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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: 8/6/2024 9:45 AM FILED
6/4/2024 11:19 AM
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ
COUNTY DEPARTMENT, LAW DIVISION CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 6/4/2024 11:19 AM 2024L006065
2024L006065
LARRY Y. SMITH, ) Calendar, Z
) No. 27961068
Plaintiff, )
)
v. ) 2024L006065
)
UNIMARK LOWBOY TRANSPORTATION LLC and )
STEPHEN S. SHINN, )
)
Defendants. )
COMPLAINT AT LAW
NOW COMES Plaintiff, LARRY Y. SMITH, by and through his attorneys, Zayed Law
Offices, and complaining of Defendants, UNIMARK LOWBOY TRANSPORTATION LLC and
STEPHEN S. SHINN, states as follows:
GENERAL ALLEGATIONS TO ALL COUNTS
1. Plaintiff, LARRY Y. SMITH, is a resident of Burbank, Cook County, Illinois.
2. Defendant, UNIMARK LOWBOY TRANSPORTATION LLC, is incorporated in
Wisconsin.
3. Defendant, STEPHEN S. SHINN, is a resident of Loveland, Ohio.
COUNT I – NEGLIGENCE
UNIMARK LOWBOY TRANSPORTATION LLC
1. That on July 15, 2022, Plaintiff, LARRY Y. SMITH (“SMITH”), was operating a
motor vehicle headed eastbound on Interstate 80, at or near milepost 20, in Geneseo Township,
Henry County, Illinois.
2. That on July 15, 2022, at all times material, Defendant, UNIMARK LOWBOY
TRANSPORTATION LLC (“UNIMARK”), by and through its principal, agent, apparent agent
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and/or employee, STEPHEN S. SHINN (“SHINN”), owned, operated, managed, maintained
and/or controlled a semi-truck headed eastbound on Interstate 80, at or near milepost 20, in
FILED DATE: 6/4/2024 11:19 AM 2024L006065
Geneseo Township, Henry County, Illinois.
3. That on July 15, 2022, at all times material, SHINN was a principal, agent, apparent
agent and/or employee of UNIMARK.
4. That on July 15, 2022, at all times material, SHINN was acting in the scope of his
employment with UNIMARK.
5. That a collision occurred when the semi-truck being operated by SHINN struck the
rear of the motor vehicle being operated by SMITH.
6. That on July 15, 2022, Defendant, UNIMARK, by and through its principal, agent,
apparent agent and/or employee, SHINN, owed a duty to Plaintiff, SMITH, to exercise reasonable
care in the operation of Defendant’s semi-truck.
7. That at the aforesaid time and place, Defendant, UNIMARK, by and through its
principal, agent, apparent agent and/or employee, SHINN, breached that duty and was negligent
in one or more of the following respects:
a. failed to maintain proper control of his semi-truck;
b. failed to keep a proper lookout;
c. was driving too fast for conditions;
d. failed to yield the right-of-way;
e. followed too closely;
f. failed to change the course of his vehicle, or to reduce its speed,
as to avoid a collision.
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8. That as a direct and proximate result of one or more of the aforementioned negligent
acts or omissions, Plaintiff, SMITH, has suffered injuries of a permanent, personal, and pecuniary
FILED DATE: 6/4/2024 11:19 AM 2024L006065
nature.
WHEREFORE, Plaintiff, LARRY Y. SMITH, demands judgment against Defendant,
UNIMARK LOWBOY TRANSPORTATION LLC, for an amount in excess of $50,000.00,
together with the costs of this action.
COUNT II – NEGLIGENCE
STEPHEN S. SHINN
1. That on July 15, 2022, Plaintiff, LARRY Y. SMITH (“SMITH”), was operating a
motor vehicle headed eastbound on Interstate 80, at or near milepost 20, in Geneseo Township,
Henry County, Illinois.
2. That on July 15, 2022, at all times material, Defendant, STEPHEN S. SHINN
(“SHINN”), operated, managed, maintained and/or controlled a semi-truck headed eastbound on
Interstate 80, at or near milepost 20, in Geneseo Township, Henry County, Illinois.
3. That a collision occurred when the semi-truck being operated by SHINN struck the
rear of the motor vehicle being operated by SMITH.
4. That on July 15, 2022, Defendant, SHINN, owed a duty to Plaintiff, SMITH, to
exercise reasonable care in the operation of Defendant’s semi-truck.
5. That at the aforesaid time and place, Defendant, SHINN, breached that duty and
was negligent in one or more of the following respects:
a. failed to maintain proper control of his motor vehicle;
b. failed to keep a proper lookout;
c. was driving too fast for conditions;
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d. failed to yield the right-of-way;
e. followed too closely;
FILED DATE: 6/4/2024 11:19 AM 2024L006065
f. failed to change the course of his vehicle, or to reduce its speed,
as to avoid a collision.
6. That as a direct and proximate result of one or more of the aforementioned negligent
acts or omissions, Plaintiff, SMITH, has suffered injuries of a permanent, personal, and pecuniary
nature.
WHEREFORE, Plaintiff, LARRY Y. SMITH, demands judgment against Defendant,
STEPHEN S. SHINN, for an amount in excess of $50,000.00, together with the costs of this action.
