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12-Person(A,B,C,D,E,F,H,R,X,Z)
Law Division Motion Section Initial Case Management Dates for CALENDARS Jury will be heard In Person.
All other Law Division Initial Case Management Dates will be heard via Zoom
For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12
Court Date: 4/26/2024 9:00 AM FILED
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 2/16/2024 3:40 PM
COUNTY DEPARTMENT IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
ARDENCIA HILL AND BOBIE HILL,
FILED DATE: 2/16/2024 3:40 PM 2024L063023
2024L063023
Plaintiff,
v. 26447943
PACE SUBURBAN BUS SERVICE, A No.
DIVISION OF THE REGIONAL
TRANSPORTATION AUTHORITY a/k/a 2024L063023
PACE SUBURBAN BUS SERVICE, SCR
MEDICAL TRANSPORTATION, LLC AND
AND DEJAVUE GRIFFINS.
Defendants.
COMPLAINT AT LAW
NOW COMES the Plaintiffs, ARDENCIA HILL AND BOBIE HILL, by and through her
attorneys, QUINN LAW GROUP, LLC, and complaining of the Defendants, PACE SUBURBAN
BUS DIVISION OF THE REGIONAL TRANSPORTATION AUTHORITY a/k/a PACE
SUBURBAN BUS SERVICE (Hereinafter refered to as “PACE”); SCR MEDICAL
TRANSPORTATION, LLC AND AND DEJAVUE GRIFFINS, alleges as follows:
COUNT I
Negligence Against All Defendants
(ARDENCIA HILL)
1. That on or about February 22, 2023, Plaintiff, ARDENCIA HILL, was on bus
through Paratransit’s Dial-a-Ride service through the Defendants, PACE and SCR MEDICAL
TRANSPORTATION, LLC at or near 6600 block of S. Claremont Street, in the City of Chicago,
County of Cook, and State of Illinois. The aforementioned Defendants own, manage, maintain and
or control the Paratransit Dial-a-Ride service.
2. That on the aforesaid time and place, Defendant, DEJAVUE GRIFFINS, operated
said motor vehicle individually and in the capacity of, agent, servant, and/or employee of the
Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC.
3. That at the aforesaid time and place, the vehicle being operated by Defendants,
10
PACE and SCR MEDICAL TRANSPORTATION, LLC, in which Plaintiff was on board.
4. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC,
FILED DATE: 2/16/2024 3:40 PM 2024L063023
by and through their agents, drivers, servants and/or employees drove at a high rate of speed over
a speed bump clearly marked on the street.
5. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC by
and through its agents, drivers, servants and/or employees, became guilty of one or more of the
following careless and negligent acts and/or omissions:
a. Operated said vehicle at rate of speed that was greater than reasonable and proper
with regard to traffic and/or weather conditions and the use of the highway,
contrary to and in violation of 625 ILCS 5/11-601;
b. Operated said vehicle without keeping a proper and sufficient lookout for other
vehicles in and about the area;
c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary
to and in violation of 625 ILCS 5/12-301;
d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and
in violation of 625 ILCS 5/11-601;
e. Failed to maintain proper control over said vehicle at all times; and
f. Failed to provide its bus drivers with proper training.
6. That one or more of the aforesaid careless or negligent acts and/or omissions of the
Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts and/or
omissions of Defendant, DEJAVUE GRIFFINS, its agent, servant and/or employee, was a
proximate cause of the personal injuries hereinafter stated.
7. That as a direct and proximate result of one or more of the aforesaid careless and
negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL
TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent
injuries, both externally and internally, and was and will be hindered and prevented from attending
to her usual duties and affairs, and has lost and will in the future lose the value of that time as
10
aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in
the future continue to suffer. Plaintiff further expended and became liable for, and will expend
FILED DATE: 2/16/2024 3:40 PM 2024L063023
and become liable for, large sums of money for medical care and services endeavoring to become
healed and cured of said injuries.
WHEREFORE, Plaintiff, ARDENCIA HILL, prays for judgment in her favor and against
the Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs
of this suit.
COUNT II
(Common Carrier Negligence Against All Defendants)
(ARDENCIA HILL)
1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count I as Paragraphs 1
through 4 of Count II as though fully set forth herein.
5. That the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC, AND
DEJAVUE GRIFFINS, by and through their agents, drivers, servants and/or employees, were
operating said bus in the capacity as a common carrier and therefore owed the plaintiff the exercise
of the highest duty of care.
6. That the Defendants breached said highest duty of care in one or more of the
following ways;
a. Operated said vehicle at rate of speed that was greater than reasonable and proper
with regard to traffic and/or weather conditions and the use of the highway,
contrary to and in violation of 625 ILCS 5/11-601;
b. Operated said vehicle without keeping a proper and sufficient lookout for other
vehicles in and about the area;
c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary
to and in violation of 625 ILCS 5/12-301;
d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and
in violation of 625 ILCS 5/11-601;
10
e. Failed to maintain proper control over said vehicle at all times; and
f. Failed to provide its bus drivers with proper training.
