Fill and Sign the Damages Vehicle Form

Complaint- Verified (This form replaces CCMI>-8A) CCM N008-50M-2/25/05 ( ) IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS _________________________________ No. ___________________________ (Name of Plaintiff)V. Contract _ ____________________ ____________________________ Amount Claimed $ _____________________ ________________________________ Return Date _____________________ (Name of Defendants) COMPLAINT The Plaintiff claims as follows: 1. Plaintiff _______________________________ (Name of Plaintiff) is, and at all times mentioned in this Complaint was, a resident of ___________________________________________ ________________________________________________________________________________ _ (street address, city, county, state, zip code) . 2. Defendant-Employee _______________________________________ (Name of Defendant- Employee) is, and at all times mentioned in this Complaint was, a resident of __________________ ________________________________________________________________________________ _ (street address, city, county, state, zip code) . 3. Defendant-Owner _____________________________________ (Name of Defendant- Owner) is, and at all times mentioned in this Complaint was, a resident of _____________________ ________________________________________________________________________________ _ (street address, city, county, state, zip code) . 4. At all times mentioned, Defendant-Owner owned, managed, and operated an automobile repair garage known as _______________________________ (Name) located at _______________ ________________________________________________________________________________ _ (street address, city, county, state, zip code) . In connection with the operation of hi garage, Defendant-Owner operated and maintained a number of tow trucks for the towing of customers' disabled automobiles. 5. At all times mentioned, Defendant-Employee was employed by Defendant-Owner as a mechanic and tow truck operator and, in doing the things alleged in this Complaint , was acting within the course and scope of that employment. 6. At all times mentioned, Plaintiff was the owner of a (describe automobile, giving year, make, and model , serial number, license number) _______________________________________ ________________________________________________________________________________ ________________________________________________________________________________ _. 7. On _______________________ (date) , at ____________ (time) , Plaintiff was driving Plaintiff's automobile on _________________ (road) in ___________________________________ (Name of City, County) , when suddenly and without warning it stopped running. Plaintiff telephoned Defendant-Owner and requested that Defendant-Owner send a tow truck to tow Plaintiff's automobile to Defendant-Owner ’ s garage for repairs. In response, Defendant-Owner dispatched Defendant-Employee to tow Plaintiff's automobile. 8. On arrival at Plaintiff's location, Defendant-Employee connected the tow truck lifting device to Plaintiff's automobile and towed the automobile to Defendant-Owner . When Defendant-Employee and Plaintiff arrived at Defendant-Owner’s garage, Plaintiff discovered that Plaintiff's automobile had sustained the following damage while being towed to the garage: ( describe damage) ________________________________________________________________________________ ________________________________________________________________________________ _ . 9. Defendants, in undertaking to tow Plaintiff's automobile to Defendant-Owner ’ s garage, owed to Plaintiff a duty to exercise due care in doing so. 10. Defendants, in breach of the duty described above, negligently and carelessly (describe negligent conduct) ________________________________________________________________ ________________________________________________________________________________ ________________________________________________________________________________ _ . 11. As a direct and proximate result of the negligence and carelessness of Defendants, Plaintiff's automobile was damaged as described above. 12. As a further direct and proximate result of the negligence and carelessness of Defendants as described above, Plaintiff was required to expend the sum of $_____________ in repairing Plaintiff's automobile; lost the use of Plaintiff's automobile for a period of ______ (number) weeks; and was required to expend the sum of $____________ for alternate transportation during the time Plaintiff's automobile was being repaired, all to Plaintiff's damage in the sum of $_____________. Wherefore, Plaintiff requests that the court: 1. Award Plaintiff damages in the sum of $__________________; 2. Award Plaintiff the costs of this action; and 3. Award Plaintiff any other and further relief that the court considers proper. Respectfully submitted, _____________________________ ________________________________ _ Name and Signature of Plaintiff I, ______________________________________ (Name of Plaintiff), certify that I am the Plaintiff in the above entitled action. The allegations in this Complaint are true. Pro Se Plaintiff: Name: _____________________________________________ Address: _____________________________________________ ____________________________________________________ City/State/Zip: ____________________________________________________ Date: _______________________ ___________________________________ _______________________________________ Name and Signature of Plaintiff _____ Under penalties as provided by law pursuant to 735 ILCS 5/1-109 the above signed certifies that the statements set forth herein are true and correct.