COMPLAINT

             COMES NOW Plaintiff, Brian Lehnen, and for his Complaint against Defendant, Greyhound Lines, Inc., states as follows:

            1.         At the time of the subject incident the Plaintiff, Brian Lehnen, (hereinafter “Plaintiff”), was a resident of Illinois.

2.         Greyhound Lines, Inc., hereinafter (“Greyhound”) is business conducting and duly authorized to conduct business in the State of Illinois.  Additionally, Greyhound conducts business in Madison County, Illinois. 

            3.         The amount in controversy exceeds $50,000 exclusive of interest and costs.    

            4.         Venue is appropriate in Madison County, State of Illinois pursuant to 735 ILCS 5/2-101.

            5.         On May 2, 2003, Plaintiff was a pedestrian crossing the Northbound I-95 merge lane that was in a service area/rest area outside of Ogletown, Delaware.  Plaintiff exited the vehicle he was a passenger in and walked around the front of the vehicle to cross the service station/rest area through lane to go to the restroom.   

6.         At the same time, a bus owned and operated by Greyhound, by and through its agents and employees acting within the course scope and furtherance of their employment, was traveling Northbound on 1-95 in the service/rest area.  

            7.         The operator of the Greyhound bus was negligent and caused a collision between the Greyhound bus and the Plaintiff, a pedestrian.  

            8.         Greyhound, through it agents and employees acting within the course, scope, and in furtherance of their employment, owed Plaintiff the highest degree of care in operating the vehicle owned and operated by Greyhound prior to and during the previously-referenced collision.

            9.         Greyhound, its agents and employees, breached the duty it owed Plaintiff in the following respects:

                        A)        Greyhound, its agents and employees, operated the said Greyhound bus in an unsafe manner by operating the bus at an excessive rate of speed for the conditions;

                        B)        Greyhound operated the bus in an unsafe manner by operating a bus that Greyhound, its agents and employees, knew or should have known had defective, faulty, or improperly working brakes;

                        C)        Greyhound, its agents and employees, failed to obey traffic signs;

                        D)        Greyhound, its agents and employees, failed to operate the bus in a safe manner; and

                        E)         Greyhound, its agents and employees, failed to avoid the collision; and

                        F)         Greyhound, its agents and employees, failed to yield to a pedestrian.

            10.       As a direct and proximate result of Greyhound’s negligence, through its agents and employees, Plaintiff was caused to suffer severe physical injuries, including but not limited to a skull fracture and a severe head and brain injury requiring a craniotomy and titanium plates put in Plaintiff’s head and resulting in severe and permanent disabling injuries, permanent disfigurement, past and future pain and suffering, loss of enjoyment of life, and past and future lost wages and medical expenses.   

            WHEREFORE, Plaintiff requests the Court to enter judgment in his favor and against the Defendant, and award him compensatory damages in an amount to be proven at trial to be fair and reasonable in excess of $50,000; to award him prejudgment interest, attorney fees, and the costs of this action; and to grant such other relief as the Court may deem necessary and proper.

Respectfully submitted

Sansone Law, LLC