FILED DATE: 2/16/2024 3:40 PM 2024L063023
7. That one or more of the aforesaid careless or negligent acts and/or omissions of the
Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts
and/or omissions of Defendant, DEJAVUE GRIFFINS, its agent, servant and/or employee, was a
proximate cause of the personal injuries hereinafter stated.
8. That as a direct and proximate result of one or more of the aforesaid careless and
negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL
TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent
injuries, both externally and internally, and was and will be hindered and prevented from attending
to her usual duties and affairs, and has lost and will in the future lose the value of that time as
aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in
the future continue to suffer. Plaintiff further expended and became liable for, and will expend
and become liable for, large sums of money for medical care and services endeavoring to become
healed and cured of said injuries.
WHEREFORE, Plaintiff, ARDENCIA HILL, prays for judgment in her favor and against
the Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs
of this suit.
COUNT III
(Willful & Wanton Misconduct Against All Defendants)
(ARDENCIA HILL)
1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count III as Paragraphs 1
through 4 of Count III as though fully set forth herein.
5. At the aforesaid time and place, it was the duty of the Defendants, PACE, SCR
MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, to provide transportation
10
services in such a matter that they do not constitute reckless, and/or willful and wanton
misconduct.
FILED DATE: 2/16/2024 3:40 PM 2024L063023
6. That the Defendants, Defendants, PACE, SCR MEDICAL TRANSPORTATION,
LLC and DEJAVUE GRIFFINS, by and through its agents, drivers, servants and/or employees
breached that duty and was reckless and/or willful and wanton in one or more of the following
ways:
a. Recklessly operated said vehicle at rate of speed that was greater than reasonable
and proper with regard to traffic and/or weather conditions and the use of the
highway, contrary to and in violation of 625 ILCS 5/11-601;
b. Recklessly operated said vehicle without keeping a proper and sufficient lookout
for other vehicles in and about the area;
c. Recklessly failed to have said vehicle equipped with proper and sufficient
brakes, contrary to and in violation of 625 ILCS 5/12-301;
d. Recklessly failed to reduce the speed of said vehicle to avoid an accident,
contrary to and in violation of 625 ILCS 5/11-601;
e. Recklessly failed to maintain proper control over said vehicle at all times; and
f. Recklessly failed to provide its bus drivers with proper training.
7. That as a direct and proximate result of one or more of the aforesaid acts and/or
omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and
DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent injuries, both externally and
internally, and was and will be hindered and prevented from attending to her usual duties and
affairs, and has lost and will in the future lose the value of that time as aforementioned. Plaintiff
also suffered great pain and anguish, both in mind and body, and will in the future continue to
suffer. Plaintiff further expended and became liable for, and will expend and become.
liable for, large sums of money for medical care and services endeavoring to become healed and
cured of said injuries.
WHEREFORE, Plaintiff, ARDENCIA HILL, prays for judgment in her favor and against
10
the Defendants in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and
costs of this suit.
FILED DATE: 2/16/2024 3:40 PM 2024L063023
COUNT IV
Negligence Against All Defendants
(BOBIE HILL)
1. That on or about February 22, 2023, Plaintiff, BOBIE HILL, was on bus through
Paratransit’s Dial-a-Ride service through the Defendants, PACE and SCR MEDICAL
TRANSPORTATION, LLC at or near 6600 block of S. Claremont Street, in the City of Chicago,
County of Cook, and State of Illinois. The aforementioned Defendants own, manage, maintain and
or control the Paratransit Dial-a-Ride service.
2. That on the aforesaid time and place, Defendant, DEJAVUE GRIFFINS, operated
said motor vehicle individually and in the capacity of, agent, servant, and/or employee of the
Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC.
3. That at the aforesaid time and place, the vehicle being operated by Defendants,
PACE and SCR MEDICAL TRANSPORTATION, LLC, in which Plaintiff was on board.
4. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC,
by and through their agents, drivers, servants and/or employees drove at a high rate of speed over
a speed bump clearly marked on the street.
5. That on or about February 22, 2023, Plaintiff, BOBIE HILL, was on bus through
Paratransit’s Dial-a-Ride service through the Defendants, PACE and SCR MEDICAL
TRANSPORTATION, LLC at or near 6600 block of S. Claremont Street, in the City of Chicago,
County of Cook, and State of Illinois. The aforementioned Defendants own, manage, maintain and
or control the Paratransit Dial-a-Ride service.
6. That on the aforesaid time and place, Defendant, DEJAVUE GRIFFINS, operated
said motor vehicle individually and in the capacity of, agent, servant, and/or employee of the
10
Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC.
