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 gppiZpg mM eeting IDs go to https.//wwwa
Court Date: 7/17/2024 10:30 AM
eggs AREY EOSIN? Zoor-Links?AaosO08
phe 175
5/16/2024 6:07 PM
STATE OF ILLINOIS ) IRIS Y. MARTINEZ
) CIRCUIT CLERK
COUNTY OF COOK ) COOK COUNTY, IL
2024L005477
IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS Calendar,
27732986
8
COUNTY DEPARTMENT, LAW DIVISION
YOLANDA TRAVIS
& KENDRA FOSTER,
Plaintiffs,
v. Court No.; 2024L005477
SHAREAL JOHNSON
& MICHELLE SHANTECE,
Defendants.
COMPLAINT AT LAW
NOW COMES the Plaintiffs, YOLANDA TRAVIS and KENDRA FOSTER, by
and through their attorneys, SHEA LAW GROUP, and for their complaint against the
Defendants, SHAREAL JOHNSON and MICHELLE SHANTECE, alleges as follows:
COUNT I
(Yolanda Travis v. Shareal Johnson)
1 That on or about the 4" day of December 2023, the Plaintiff, YOLANDA.
TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a
generally westbound direction on 88" Street, at its intersection with Cregier Avenue, in the
City of Chicago, County of Cook, and State of Illinois.
2 That on the aforementioned date, the Defendant, SHAREAL JOHNSON
was the operator and/or owner of a certain motor vehicle, which was being driven in a
generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the
City of Chicago, County of Cook, and State of Illinois.
3 That at said time and place, Defendant disobeyed traffic signal and/or stop
sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross-
traffic on 88" Street for eastbound or westbound traffic.
4. That at said time and place, a collision occurred between the motor vehicle
of the Defendant and the motor vehicle of the Plaintiff.
5 That on the aforementioned date, the Defendant was under a duty to exercise
due care and caution for her own safety and for the safety of others.
6 That the Defendant, SHAREAL JOHNSON, committed one or more of the
following negligent acts or omissions:
a) Failed to exercise due care in the operation of said motor
vehicle;
b) Drove said motor vehicle at a speed greater than was
reasonable and proper, with regard to traffic conditions, or so
as to endanger the life and limb of persons on said public
highway, contrary to and in violation of 625 ILCS 5/11-601;
c) Failed to have said motor vehicle equipped with brakes
adequate to control its movement and to stop and hold it,
contrary to and in violation of 625 ILCS 5/12-301;
qd) Failed to stop or slacken in speed when danger to Plaintiff
was imminent;
e) Failed to give any warning signal to the Plaintiff by sounding
said motor vehicle’s horn;
Failed to keep a proper and sufficient lookout for adverse
vehicles;
8) Failed to yield the right of way to cross-traffic on Addison
Street, including the vehicle of the Plaintiff herein, which did
not have a stop sign for eastbound or westbound traffic;
h) Failed to obey traffic signal and/or stop sign; and
i) Drive while distracted and/or looking away from the road.
1
As a proximate result of one or more of the aforesaid negligent acts and/or
omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and
pecuniary nature.
8 As a further direct and proximate result of the aforesaid injuries, the
Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement,
loss of a normal life, has incurred legal obligations for medical bills and has suffered lost
earnings and lost earning capacity, all of which injuries and conditions are permanent in
nature.
WHEREFORE the Plaintiff, YOLANDA TRAVIS, asks for judgment against the
Defendant, SHAREAL JOHNSON, of a sum in excess of Fifty Thousand Dollars
($50,000.00) plus the costs of this action, and for any and all additional relief this court
deems just.
COUNT Il
(Yolanda Travis v. Michelle Shantece)
1 That on or about the 4" day of December 2023, the Plaintiff, YOLANDA
TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a
generally westbound direction on 88" Street, at its intersection with Cregier Avenue, in the
City of Chicago, County of Cook, and State of Illinois.
2 That on the aforementioned date, the Defendant, SHAREAL JOHNSON
was the operator and/or owner of a certain motor vehicle, which was being driven in a
generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the
City of Chicago, County of Cook, and State of Illinois.
