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 11:00 AM FILED
5/17/2024 8:45 AM
IRIS Y. MARTINEZ
THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS CIRCUIT CLERK
COOK COUNTY, IL
COUNTY DEPARTMENT, LAW DIVISION
FILED DATE: 5/17/2024 8:45 AM 2024L005483
2024L005483
WAHEEP A. AHMED, ) Calendar, B
27735875
)
Plaintiff, )
)
v. ) Case No.: 2024L005483
)
)
ROMILIO GALINDO, ) Jury Trial Demanded.
)
Defendant. )
COMPLAINT AT LAW
NOW COMES the Plaintiff, WAHEEP A. AHMED, by and through his attorneys,
SHERWOOD LAW GROUP, LLC, and in his Complaint at Law against the Defendant,
ROMILIO GALINDO, hereby states as follows:
1. That on or about September 13, 2023, and at all times relevant herein, Plaintiff,
WAHEEP A. AHMED, was the owner and operator of a certain motor vehicle to which he was
operating eastbound on W. 79th Street, at or near its intersection with S. Central Park Avenue, in
the City of Chicago, County of Cook, and State of Illinois.
2. That on or about September 13, 2023, and at all times relevant herein, the
Defendant, ROMILIO GALINDO, was the owner and operator of a certain motor vehicle to
which he was operating westbound on W. 79th Street, at or near its intersection with S. Central
Park Avenue, in the City of Chicago, County of Cook, and State of Illinois.
3. That on or about September 13, 2023, and at all times relevant herein, the
Plaintiff, WAHEEP A. AHMED, was in the exercise of ordinary care and caution for his own
safety and property.
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4. That it then and there became and was the duty of Defendant, ROMILIO
GALINDO, to operate said motor vehicle with due care and caution, in accordance with the
FILED DATE: 5/17/2024 8:45 AM 2024L005483
Statutes of the State of Illinois and Ordinances of the City of Chicago, for the safety and
protection of the Plaintiff, WAHEEP A. AHMED, and others then and there present.
5. At said time and place, Defendant, ROMILIO GALINDO, negligently and
carelessly drove his motor vehicle to cause it to collide with the motor vehicle driven by
Plaintiff, WAHEEP A. AHMED.
6. That not regarding her duty aforesaid, the Defendant, ROMILIO GALINDO, was
then and there guilty of one or more of the following careless and negligent acts and/or
omissions:
a. Failed to sound horn or otherwise give timely warning, contrary to and in
violation of the provisions of 625 ILCS 5/12-601;
b. Failed to reduce speed to avoid an accident, contrary to and in violation of the
provisions of 625 ILCS 5/11-601;
c. Operated said motor vehicle without sufficient lights in violation of the provisions
of 625 ILCS 5/12-201;
d. Operated said motor vehicle with faulty and defective brakes, contrary to and
violation of the provisions of 625 ILCS 5/12-301;
e. Operated a non-hands-free cellular device while operating a motor vehicle which
caused a collision;
f. Failed to maintain a proper and sufficient lookout;
g. Failed to keep proper and necessary control over the Defendant’s motor vehicle;
h. Operated said motor vehicle too closely to the motor vehicle in front of her;
i. Failed to leave sufficient space between Defendant’s motor vehicle and the
Plaintiff’s motor vehicle;
j. Failed to take reasonable corrective action under the circumstances to avoid a
causing the collision;
k. Failed to yield the right of way to Plaintiff’s vehicle and other vehicles pursuant
to traffic conditions;
l. Failed to conduct a proper lane change;
m. Failed to abide with a traffic control device wherein Defendant caused a T-bone
accident with Plaintiff;
n. Failed to use turn signal indicator when merging in traffic and changing lanes;
o. Failed to adhere to traffic conditions causing an accident; and
p. Was otherwise careless and negligent in the operation of said motor vehicle.
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7. That as a direct and proximate result of the aforesaid, the Plaintiff, WAHEEP A.
AHMED, suffered diverse injuries, both internally and externally, of a permanent and lasting
FILED DATE: 5/17/2024 8:45 AM 2024L005483
nature, which have caused and will continue to cause pain in body and mind; and the Plaintiff,
WAHEEP A. AHMED, was caused to expend and in the future will be compelled to expend, large
sums of money for medical care, treatment and services in endeavoring to be cured of said injuries;
and the Plaintiff suffered and will continue to suffer in the future acute and prolonged physical and
mental pain and suffering; the Plaintiff has suffered and will continue to suffer in the future
permanent disfigurement and/or disability; the Plaintiff has experienced and will continue to
experience in the future loss of a normal life; the Plaintiff was caused to expend large sums of
money in endeavoring to repair and/or replace property damage and/or loss from said collision;
the Plaintiff was caused to and in the future will lose much time from his employment, thereby
incurring losses of large sums of money and the Plaintiff has been and in the future will be
prevented from attending to his usual affairs and duties.
WHEREFORE, Plaintiff, WAHEEP A. AHMED, by and through his attorneys,
SHERWOOD LAW GROUP, LLC, hereby prays for judgment against Defendant, for a sum of
money in excess of FIFTY THOUSAND DOLLARS [$50,000.00] and such additional amounts as
the jury and the Court shall deem proper and appropriate under the circumstances provided
herein, inclusive of the costs of bringing this action.