7. That at the aforesaid time and place, the vehicle being operated by Defendants,
FILED DATE: 2/16/2024 3:40 PM 2024L063023
PACE and SCR MEDICAL TRANSPORTATION, LLC, in which Plaintiff.
8. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC,
by and through their agents, drivers, servants and/or employees drove at a high rate of speed over
a speed bump clearly marked on the street.
9. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC by
and through its agents, drivers, servants and/or employees, became guilty of one or more of the
following careless and negligent acts and/or omissions:
a. Operated said vehicle at rate of speed that was greater than reasonable and proper
with regard to traffic and/or weather conditions and the use of the highway,
contrary to and in violation of 625 ILCS 5/11-601;
b. Operated said vehicle without keeping a proper and sufficient lookout for other
vehicles in and about the area;
c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary
to and in violation of 625 ILCS 5/12-301;
d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and
in violation of 625 ILCS 5/11-601;
e. Failed to maintain proper control over said vehicle at all times; and
f. Failed to provide its bus drivers with proper training.
10. That one or more of the aforesaid careless or negligent acts and/or omissions of the
Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts
and/or omissions of Defendant, DEJAVUE GRIFFINS its agent, servant and/or employee, was a
proximate cause of the personal injuries hereinafter stated.
11. That as a direct and proximate result of one or more of the aforesaid careless and
negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL
TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent
10
injuries, both externally and internally, and was and will be hindered and prevented from attending
to her usual duties and affairs, and has lost and will in the future lose the value of that time as
FILED DATE: 2/16/2024 3:40 PM 2024L063023
aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in
the future continue to suffer. Plaintiff further expended and became liable for, and will expend
and become liable for, large sums of money for medical care and services endeavoring to become
healed and cured of said injuries.
WHEREFORE, Plaintiff, BOBIE HILL, prays for judgment in her favor and against the
Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs
of this suit.
COUNT V
(Common Carrier Negligence Against All Defendants)
(BOBIE HILL)
1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count IV as Paragraphs 1
through 4 of Count V as though fully set forth herein.
5. That the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC, AND
DEJAVUE GRIFFINS, by and through their agents, drivers, servants and/or employees, were
operating said bus in the capacity as a common carrier and therefore owed the plaintiff the exercise
of the highest duty of care.
6. That the Defendants breached said highest duty of care in one or more of the
following ways;
a. Operated said vehicle at rate of speed that was greater than reasonable and proper
with regard to traffic and/or weather conditions and the use of the highway,
contrary to and in violation of 625 ILCS 5/11-601;
b. Operated said vehicle without keeping a proper and sufficient lookout for other
vehicles in and about the area;
c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary
to and in violation of 625 ILCS 5/12-301;
10
d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and
in violation of 625 ILCS 5/11-601;
FILED DATE: 2/16/2024 3:40 PM 2024L063023
e. Failed to maintain proper control over said vehicle at all times; and
f. Failed to provide its bus drivers with proper training.
7. That one or more of the aforesaid careless or negligent acts and/or omissions of the
Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts
and/or omissions of Defendant, DEJAVUE GRIFFINS, its agent, servant and/or employee, was a
proximate cause of the personal injuries hereinafter stated.
8. That as a direct and proximate result of one or more of the aforesaid careless and
negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL
TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent
injuries, both externally and internally, and was and will be hindered and prevented from attending
to her usual duties and affairs, and has lost and will in the future lose the value of that time as
aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in
the future continue to suffer. Plaintiff further expended and became liable for, and will expend and
become liable for, large sums of money for medical care and services endeavoring to become
healed and cured of said injuries.
WHEREFORE, Plaintiff, BOBIE HILL, prays for judgment in her favor and against the
Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs
of this suit.
COUNT VI
(Willful & Wanton Misconduct Against All Defendants)
(BOBIE HILL)
1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count IV as Paragraphs VI
10
through 4 of Count VI as though fully set forth herein.
5. At the aforesaid time and place, it was the duty of the Defendants, PACE, SCR
FILED DATE: 2/16/2024 3:40 PM 2024L063023
MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, to provide transportation
services in such a matter that they do not constitute reckless, and/or willful and wanton
misconduct.
6. That the Defendants, Defendants, PACE, SCR MEDICAL TRANSPORTATION,
LLC and DEJAVUE GRIFFINS, by and through its agents, drivers, servants and/or employees
breached that duty and was reckless and/or willful and wanton in one or more of the following
ways:
a. Recklessly operated said vehicle at rate of speed that was greater than reasonable
and proper with regard to traffic and/or weather conditions and the use of the
highway, contrary to and in violation of 625 ILCS 5/11-601;
b. Recklessly operated said vehicle without keeping a proper and sufficient lookout
for other vehicles in and about the area;
c. Recklessly failed to have said vehicle equipped with proper and sufficient
brakes, contrary to and in violation of 625 ILCS 5/12-301;
d. Recklessly failed to reduce the speed of said vehicle to avoid an accident,
contrary to and in violation of 625 ILCS 5/11-601;
e. Recklessly failed to maintain proper control over said vehicle at all times; and
f. Recklessly failed to provide its bus drivers with proper training.