3 That at said time and place, Defendant disobeyed traffic signal and/or stop
sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross-
traffic on 88" Street for eastbound or westbound traffic.
4 That at said time and place, a collision occurred between the motor vehicle
of the Defendant and the motor vehicle of the Plaintiff.
5 That on the aforementioned date, the Co-Defendant, MICHELLE
SHANTECE, was the owner of said motor vehicle which was being operated by Defendant,
SHAREAL JOHNSON.
6 At all times relevant, the Defendant, SHAREAL JOHNSON, was an agent
of, and or acting with permission and furtherance of the interests of Co-Defendant,
MICHELLE SHANTECE.
7 That on the aforementioned date, the Defendant was under a duty to exercise
due care and caution for her own safety and for the safety of others.
8 That the Defendant, MICHELLE SHANTECE, committed one or more of
the following negligent acts or omissions:
a) Failed to exercise due care in the operation of said motor
vehicle;
b) Drove said motor vehicle at a speed greater than was
reasonable and proper, with regard to traffic conditions, or so
as to endanger the life and limb of persons on said public
highway, contrary to and in violation of 625 ILCS 5/11-601;
¢) Failed to have said motor vehicle equipped with brakes
adequate to control its movement and to stop and hold it,
contrary to and in violation of 625 ILCS 5/12-301;
d) Failed to stop or slacken in speed when danger to Plaintiff
was imminent;
8) Failed to give any warning signal to the Plaintiff by sounding
said motor vehicle’s horn;
Failed to keep a proper and sufficient lookout for adverse
vehicles;
8) Failed to yield the right of way to cross-traffic on Addison
Street, including the vehicle of the Plaintiff herein, which did
not have a stop sign for eastbound or westbound traffic;
h) Failed to obey traffic signal and/or stop sign; and
i) Drive while distracted and/or looking away from the road.
9 As a proximate result of one or more of the aforesaid negligent acts and/or
omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and
pecuniary nature.
10. As a further direct and proximate result of the aforesaid injuries, the
Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement,
loss of a normal life, has incurred legal obligations for medical bills and has suffered lost
earnings and lost earning capacity, all of which injuries and conditions are permanent in
nature.
WHEREFORE the Plaintiff, YOLANDA TRAVIS, asks for judgment against the
Defendant, MICHELLE SHANTECE, of a sum in excess of Fifty Thousand Dollars
($50,000.00) plus the costs of this action, and for any and all additional relief this court
deems just.
COUNT DT
(Kendra Foster vy. Shareal Johnson)
1 That on or about the 4th day of December 2023, the Plaintiff, YOLANDA
TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a
generally westbound direction on 88th Street, at its intersection with Cregier Avenue, in
the City of Chicago, County of Cook, and State of Illinois.
2 That on the aforementioned date, Co-Plaintiff, KENDRA FOSTER, was a
passenger in said vehicle driven by YOLANDA TRAVIS.
3 That on the aforementioned date, the Defendant, SHAREAL JOHNSON
was the operator and/or owner of a certain motor vehicle, which was being driven in a
generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the
City of Chicago, County of Cook, and State of Illinois.
4 That at said time and place, Defendant disobeyed traffic signal and/or stop
sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross-
traffic on 88" Street for eastbound or westbound traffic.
5 That at said time and place, a collision occurred between the motor vehicle
of the Defendant and the motor vehicle of the Plaintiff.
6 That on the aforementioned date, the Defendant was under a duty to exercise
due care and caution for her own safety and for the safety of others.
1
That the Defendant, SHAREAL JOHNSON, committed one or more of the
following negligent acts or omissions:
a) Failed to exercise due care in the operation of said motor
vehicle;
b) Drove said motor vehicle at a speed greater than was
reasonable and proper, with regard to traffic conditions, or so
as to endanger the life and limb of persons on said public
highway, contrary to and in violation of 625 ILCS 5/11-601;
°) Failed to have said motor vehicle equipped with brakes
adequate to control its movement and to stop and hold it,
contrary to and in violation of 625 ILCS 5/12-301;
d) Failed to stop or slacken in speed when danger to Plaintiff
was imminent;
°) Failed to give any warning signal to the Plaintiff by sounding
said motor vehicle’s horn;
Failed to keep a proper and sufficient lookout for adverse
vehicles;
8) Failed to yield the right of way to cross-traffic on Addison
Street, including the vehicle of the Plaintiff herein, which did
not have a stop sign for eastbound or westbound traffic;
h) Failed to obey traffic signal and/or stop sign; and
i) Drive while distracted and/or looking away from the road.
