Preview
Law Division Motion Section Initial Case Management Dates for CALENDARS (A,B,C,D,E,F,H,R,X,Z) will be heard In Person.
All other Law Division Initial Case Management Dates will be heard via Zoom
For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12
Court Date: 7/17/2024 10:30 AM FILED
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 5/15/2024 3:13 PM
IRIS Y. MARTINEZ
COUNTY DEPARTMENT, LAW DIVISION CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 5/15/2024 3:13 PM 2024L005416
WIDLINE MICHAELLE TASSY 2024L005416
Plaintiff, Calendar, B
vs. No. 27708666
DWAYNE T. KENNEDY Amount Claimed: in excess
Defendant, of $50,000.00 PLUS COSTS
COMPLAINT
NOW COMES the Plaintiff, WIDLINE MICHAELLE TASSY, by her attorneys,
ELMAN JOSEPH LAW GROUP, LLC, and in complaining of the Defendant, DWAYNE T.
KENNEDY, states as follows:
1. That on July 28, 2022, the Plaintiff, WIDLINE MICHAELLE TASSY, was an
operator and owner of a motor vehicle which was proceeding northbound at or near 1600 South
Lake Shore Dr. in the City of Chicago, County of Cook, and State of Illinois.
2. That on the above said date, the Defendant, DWAYNE T. KENNEDY, was an
operator of a motor vehicle which was proceeding northbound at or near 1600 South Lake Shore
Dr. in the City of Chicago, County of Cook, and State of Illinois.
3. That at all times pertinent hereto, it was the duty of the Defendant to exercise
ordinary care for the safety of the Plaintiff.
4. That at the time of the accident, the Plaintiff’s vehicle was at a complete stop.
5. That at the time of the accident, the Defendant’s vehicle rear ended the Plaintiff's
vehicle.
6. That notwithstanding said duty, the Defendant was guilty of one or more of the
following negligent acts or omissions:
a. Failed to yield the right of way;
b. Failed to maintain a safe distance from the vehicle immediately in his path of
travel;
c. Failed to decrease the speed of said motor vehicle;
d. Proceeded at a speed which was greater than reasonable and proper with regard to
traffic conditions, which endangered the safety of the Plaintiff;
e. Failed to keep said motor vehicle under proper control;
f. Failed to take proper evasive action to avoid a collision once it became imminent;
FILED DATE: 5/15/2024 3:13 PM 2024L005416
g. Failed to warn the Plaintiff by honking his horn;
h. Operated said motor vehicle without keeping a proper and sufficient lookout; and
i. Followed too close for conditions.
7. That as a direct and proximate result of one or more of the aforementioned
negligent acts or omissions of the Defendant, the Defendant’s motor vehicle collided with
Plaintiff’s vehicle resulting in the Plaintiff sustaining injury to various portions of her body,
requiring her to expend money for medical care and treatment, resulting in her experiencing pain,
suffering, and mental anguish both now and in the future, property damage to vehicle, resulting
in her becoming both temporarily and permanently disabled and disfigured, and resulting in out
of pocket expenses.
WHEREFORE, Plaintiff, WIDLINE MICHAELLE TASSY, prays for judgment against
the Defendant, DWAYNE T. KENNEDY, in a sum in excess of fifty thousand dollars
($50,000.00) plus costs for Plaintiff.
ELMAN JOSEPH LAW GROUP, LLC
By: ANTHONY R. ELMAN
ANTHONY R. ELMAN
Attorney for Plaintiff
ELMAN JOSEPH LAW GROUP, LLC #32429
212 W. WASHINGTON, SUITE 1208
CHICAGO, IL 60606
Phone: (312) 739-2159
Email: elmanlawgroup.court@gmail.com
2
AFFIDAVIT AND VERIFICATION PURSUANT TO S. CT. RULE 222 (B)
FILED DATE: 5/15/2024 3:13 PM 2024L005416
I, ANTHONY R. ELMAN, an attorney for the Plaintiff, state on oath that I am
familiar with the facts relating to the above captioned matter. That the allegations contained
in the Complaint are true and the nature and extent of Plaintiff's injuries are such that the
claim has a value in excess of $50,000.00, pursuant to S. Ct. Rule 222 (B).
