1.    That at all times herein mentioned all Plaintiffs were residents of the State of Illinois.
2.    That at all times herein mentioned Defendant, Dustin W. REDACTED, was a resident of Adams County, State of Illinois.
3.    That at all times herein mentioned Defendant, Lindsey REDACTED, was a resident of Hancock County, State of Illinois.
4.    That defendant, Little REDACTED Motors Co., is an Illinois Corporation in good standing located in Adams County, Illinois. 
5.    That the cause of action herein accrued and occurred in the State of Illinois on or about August 11, 2007. 
6.    That at all times herein mentioned, Birmingham Road was an open and public highway located in the State of Illinois.
7.     That Defendant, Little REDACTED Motors Co., by and through its agents, servants and employees entrusted a 2004 Chevrolet 2500 HD to Defendant, Dustin W. REDACTED, when they knew or should have known that Mr. REDACTED was incompetent, inexperienced or would operate the vehicle in a reckless manner. 
8.    That on or about August 11, 2007, Plaintiffs were passengers in Defendant, Lindsey M. REDACTED’s vehicle on Birmingham Road, when due to the negligent and careless manner in which defendant, Dustin W. REDACTED, operated his vehicle, the vehicle rear ended Plaintiffs’ vehicle, thereby causing Plaintiffs to suffer severe and permanent injuries as more specifically alleged below. 
9.     That the aforesaid collision and resulting damages sustained by all Plaintiffs were directly and proximately caused by the negligence and recklessness of the defendant Dustin REDACTED in the following respects, to wit:
(a)    That REDACTED failed to keep a careful lookout;
(b)    That REDACTED drove at an excessive speed;
(c)    That REDACTED failed to maintain control of his vehicle;
(d)    That REDACTED negligently failed to stop, swerve, or apply his brakes in a proper and timely fashion so that a collision would not occur;
(e)    That REDACTED knew or by the highest degree of care should have known that there was a reasonable likelihood of collision in time thereafter to have stopped, swerved, slackened his speed and sounded a warning, or swerved and sounded a warning, but defendant failed to do so;
(f)    That REDACTED drove while impaired and intoxicated to the extent that defendant’s driving ability was adversely affected;
(g)    That REDACTED engaged in a game of high speed racing with Defendant, Lindsey M. REDACTED.
10.     That on or about August 11, 2007, Plaintiffs were passengers in Defendant, Lindsey M. REDACTED’s vehicle on Birmingham Road, when due to the negligent and careless manner in which REDACTED operated her vehicle, directly and proximately caused all Plaintiffs to suffer severe and permanent injuries as more specifically alleged below. 
11.    That the aforesaid collision and resulting damages sustained by all Plaintiffs were directly and proximately caused by the negligence and recklessness of Defendant REDACTED in the following respects, to wit:
(a)    That REDACTED failed to signal an intention to turn;
(b)    That REDACTED suddenly slowed her vehicle without first giving an adequate and timely warning of her intention to slow;
(c)    That REDACTED drove while impaired and intoxicated to the extent that Defendant’s driving ability was adversely affected;
(d)    That REDACTED engaged in a game of high speed racing with Defendant, Dustin W. REDACTED.

COMES NOW Plaintiff, James REDACTED, by and through his attorneys, and for his cause of action against Defendant, REDACTED., states to the Court as follows:
12.    Plaintiff, James REDACTED (hereinafter “REDACTED”) hereby incorporates by reference paragraphs 1 through 11, and all of their subparts, as if fully set forth herein.
13.    That as a direct and proximate result of the negligence, carelessness, failures and omissions of the defendant, REDACTED sustained injuries to his head, face, neck, back, scarring and disability; that REDACTED suffered a traumatic brain injury with permanent damage to his cognitive abilities; that REDACTED suffers and will continue to suffer from seizures; that REDACTED suffers and will continue to suffer from coordination and balance issues; that REDACTED has increased irritability and trouble dealing with conflict; that he has not been medically cleared to operate an automobile; that he suffers from and will continue to suffer from headaches and memory loss; that REDACTED suffered severe disfigurement on his face, that REDACTED suffered, suffers and will in the future continue to suffer great physical pain and mental anguish, post traumatic psychological damage and that all of REDACTED’s injuries are permanent and progressive.
14.    That as a direct and proximate result of the carelessness, negligence, failures and omissions of Defendant, as stated aforesaid, REDACTED has been caused to expend sums of money for reasonable medical, doctor and hospital care, and REDACTED will be caused to undergo further reasonable and necessary medical care and treatment in the future for which he will become indebted.  That REDACTED has lost income and will lose income and the ability to earn income in the future.  That REDACTED’s career opportunities are diminished. 
WHEREFORE, Plaintiff, James L. REDACTED, prays for judgment against Defendant, Dustin W. REDACTED, for a fair and reasonable amount in excess of Fifty Thousand Dollars ($50,000.00), and for his costs expended herein, and for such other and further relief as the Court deems just and proper under the circumstances.