Respectfully Submitted,
SHERWOOD LAW GROUP, LLC
Keegan E. Finn / s
_______________________________
KEEGAN E. FINN
Attorney for Plaintiff
kef@sherwoodlawgroup.com
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FILED DATE: 5/17/2024 8:45 AM 2024L005483
JASON H. SHERWOOD
KEEGAN E. FINN
SHERWOOD LAW GROUP, LLC
218 N. Jefferson Street
Suite #401
Chicago, Illinois 60661
Phone: 312.627.1650
Fax: 312.648.9503
Attorney No. 47294
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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 11:00 AM FILED 5/17/2024 8:45 AM IRIS Y. MARTINEZ THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS CIRCUIT CLERK COOK COUNTY, IL COUNTY DEPARTMENT, LAW DIVISION FILED DATE: 5/17/2024 8:45 AM 2024L005483 2024L005483 WAHEEP A. AHMED, ) Calendar, B 27735875 ) Plaintiff, ) ) v. ) Case No.: 2024L005483 ) ) ROMILIO GALINDO, ) Jury Trial Demanded. ) Defendant. ) COMPLAINT AT LAW NOW COMES the Plaintiff, WAHEEP A. AHMED, by and through his attorneys, SHERWOOD LAW GROUP, LLC, and in his Complaint at Law against the Defendant, ROMILIO GALINDO, hereby states as follows: 1. That on or about September 13, 2023, and at all times relevant herein, Plaintiff, WAHEEP A. AHMED, was the owner and operator of a certain motor vehicle to which he was operating eastbound on W. 79th Street, at or near its intersection with S. Central Park Avenue, in the City of Chicago, County of Cook, and State of Illinois. 2. That on or about September 13, 2023, and at all times relevant herein, the Defendant, ROMILIO GALINDO, was the owner and operator of a certain motor vehicle to which he was operating westbound on W. 79th Street, at or near its intersection with S. Central Park Avenue, in the City of Chicago, County of Cook, and State of Illinois. 3. That on or about September 13, 2023, and at all times relevant herein, the Plaintiff, WAHEEP A. AHMED, was in the exercise of ordinary care and caution for his own safety and property. 1 4. That it then and there became and was the duty of Defendant, ROMILIO GALINDO, to operate said motor vehicle with due care and caution, in accordance with the FILED DATE: 5/17/2024 8:45 AM 2024L005483 Statutes of the State of Illinois and Ordinances of the City of Chicago, for the safety and protection of the Plaintiff, WAHEEP A. AHMED, and others then and there present. 5. At said time and place, Defendant, ROMILIO GALINDO, negligently and carelessly drove his motor vehicle to cause it to collide with the motor vehicle driven by Plaintiff, WAHEEP A. AHMED. 6. That not regarding her duty aforesaid, the Defendant, ROMILIO GALINDO, was then and there guilty of one or more of the following careless and negligent acts and/or omissions: a. Failed to sound horn or otherwise give timely warning, contrary to and in violation of the provisions of 625 ILCS 5/12-601; b. Failed to reduce speed to avoid an accident, contrary to and in violation of the provisions of 625 ILCS 5/11-601; c. Operated said motor vehicle without sufficient lights in violation of the provisions of 625 ILCS 5/12-201; d. Operated said motor vehicle with faulty and defective brakes, contrary to and violation of the provisions of 625 ILCS 5/12-301; e. Operated a non-hands-free cellular device while operating a motor vehicle which caused a collision; f. Failed to maintain a proper and sufficient lookout; g. Failed to keep proper and necessary control over the Defendant’s motor vehicle; h. Operated said motor vehicle too closely to the motor vehicle in front of her; i. Failed to leave sufficient space between Defendant’s motor vehicle and the Plaintiff’s motor vehicle; j. Failed to take reasonable corrective action under the circumstances to avoid a causing the collision; k. Failed to yield the right of way to Plaintiff’s vehicle and other vehicles pursuant to traffic conditions; l. Failed to conduct a proper lane change; m. Failed to abide with a traffic control device wherein Defendant caused a T-bone accident with Plaintiff; n. Failed to use turn signal indicator when merging in traffic and changing lanes; o. Failed to adhere to traffic conditions causing an accident; and p. Was otherwise careless and negligent in the operation of said motor vehicle. 2 7. That as a direct and proximate result of the aforesaid, the Plaintiff, WAHEEP A. AHMED, suffered diverse injuries, both internally and externally, of a permanent and lasting FILED DATE: 5/17/2024 8:45 AM 2024L005483 nature, which have caused and will continue to cause pain in body and mind; and the Plaintiff, WAHEEP A. AHMED, was caused to expend and in the future will be compelled to expend, large sums of money for medical care, treatment and services in endeavoring to be cured of said injuries; and the Plaintiff suffered and will continue to suffer in the future acute and prolonged physical and mental pain and suffering; the Plaintiff has suffered and will continue to suffer in the future permanent disfigurement and/or disability; the Plaintiff has experienced and will continue to experience in the future loss of a normal life; the Plaintiff was caused to expend large sums of money in endeavoring to repair and/or replace property damage and/or loss from said collision; the Plaintiff was caused to and in the future will lose much time from his employment, thereby incurring losses of large sums of money and the Plaintiff has been and in the future will be prevented from attending to his usual affairs and duties. WHEREFORE, Plaintiff, WAHEEP A. AHMED, by and through his attorneys, SHERWOOD LAW GROUP, LLC, hereby prays for judgment against Defendant, for a sum of money in excess of FIFTY THOUSAND DOLLARS [$50,000.00] and such additional amounts as the jury and the Court shall deem proper and appropriate under the circumstances provided herein, inclusive of the costs of bringing this action. Respectfully Submitted, SHERWOOD LAW GROUP, LLC Keegan E. Finn / s _______________________________ KEEGAN E. FINN Attorney for Plaintiff kef@sherwoodlawgroup.com 3 FILED DATE: 5/17/2024 8:45 AM 2024L005483 JASON H. SHERWOOD KEEGAN E. FINN SHERWOOD LAW GROUP, LLC 218 N. Jefferson Street Suite #401 Chicago, Illinois 60661 Phone: 312.627.1650 Fax: 312.648.9503 Attorney No. 47294 4