ANTHONY R. ELMAN
ANTHONY R. ELMAN
3
Preview
Law Division Motion Section Initial Case Management Dates for CALENDARS (A,B,C,D,E,F,H,R,X,Z) will be heard In Person. All other Law Division Initial Case Management Dates will be heard via Zoom For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12 Court Date: 7/17/2024 10:30 AM FILED IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 5/15/2024 3:13 PM IRIS Y. MARTINEZ COUNTY DEPARTMENT, LAW DIVISION CIRCUIT CLERK COOK COUNTY, IL FILED DATE: 5/15/2024 3:13 PM 2024L005416 WIDLINE MICHAELLE TASSY 2024L005416 Plaintiff, Calendar, B vs. No. 27708666 DWAYNE T. KENNEDY Amount Claimed: in excess Defendant, of $50,000.00 PLUS COSTS COMPLAINT NOW COMES the Plaintiff, WIDLINE MICHAELLE TASSY, by her attorneys, ELMAN JOSEPH LAW GROUP, LLC, and in complaining of the Defendant, DWAYNE T. KENNEDY, states as follows: 1. That on July 28, 2022, the Plaintiff, WIDLINE MICHAELLE TASSY, was an operator and owner of a motor vehicle which was proceeding northbound at or near 1600 South Lake Shore Dr. in the City of Chicago, County of Cook, and State of Illinois. 2. That on the above said date, the Defendant, DWAYNE T. KENNEDY, was an operator of a motor vehicle which was proceeding northbound at or near 1600 South Lake Shore Dr. in the City of Chicago, County of Cook, and State of Illinois. 3. That at all times pertinent hereto, it was the duty of the Defendant to exercise ordinary care for the safety of the Plaintiff. 4. That at the time of the accident, the Plaintiff’s vehicle was at a complete stop. 5. That at the time of the accident, the Defendant’s vehicle rear ended the Plaintiff's vehicle. 6. That notwithstanding said duty, the Defendant was guilty of one or more of the following negligent acts or omissions: a. Failed to yield the right of way; b. Failed to maintain a safe distance from the vehicle immediately in his path of travel; c. Failed to decrease the speed of said motor vehicle; d. Proceeded at a speed which was greater than reasonable and proper with regard to traffic conditions, which endangered the safety of the Plaintiff; e. Failed to keep said motor vehicle under proper control; f. Failed to take proper evasive action to avoid a collision once it became imminent; FILED DATE: 5/15/2024 3:13 PM 2024L005416 g. Failed to warn the Plaintiff by honking his horn; h. Operated said motor vehicle without keeping a proper and sufficient lookout; and i. Followed too close for conditions. 7. That as a direct and proximate result of one or more of the aforementioned negligent acts or omissions of the Defendant, the Defendant’s motor vehicle collided with Plaintiff’s vehicle resulting in the Plaintiff sustaining injury to various portions of her body, requiring her to expend money for medical care and treatment, resulting in her experiencing pain, suffering, and mental anguish both now and in the future, property damage to vehicle, resulting in her becoming both temporarily and permanently disabled and disfigured, and resulting in out of pocket expenses. WHEREFORE, Plaintiff, WIDLINE MICHAELLE TASSY, prays for judgment against the Defendant, DWAYNE T. KENNEDY, in a sum in excess of fifty thousand dollars ($50,000.00) plus costs for Plaintiff. ELMAN JOSEPH LAW GROUP, LLC By: ANTHONY R. ELMAN ANTHONY R. ELMAN Attorney for Plaintiff ELMAN JOSEPH LAW GROUP, LLC #32429 212 W. WASHINGTON, SUITE 1208 CHICAGO, IL 60606 Phone: (312) 739-2159 Email: elmanlawgroup.court@gmail.com 2 AFFIDAVIT AND VERIFICATION PURSUANT TO S. CT. RULE 222 (B) FILED DATE: 5/15/2024 3:13 PM 2024L005416 I, ANTHONY R. ELMAN, an attorney for the Plaintiff, state on oath that I am familiar with the facts relating to the above captioned matter. That the allegations contained in the Complaint are true and the nature and extent of Plaintiff's injuries are such that the claim has a value in excess of $50,000.00, pursuant to S. Ct. Rule 222 (B). ANTHONY R. ELMAN ANTHONY R. ELMAN 3