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Court Date: 11/15/2023 10:30 AM FILED
9/14/2023 2:29 PM
IN THE CIRCUIT COURT OF COOK COUNTY, IRIS Y. MARTINEZ
CIRCUIT CLERK
COUNTY DEPARTMENT, LAW DIVISION
COOK COUNTY, IL
FILED DATE: 9/14/2023 2:29 PM 2023L009330

2023L009330
PATRICK HICKEY, ) Calendar, B
) 24378481
Plaintiff, )
) 2023L009330
v. ) No.:
)
ADAM HAMM, )
)
Defendant. )

COMPLAINT AT LAW

Automobile - Negligence

Plaintiff, PATRICK HICKEY, complaining of defendant, ADAM HAMM, states:

1. At all times relevant, Burlington Avenue was a public roadway running in an east

and west direction in LaGrange, Illinois.

2. At all times relevant, Brainard Avenue was a public roadway running in a north

and south direction in LaGrange, Illinois.

3. At all times relevant, Burlington Avenue and Brainard Avenue intersected in

LaGrange, Illinois (hereinafter “the intersection”).

4. At all times relevant, there existed a crosswalk that crossed Brainard Avenue,

south of the intersection (hereinafter “the crosswalk”).

5. On May 10, 2023, plaintiff, PATRICK HICKEY, was a pedestrian walking from

west to east in the crosswalk.

6. On May 10, 2023, there existed a 2006 Jeep Wrangler with VIN

1J4FA39576P715686 (hereinafter “the Jeep”).

7. On May 10, 2023, and at all times relevant, the Jeep was in good mechanical

conditions with no defects or problems.

 8. On May 10, 2023, defendant, ADAM HAMM, operated the Jeep.

9. On May 10, 2023, defendant, ADAM HAMM, operated the Jeep southbound on
FILED DATE: 9/14/2023 2:29 PM 2023L009330

Brainard Avenue.

10. On May 10, 2023, defendant, ADAM HAMM, operated the Jeep southbound on

Brainard Avenue into the crosswalk.

11. On May 10, 2023, defendant, ADAM HAMM, operated the Jeep southbound on

Brainard Avenue into the crosswalk and into the body of plaintiff, PATRICK HICKEY.

12. On May 10, 2023, defendant, ADAM HAMM, was negligent in one or more of

the following ways:

a) Failed to yield the right of way to a pedestrian in violation of 625 Illinois

Compiled Statutes § 5/11-901;

b) Operated the vehicle at a speed which endangered the safety of persons, in

violation of 625 Illinois Compiled Statutes § 5/11-601;

c) Operated the vehicle at a speed which was greater than reasonable and proper
in violation of 625 Illinois Compiled Statutes § 5/11-601 et seq.;

d) Failed to decrease speed to avoid collision with a person in violation of 625

Illinois Compiled Statutes § 5/11-601;

e) Failed to exercise due care to avoid colliding with a pedestrian in violation of

625 Illinois Compiled Statutes § 5/11-1003.1;

f) Failed to exercise due care to avoid colliding with a pedestrian in violation of

625 Illinois Compiled Statutes § 5/11-1007;

g) Failed to give audible warning with a horn to insure safe operation of the
motor vehicle when such warning was reasonably necessary in violation of
625 Illinois Compiled Statutes § 5/12-601;

h) Operated the vehicle without keeping proper and sufficient lookout;

i) Failed to decrease speed so as to avoid colliding with a pedestrian;

j) Failed to yield the right of way to a pedestrian with clearly visible disabilities
in violation of 625 Illinois Compiled Statutes § 5/11-1004;

2
 k) Failed to give warning of impending collision by sounding horn in violation of
625 Illinois Compiled Statutes § 5/11-1003.1; and,
FILED DATE: 9/14/2023 2:29 PM 2023L009330

l) Failed to yield the right of way to a pedestrian in the crosswalk in violation of

625 Illinois Compiled Statutes § 5/11-1002 (a).

13. As a proximate result of one or more of these negligent acts or omissions,

plaintiff, PATRICK HICKEY, suffered injuries – both temporary and permanent – to his

personal and pecuniary interests.

WHEREFORE, plaintiff, PATRICK HICKEY, demands judgment of defendant, ADAM

HAMM, for compensatory damages in an amount in excess of the jurisdictional minimum of the

Law Division of the Circuit Court of Cook County.

____________________________________
Dixon Law Office
By: G. Grant Dixon III

Dixon Law Office

Attorneys for Plaintiff
1415 West 55th Street
Suite 101
La Grange, Illinois 60525
Tel (708) 354-9880
Fax (708) 354-9885
Web www.AttorneysMakingItRight.com
Email Contact@DixonLawOffice.com
County ID: 37599