lose income she would have otherwise earned. Due to Plaintiffs lost income, Plaintiff could not afford her rent and was forced to move out of her home. WHEREFORE, Plaintiff, BRIANNA RUSHING, requests that the Court enter judgment in her favor, and against Defendant, DJ'S SPORTS BAR & GRILL, INC., in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), together with costs and interest.

Respectfully submitted, BELCHER LA W OFFICE

/71

BECHER LAW OFFICE 350 NORTH LASALLESTREET, SUITE 750 CHICAGO, ILUNOIS 60654 (312) 670-9000 ATTORNEY No.: 34466

) ) SS County of Cook )

State of lllinois

Attorney No.: 34466

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - LAW DIVISION
BRIANA RUSHING Plaintiff, vs. Drs SPORTS BAR & GRILL, INC., Defendant.
) ) ) ) ) ) ) )

No.

ILLINOIS SUPREME COURT RULE 222 AFFIDAVIT

NOW COMES the Affiant, Matthew D. Goodstein, attorney for the Plaintiff, being first sworn on oath, deposes states and certifies to this court that the total money damages sought in this cause exceeds FIFTY THOUSAND DOLLARS ($50,000.00). FURTHER AFFIANT SAYETH NAUGHT.

BECHER LAW OFFICE

350 NORTH LASALLE STREET, SUITE 750 CHICAGO, ILLINOIS 60654 (3 I2) 670-9000 ArrORNEyNo.: 34466