8 As a proximate result of one or more of the aforesaid negligent acts and/or
omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and
pecuniary nature.
9 As a further direct and proximate result of the aforesaid injuries, the
Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement,
loss of a normal life, has incurred legal obligations for medical bills and has suffered lost
earnings and lost earning capacity, all of which injuries and conditions are permanent in
nature.
|
WHEREFORE the Plaintiff, KENDRA FOSTER, asks for judgment against the
Defendant, SHAREAL JOHNSON, of a sum in excess of Fifty Thousand Dollars
($50,000.00) plus the costs of this action, and for any and all additional relief this court
deems just.
COUNT II
(Kendra Foster vy. Michelle Shantece)
1 That on or about the 4" day of December 2023, the Plaintiff, YOLANDA
TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a
generally westbound direction on 88" Street, at its intersection with Cregier Avenue, in the
City of Chicago, County of Cook, and State of Illinois.
2 That on the aforementioned date, Co-Plaintiff, KENDRA FOSTER, was a
passenger in said vehicle driven by YOLANDA TRAVIS.
3 That on the aforementioned date, the Defendant, SHAREAL JOHNSON
was the operator and/or owner of a certain motor vehicle, which was being driven in a
generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the
City of Chicago, County of Cook, and State of Illinois.
4 That at said time and place, Defendant disobeyed traffic signal and/or stop
sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross-
traffic on 88" Street for eastbound or westbound traffic.
5 That at said time and place, a collision occurred between the motor vehicle
of the Defendant and the motor vehicle of the Plaintiff.
6 That on the aforementioned date, the Co-Defendant, MICHELLE
SHANTECE, was the owner of said motor vehicle which was being operated by Defendant,
SHAREAL JOHNSON.
7 At all times relevant, the Defendant, SHAREAL JOHNSON, was an agent
of, and or acting with permission and furtherance of the interests of Co-Defendant,
MICHELLE SHANTECE.
8 That on the aforementioned date, the Defendant was under a duty to exercise
f
due care and caution for her own safety and for the safety of others.
9 That the Defendant, MICHELLE SHANTECE, committed one or more of
the following negligent acts or omissions:
a) Failed to exercise due care in the operation of said motor
vehicle;
b) Drove said motor vehicle at a speed greater than was
reasonable and proper, with regard to traffic conditions, or so
as to endanger the life and limb of persons on said public
highway, contrary to and in violation of 625 ILCS 5/11-601;
c) Failed to have said motor vehicle equipped with brakes
adequate to control its movement and to stop and hold it,
contrary to and in violation of 625 ILCS 5/12-301;
qd) Failed to stop or slacken in speed when danger to Plaintiff
‘was imminent;
e) Failed to give any warning signal to the Plaintiff by sounding
said motor vehicle’s horn;
Failed to keep a proper and sufficient lookout for adverse
vehicles;
g) Failed to yield the right of way to cross-traffic on Addison
Street, including the vehicle of the Plaintiff herein, which did
not have a stop sign for eastbound or westbound traffic;
h) Failed to obey traffic signal and/or stop sign; and
i) Drive while distracted and/or looking away from the road.
10. As a proximate result of one or more of the aforesaid negligent acts and/or
omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and
pecuniary nature.
11. As a further direct and proximate result of the aforesaid injuries, the
Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement,
loss of a normal life, has incurred legal obligations for medical bills and has suffered lost
earnings and lost earning capacity, all of which injuries and conditions are permanent in
nature.