COUNT II JAMES REDACTED’S CLAIM FOR PUNITIVE DAMAGES AGAINT DUSTIN REDACTED

COMES NOW Plaintiff, James REDACTED, by and through his attorneys, and for his claim for Punitive Damages against Defendant REDACTED, states to the Court as follows:
15.    REDACTED hereby incorporates by reference paragraphs 1 through 15, and all of their subparts, as if fully set forth herein.
16.    That REDACTED’s conduct of engaging in a high speed race demonstrated complete indifference to or conscious disregard for the safety of others, including REDACTED.
17.    REDACTED’s conduct of operating his vehicle while legally intoxicated has direct and proximate causation to the said collision and resultant injuries and constitutes extreme and outrageous conduct that constitutes a conscious disregard for the safety of others.  Said conduct justifies the imposition of punitive damages against Defendant.
WHEREFORE, Plaintiff James REDACTED, prays for judgment against Defendant, Dustin REDACTED, for punitive damages in an amount necessary to deter and punish Defendant of $500,000.00, or whatever other relief the Court deems just and proper.

COMES NOW Plaintiff, James REDACTED, by and through his attorneys, and for his cause of action against Defendant, Little REDACTED Motors Co., states to the Court as follows:
18.    That REDACTED incorporates by reference paragraphs 1 through 17, and all of their subparts, as if fully set forth herein.
19.    That as a direct and proximate result of the negligence, carelessness, failures and omissions of Defendant Little REDACTED Motors, REDACTED sustained injuries to his head, neck, back, scarring and disability; that REDACTED suffered a traumatic brain injury with permanent damage to his cognitive abilities; that he suffers and will continue to suffer from seizures; that he suffers and will continue to suffer from coordination and balance issues; that he has increased irritability and trouble dealing with conflict; that he has not been medically cleared to operate an automobile; that he suffers from and will continue to suffer from headaches and memory loss; that REDACTED suffered severe disfigurement about his face, that he suffered, suffers and will in the future continue to suffer great physical pain and mental anguish, post trauma psychological damage and severe injury and that all of REDACTED’s injuries are permanent and progressive.
20.    That as a direct and proximate result of the carelessness, negligence, failures and omissions of Defendant, Little REDACTED Motors, as stated aforesaid, REDACTED has been caused to expend sums of money for reasonable medical, doctor and hospital care, and REDACTED will be caused to undergo further reasonable and necessary medical care and treatment in the future for which he will become indebted.  That REDACTED has lost income and will lose income and the ability to earn income in the future.  That REDACTED’s career opportunities are diminished. 
WHEREFORE, Plaintiff, James L. REDACTED, prays judgment against defendant, Little REDACTED Motors Co., for a fair and reasonable amount in excess of Fifty Thousand Dollars ($50,000.00), and for his costs expended herein, and for such other and further relief as the Court deems just and proper under the circumstances.

COMES NOW Plaintiff, James L. REDACTED, by and through his attorneys, and for his cause of action against defendant, Lindsey M. REDACTED (hereinafter “REDACTED”), states to the Court as follows:
21.    Plaintiff hereby incorporates by reference paragraphs 1 through 17, and all of their subparts, as if fully set forth herein.     
22.     That as a direct and proximate result of the negligence, carelessness, failures and omissions of the defendant REDACTED, REDACTED sustained injuries to his head, neck, back, scarring and disability; that he suffered a traumatic brain injury with permanent damage to his cognitive abilities; that he suffers and will continue to suffer from seizures; that REDACTED suffers and will continue to suffer from coordination and balance issues; that he has increased irritability and trouble dealing with conflict; that he has not been medically cleared to operate an automobile; that he suffers from and will continue to suffer from headaches and memory loss; that REDACTED suffered severe disfigurement about his face, that plaintiff suffered, suffers and will in the future continue to suffer great physical pain and mental anguish, post trauma psychological damage and severe injury and that all of REDACTED’s injuries are permanent and progressive.
23.    That as a direct and proximate result of the carelessness, negligence, failures and omissions of defendant, as stated aforesaid, plaintiff has been caused to expend sums of money for reasonable medical, doctor and hospital care, and Plaintiff will be caused to undergo further reasonable and necessary medical care and treatment in the future for which he will become indebted.  That REDACTED has lost income and will lose income and the ability to earn income in the future.  That REDACTED’s career opportunities are diminished. 
WHEREFORE, plaintiff, James L. REDACTED, prays judgment against defendant, Lindsey M. REDACTED, for a fair and reasonable amount in excess of Fifty Thousand Dollars ($50,000.00), and for his costs expended herein, and for such other and further relief as the Court deems just and proper under the circumstances.

COMES NOW Plaintiff, James REDACTED, by and through his attorneys, and for his claim for Punitive Damages against Defendant REDACTED, states to the Court as follows:
24.     REDACTED hereby incorporates by reference paragraphs 1 through 23, and all of their subparts, as if fully set forth herein.
25.    That REDACTED’s conduct of engaging in a high speed race demonstrated complete indifference to or conscious disregard for the safety of others, including REDACTED.
26.    REDACTED’s conduct of operating her vehicle while legally intoxicated has direct and proximate causation to the said collision and resultant injuries and constitutes extreme and outrageous conduct that constitutes a conscious disregard for the safety of others.  Said conduct justifies the imposition of punitive damages against Defendant REDACTED.
WHEREFORE, Plaintiff James REDACTED, prays for judgment against Defendant, REDACTED, for punitive damages in an amount necessary to deter and punish Defendant of $500,000.00, or whatever other relief the Court deems just and proper.

(Counts 6 through 20 of the Illinois Drunk Driving Car Accident Lawyer Lawsuit are not published as they are repetitive of counts 1 through 5 except pertaining to other named Plaintiffs in the Illinois drinking and driving accident injury lawsuit)