IN THE 22ND JUDICIAL CIRCUIT COURT OF
ST. LOUIS, MISSOURI
JUSTIN KING, ) ) Plaintiff, ) Civil Actions No.___________ v. )
ANHEUSER BUSCH, ) ) Defendant, ) ____________________ ) COMPLAINT
Comes now the plaintiff, Justin King, by and through his attorney and alleges as follows:
I. PARTIES 1. Plaintiff, Justin King, for all times mentioned herein, was and is a resident of Kansas…show more content… Plaintiff was injured as a direct result of the collision, the same having been directly and proximately caused by the negligent, wanton conduct of the defendant and by defendant’s total heedless and reckless disregard of the rights of others.
V. DAMAGES 16. By reason of said negligence and collision aforesaid, the plaintiff has suffered general, special, incidental and consequential damages as the direct and proximate result of the acts and omissions of the defendant, in an amount that shall be fully proven at the time to trial. These damages include injuries consisting of but not limited to, bruises, contusions, strain to all the muscles of his body, nine broken bones in plaintiff’s jaw and dislocation of his jaw, which had to be wired back together; the injuries thus received by plaintiff have greatly impaired his health, strength, and activity and have thereby caused and continue to cause him great mental, physical and nervous pain and suffering and extreme shock to plaintiff’s nervous system. These damages include, but are not limited to, damages for general pain and suffering, damages for loss of enjoyment of life, both past and future, medical and medical related expenses, both past and future, emotional distress, both past and future, both past and future, and all other ordinary, incidental, or consequential damages would or could be reasonably anticipated to arise under the circumstances.