WHEREFORE the Plaintiff, KENDRA FOSTER, asks for judgment against the
Defendant, MICHELLE SHANTECE, of a sum in excess of Fifty Thousand Dollars
($50,000.00) plus the costs of this action, and for any and all additional relief this court
deems just.
submitted,
GROUP
MAD
SHEA LAW GROUP
Attorneys for Plaintiff
2400 N. Western Ave., 24 Floor
Chicago, IL 60647
773-365-0040
Attorney No.: 44998
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 gppiZpg mM eeting IDs go to https.//wwwa Court Date: 7/17/2024 10:30 AM eggs AREY EOSIN? Zoor-Links?AaosO08 phe 175 5/16/2024 6:07 PM STATE OF ILLINOIS ) IRIS Y. MARTINEZ ) CIRCUIT CLERK COUNTY OF COOK ) COOK COUNTY, IL 2024L005477 IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS Calendar, 27732986 8 COUNTY DEPARTMENT, LAW DIVISION YOLANDA TRAVIS & KENDRA FOSTER, Plaintiffs, v. Court No.; 2024L005477 SHAREAL JOHNSON & MICHELLE SHANTECE, Defendants. COMPLAINT AT LAW NOW COMES the Plaintiffs, YOLANDA TRAVIS and KENDRA FOSTER, by and through their attorneys, SHEA LAW GROUP, and for their complaint against the Defendants, SHAREAL JOHNSON and MICHELLE SHANTECE, alleges as follows: COUNT I (Yolanda Travis v. Shareal Johnson) 1 That on or about the 4" day of December 2023, the Plaintiff, YOLANDA. TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a generally westbound direction on 88" Street, at its intersection with Cregier Avenue, in the City of Chicago, County of Cook, and State of Illinois. 2 That on the aforementioned date, the Defendant, SHAREAL JOHNSON was the operator and/or owner of a certain motor vehicle, which was being driven in a generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the City of Chicago, County of Cook, and State of Illinois. 3 That at said time and place, Defendant disobeyed traffic signal and/or stop sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross- traffic on 88" Street for eastbound or westbound traffic. 4. That at said time and place, a collision occurred between the motor vehicle of the Defendant and the motor vehicle of the Plaintiff. 5 That on the aforementioned date, the Defendant was under a duty to exercise due care and caution for her own safety and for the safety of others. 6 That the Defendant, SHAREAL JOHNSON, committed one or more of the following negligent acts or omissions: a) Failed to exercise due care in the operation of said motor vehicle; b) Drove said motor vehicle at a speed greater than was reasonable and proper, with regard to traffic conditions, or so as to endanger the life and limb of persons on said public highway, contrary to and in violation of 625 ILCS 5/11-601; c) Failed to have said motor vehicle equipped with brakes adequate to control its movement and to stop and hold it, contrary to and in violation of 625 ILCS 5/12-301; qd) Failed to stop or slacken in speed when danger to Plaintiff was imminent; e) Failed to give any warning signal to the Plaintiff by sounding said motor vehicle’s horn; Failed to keep a proper and sufficient lookout for adverse vehicles; 8) Failed to yield the right of way to cross-traffic on Addison Street, including the vehicle of the Plaintiff herein, which did not have a stop sign for eastbound or westbound traffic; h) Failed to obey traffic signal and/or stop sign; and i) Drive while distracted and/or looking away from the road. 1 As a proximate result of one or more of the aforesaid negligent acts and/or omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and pecuniary nature. 8 As a further direct and proximate result of the aforesaid injuries, the Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement, loss of a normal life, has incurred legal obligations for medical bills and has suffered lost earnings and lost earning capacity, all of which injuries and conditions are permanent in nature. WHEREFORE the Plaintiff, YOLANDA TRAVIS, asks for judgment against the Defendant, SHAREAL JOHNSON, of a sum in excess of Fifty Thousand Dollars ($50,000.00) plus the costs of this action, and for any and all additional relief this court deems just. COUNT Il (Yolanda Travis v. Michelle Shantece) 1 That on or about the 4" day of December 2023, the Plaintiff, YOLANDA TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a generally westbound direction on 88" Street, at its intersection with Cregier Avenue, in the City of Chicago, County of Cook, and State of Illinois. 2 That on the aforementioned date, the Defendant, SHAREAL JOHNSON was the operator and/or owner of a certain motor vehicle, which was being driven in a generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the City of Chicago, County of Cook, and State of Illinois. 