Respectfully submitted,
/s/ Jeremy D. Lee
Adam J. Zayed – 6301240
Jeremy D. Lee – 6306416
ZAYED LAW OFFICES
195 Springfield Ave.
Joliet, IL 60435
Tel: 815.726.1616
Fax: 815.726.1779
service@zayedlaw.com
Firm Id. 46450
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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: 8/6/2024 9:45 AM FILED 6/4/2024 11:19 AM IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS IRIS Y. MARTINEZ COUNTY DEPARTMENT, LAW DIVISION CIRCUIT CLERK COOK COUNTY, IL FILED DATE: 6/4/2024 11:19 AM 2024L006065 2024L006065 LARRY Y. SMITH, ) Calendar, Z ) No. 27961068 Plaintiff, ) ) v. ) 2024L006065 ) UNIMARK LOWBOY TRANSPORTATION LLC and ) STEPHEN S. SHINN, ) ) Defendants. ) COMPLAINT AT LAW NOW COMES Plaintiff, LARRY Y. SMITH, by and through his attorneys, Zayed Law Offices, and complaining of Defendants, UNIMARK LOWBOY TRANSPORTATION LLC and STEPHEN S. SHINN, states as follows: GENERAL ALLEGATIONS TO ALL COUNTS 1. Plaintiff, LARRY Y. SMITH, is a resident of Burbank, Cook County, Illinois. 2. Defendant, UNIMARK LOWBOY TRANSPORTATION LLC, is incorporated in Wisconsin. 3. Defendant, STEPHEN S. SHINN, is a resident of Loveland, Ohio. COUNT I – NEGLIGENCE UNIMARK LOWBOY TRANSPORTATION LLC 1. That on July 15, 2022, Plaintiff, LARRY Y. SMITH (“SMITH”), was operating a motor vehicle headed eastbound on Interstate 80, at or near milepost 20, in Geneseo Township, Henry County, Illinois. 2. That on July 15, 2022, at all times material, Defendant, UNIMARK LOWBOY TRANSPORTATION LLC (“UNIMARK”), by and through its principal, agent, apparent agent 1 and/or employee, STEPHEN S. SHINN (“SHINN”), owned, operated, managed, maintained and/or controlled a semi-truck headed eastbound on Interstate 80, at or near milepost 20, in FILED DATE: 6/4/2024 11:19 AM 2024L006065 Geneseo Township, Henry County, Illinois. 3. That on July 15, 2022, at all times material, SHINN was a principal, agent, apparent agent and/or employee of UNIMARK. 4. That on July 15, 2022, at all times material, SHINN was acting in the scope of his employment with UNIMARK. 5. That a collision occurred when the semi-truck being operated by SHINN struck the rear of the motor vehicle being operated by SMITH. 6. That on July 15, 2022, Defendant, UNIMARK, by and through its principal, agent, apparent agent and/or employee, SHINN, owed a duty to Plaintiff, SMITH, to exercise reasonable care in the operation of Defendant’s semi-truck. 7. That at the aforesaid time and place, Defendant, UNIMARK, by and through its principal, agent, apparent agent and/or employee, SHINN, breached that duty and was negligent in one or more of the following respects: a. failed to maintain proper control of his semi-truck; b. failed to keep a proper lookout; c. was driving too fast for conditions; d. failed to yield the right-of-way; e. followed too closely; f. failed to change the course of his vehicle, or to reduce its speed, as to avoid a collision. 2 8. That as a direct and proximate result of one or more of the aforementioned negligent acts or omissions, Plaintiff, SMITH, has suffered injuries of a permanent, personal, and pecuniary FILED DATE: 6/4/2024 11:19 AM 2024L006065 nature. WHEREFORE, Plaintiff, LARRY Y. SMITH, demands judgment against Defendant, UNIMARK LOWBOY TRANSPORTATION LLC, for an amount in excess of $50,000.00, together with the costs of this action. COUNT II – NEGLIGENCE STEPHEN S. SHINN 1. That on July 15, 2022, Plaintiff, LARRY Y. SMITH (“SMITH”), was operating a motor vehicle headed eastbound on Interstate 80, at or near milepost 20, in Geneseo Township, Henry County, Illinois. 2. That on July 15, 2022, at all times material, Defendant, STEPHEN S. SHINN (“SHINN”), operated, managed, maintained and/or controlled a semi-truck headed eastbound on Interstate 80, at or near milepost 20, in Geneseo Township, Henry County, Illinois. 3. That a collision occurred when the semi-truck being operated by SHINN struck the rear of the motor vehicle being operated by SMITH. 4. That on July 15, 2022, Defendant, SHINN, owed a duty to Plaintiff, SMITH, to exercise reasonable care in the operation of Defendant’s semi-truck. 5. That at the aforesaid time and place, Defendant, SHINN, breached that duty and was negligent in one or more of the following respects: a. failed to maintain proper control of his motor vehicle; b. failed to keep a proper lookout; c. was driving too fast for conditions; 3 d. failed to yield the right-of-way; e. followed too closely; FILED DATE: 6/4/2024 11:19 AM 2024L006065 f. failed to change the course of his vehicle, or to reduce its speed, as to avoid a collision. 6. That as a direct and proximate result of one or more of the aforementioned negligent acts or omissions, Plaintiff, SMITH, has suffered injuries of a permanent, personal, and pecuniary nature. WHEREFORE, Plaintiff, LARRY Y. SMITH, demands judgment against Defendant, STEPHEN S. SHINN, for an amount in excess of $50,000.00, together with the costs of this action. Respectfully submitted, /s/ Jeremy D. Lee Adam J. Zayed – 6301240 Jeremy D. Lee – 6306416 ZAYED LAW OFFICES 195 Springfield Ave. Joliet, IL 60435 Tel: 815.726.1616 Fax: 815.726.1779 service@zayedlaw.com Firm Id. 46450 4