COMES NOW, the plaintiff, JUSTIN KING, by and for his complaint against ANHEUSER-BUSCH COMPANIES, INC. and ANHEUSER-BUSCH – INBEV (collectively Anheuser-Busch), defendant, alleges as follows:
1.1 The plaintiff resides in Kansas City, Missouri.
1.2 The defendant Anheuser-Busch Companies, Inc., is a corporation organized and existing under the laws of the State of Missouri, with its principal place of business being in the State of Missouri. The defendant Anheuser-Busch Companies, Inc. is a foreign corporation and not a resident of Illinois. Further, the defendant Anheuser-Busch, Companies, Inc., is authorized to, and in fact does, business in the State of Illinois.
JURISDICTION AND VENUE
2.1 This court has jurisdiction over the subject matter of this action because the amount in controversy exceeds $75,000.00, exclusive of costs.
2.2 Venue in the United States District Court for the Central District of Illinois is proper as because the event giving rise to the plaintiff’s claim occurred in the judicial district as a result of the defendant’s business ventures inside this state.
3.1 On April 8, 2004, plaintiff Justin King was riding his motorcycle in the left lane of Interstate 57.
3.2 At that time, an Anheuser Busch beer truck came up from behind him and signaled to pass by flashing his headlights.
3.3 Justin changed lanes to allow the truck to pass, as the defendant was passing, cases of beer fell from the truck onto the interstate where Justin was riding his motorcycle.
3.4 Justin swerved to avoid the beer, thus hitting the back of the truck.