3 That at said time and place, Defendant disobeyed traffic signal and/or stop sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross- traffic on 88" Street for eastbound or westbound traffic. 4 That at said time and place, a collision occurred between the motor vehicle of the Defendant and the motor vehicle of the Plaintiff. 5 That on the aforementioned date, the Co-Defendant, MICHELLE SHANTECE, was the owner of said motor vehicle which was being operated by Defendant, SHAREAL JOHNSON. 6 At all times relevant, the Defendant, SHAREAL JOHNSON, was an agent of, and or acting with permission and furtherance of the interests of Co-Defendant, MICHELLE SHANTECE. 7 That on the aforementioned date, the Defendant was under a duty to exercise due care and caution for her own safety and for the safety of others. 8 That the Defendant, MICHELLE SHANTECE, committed one or more of the following negligent acts or omissions: a) Failed to exercise due care in the operation of said motor vehicle; b) Drove said motor vehicle at a speed greater than was reasonable and proper, with regard to traffic conditions, or so as to endanger the life and limb of persons on said public highway, contrary to and in violation of 625 ILCS 5/11-601; ¢) Failed to have said motor vehicle equipped with brakes adequate to control its movement and to stop and hold it, contrary to and in violation of 625 ILCS 5/12-301; d) Failed to stop or slacken in speed when danger to Plaintiff was imminent; 8) Failed to give any warning signal to the Plaintiff by sounding said motor vehicle’s horn; Failed to keep a proper and sufficient lookout for adverse vehicles; 8) Failed to yield the right of way to cross-traffic on Addison Street, including the vehicle of the Plaintiff herein, which did not have a stop sign for eastbound or westbound traffic; h) Failed to obey traffic signal and/or stop sign; and i) Drive while distracted and/or looking away from the road. 9 As a proximate result of one or more of the aforesaid negligent acts and/or omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and pecuniary nature. 10. As a further direct and proximate result of the aforesaid injuries, the Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement, loss of a normal life, has incurred legal obligations for medical bills and has suffered lost earnings and lost earning capacity, all of which injuries and conditions are permanent in nature. WHEREFORE the Plaintiff, YOLANDA TRAVIS, asks for judgment against the Defendant, MICHELLE SHANTECE, of a sum in excess of Fifty Thousand Dollars ($50,000.00) plus the costs of this action, and for any and all additional relief this court deems just. COUNT DT (Kendra Foster vy. Shareal Johnson) 1 That on or about the 4th day of December 2023, the Plaintiff, YOLANDA TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a generally westbound direction on 88th Street, at its intersection with Cregier Avenue, in the City of Chicago, County of Cook, and State of Illinois. 2 That on the aforementioned date, Co-Plaintiff, KENDRA FOSTER, was a passenger in said vehicle driven by YOLANDA TRAVIS. 3 That on the aforementioned date, the Defendant, SHAREAL JOHNSON was the operator and/or owner of a certain motor vehicle, which was being driven in a generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the City of Chicago, County of Cook, and State of Illinois. 4 That at said time and place, Defendant disobeyed traffic signal and/or stop sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross- traffic on 88" Street for eastbound or westbound traffic. 5 That at said time and place, a collision occurred between the motor vehicle of the Defendant and the motor vehicle of the Plaintiff. 6 That on the aforementioned date, the Defendant was under a duty to exercise due care and caution for her own safety and for the safety of others. 1 That the Defendant, SHAREAL JOHNSON, committed one or more of the following negligent acts or omissions: a) Failed to exercise due care in the operation of said motor vehicle; b) Drove said motor vehicle at a speed greater than was reasonable and proper, with regard to traffic conditions, or so as to endanger the life and limb of persons on said public highway, contrary to and in violation of 625 ILCS 5/11-601; °) Failed to have said motor vehicle equipped with brakes adequate to control its movement and to stop and hold it, contrary to and in violation of 625 ILCS 5/12-301; d) Failed to stop or slacken in speed when danger to Plaintiff was imminent; °) Failed to give any warning signal to the Plaintiff by sounding said motor vehicle’s horn; Failed to keep a proper and sufficient lookout for adverse vehicles; 8) Failed to yield the right of way to cross-traffic on Addison Street, including the vehicle of the Plaintiff herein, which did not have a stop sign for eastbound or westbound traffic; h) Failed to obey traffic signal and/or stop sign; and i) Drive while distracted and/or looking away from the road. 8 As a proximate result of one or more of the aforesaid negligent acts and/or omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and pecuniary nature. 9 As a further direct and proximate result of the aforesaid injuries, the Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement, loss of a normal life, has incurred legal obligations for medical bills and has suffered lost earnings and lost earning capacity, all of which injuries and conditions are permanent in nature. | WHEREFORE the Plaintiff, KENDRA FOSTER, asks for judgment against the Defendant, SHAREAL JOHNSON, of a sum in excess of Fifty Thousand Dollars ($50,000.00) plus the costs of this action, and for any and all additional relief this court deems just. COUNT II (Kendra Foster vy. Michelle Shantece) 1 That on or about the 4" day of December 2023, the Plaintiff, YOLANDA TRAVIS, was the owner and operator of a certain motor vehicle, which was traveling in a generally westbound direction on 88" Street, at its intersection with Cregier Avenue, in the City of Chicago, County of Cook, and State of Illinois. 2 That on the aforementioned date, Co-Plaintiff, KENDRA FOSTER, was a passenger in said vehicle driven by YOLANDA TRAVIS. 3 That on the aforementioned date, the Defendant, SHAREAL JOHNSON was the operator and/or owner of a certain motor vehicle, which was being driven in a generally southbound direction on Cregier Avenue, at its intersection with 88" Street, in the City of Chicago, County of Cook, and State of Illinois. 4 That at said time and place, Defendant disobeyed traffic signal and/or stop sign for southbound traffic on Cregier Avenue, and failed to yield the right of way to cross- traffic on 88" Street for eastbound or westbound traffic. 5 That at said time and place, a collision occurred between the motor vehicle of the Defendant and the motor vehicle of the Plaintiff. 6 That on the aforementioned date, the Co-Defendant, MICHELLE SHANTECE, was the owner of said motor vehicle which was being operated by Defendant, SHAREAL JOHNSON. 7 At all times relevant, the Defendant, SHAREAL JOHNSON, was an agent of, and or acting with permission and furtherance of the interests of Co-Defendant, MICHELLE SHANTECE. 8 That on the aforementioned date, the Defendant was under a duty to exercise f due care and caution for her own safety and for the safety of others. 9 That the Defendant, MICHELLE SHANTECE, committed one or more of the following negligent acts or omissions: a) Failed to exercise due care in the operation of said motor vehicle; b) Drove said motor vehicle at a speed greater than was reasonable and proper, with regard to traffic conditions, or so as to endanger the life and limb of persons on said public highway, contrary to and in violation of 625 ILCS 5/11-601; c) Failed to have said motor vehicle equipped with brakes adequate to control its movement and to stop and hold it, contrary to and in violation of 625 ILCS 5/12-301; qd) Failed to stop or slacken in speed when danger to Plaintiff ‘was imminent; e) Failed to give any warning signal to the Plaintiff by sounding said motor vehicle’s horn; Failed to keep a proper and sufficient lookout for adverse vehicles; g) Failed to yield the right of way to cross-traffic on Addison Street, including the vehicle of the Plaintiff herein, which did not have a stop sign for eastbound or westbound traffic; h) Failed to obey traffic signal and/or stop sign; and i) Drive while distracted and/or looking away from the road. 10. As a proximate result of one or more of the aforesaid negligent acts and/or omissions of the Defendant, the Plaintiff suffered injuries of a personal, permanent and pecuniary nature. 11. As a further direct and proximate result of the aforesaid injuries, the Plaintiff has experienced pain, suffering, emotional distress, disability, disfigurement, loss of a normal life, has incurred legal obligations for medical bills and has suffered lost earnings and lost earning capacity, all of which injuries and conditions are permanent in nature. WHEREFORE the Plaintiff, KENDRA FOSTER, asks for judgment against the Defendant, MICHELLE SHANTECE, of a sum in excess of Fifty Thousand Dollars ($50,000.00) plus the costs of this action, and for any and all additional relief this court deems just. submitted, GROUP MAD SHEA LAW GROUP Attorneys for Plaintiff 2400 N. Western Ave., 24 Floor Chicago, IL 60647 773-365-0040 Attorney No.: 44998