7. That as a direct and proximate result of one or more of the aforesaid acts and/or
omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and
DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent injuries, both externally and
internally, and was and will be hindered and prevented from attending to her usual duties and
affairs, and has lost and will in the future lose the value of that time as aforementioned. Plaintiff
also suffered great pain and anguish, both in mind and body, and will in the future continue to
suffer. Plaintiff further expended and became liable for, and will expend and become liable for,
10
large sums of money for medical care and services endeavoring to become healed and cured of
said injuries.
FILED DATE: 2/16/2024 3:40 PM 2024L063023
WHEREFORE, Plaintiff, BOBIE HILL, prays for judgment in her favor and against the
Defendants in a s um in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs
of this suit.
Respectfully submitted,
/s/ Patrick Quinn
Patrick Quinn
Attorney for Plaintiff
Patrick Quinn
Attorney for Plaintiff
350 S. Northwest Highway, Suite 300
Park Ridge, IL 60068
pat@pquinnlaw.com
847-232-7180
847-232-7181
10
FILED DATE: 2/16/2024 3:40 PM 2024L063023
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT
ARDENCIA HILL AND BOBIE HILL,
Plaintiff,
v.
No.
PACE SUBURBAN BUS SERVICE, A DIVISION OF
THE REGIONAL TRANSPORTATION AUTHORITY
a/k/a PACE SUBURBAN BUS SERVICE, SCR
MEDICAL TRANSPORTATION, LLC AND AND
DEJAVUE GRIFFINS.
Defendants.
AFFIDAVIT PURSUANT TO SUPREME COURT RULE 222(B)
Pursuant to Supreme Court Rule 222(B), counsel for the above-named plaintiff certifies
that plaintiff seeks money damages in excess of FIFTY THOUSAND AND 00/100 DOLLARS
($50,000.00).
Respectfully submitted,
/s/ Patrick Quinn
Patrick Quinn
Attorney for Plaintiff
Patrick Quinn
Attorney for Plaintiff
350 S. Northwest Highway, Suite 300
Park Ridge, IL 60068
pat@pquinnlaw.com
847-232-7180
847-232-7181
10
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12-Person(A,B,C,D,E,F,H,R,X,Z) Law Division Motion Section Initial Case Management Dates for CALENDARS Jury will be heard In Person. All other Law Division Initial Case Management Dates will be heard via Zoom For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12 Court Date: 4/26/2024 9:00 AM FILED IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 2/16/2024 3:40 PM COUNTY DEPARTMENT IRIS Y. MARTINEZ CIRCUIT CLERK COOK COUNTY, IL ARDENCIA HILL AND BOBIE HILL, FILED DATE: 2/16/2024 3:40 PM 2024L063023 2024L063023 Plaintiff, v. 26447943 PACE SUBURBAN BUS SERVICE, A No. DIVISION OF THE REGIONAL TRANSPORTATION AUTHORITY a/k/a 2024L063023 PACE SUBURBAN BUS SERVICE, SCR MEDICAL TRANSPORTATION, LLC AND AND DEJAVUE GRIFFINS. Defendants. COMPLAINT AT LAW NOW COMES the Plaintiffs, ARDENCIA HILL AND BOBIE HILL, by and through her attorneys, QUINN LAW GROUP, LLC, and complaining of the Defendants, PACE SUBURBAN BUS DIVISION OF THE REGIONAL TRANSPORTATION AUTHORITY a/k/a PACE SUBURBAN BUS SERVICE (Hereinafter refered to as “PACE”); SCR MEDICAL TRANSPORTATION, LLC AND AND DEJAVUE GRIFFINS, alleges as follows: COUNT I Negligence Against All Defendants (ARDENCIA HILL) 1. That on or about February 22, 2023, Plaintiff, ARDENCIA HILL, was on bus through Paratransit’s Dial-a-Ride service through the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC at or near 6600 block of S. Claremont Street, in the City of Chicago, County of Cook, and State of Illinois. The aforementioned Defendants own, manage, maintain and or control the Paratransit Dial-a-Ride service. 2. That on the aforesaid time and place, Defendant, DEJAVUE GRIFFINS, operated said motor vehicle individually and in the capacity of, agent, servant, and/or employee of the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC. 3. That at the aforesaid time and place, the vehicle being operated by Defendants, 10 PACE and SCR MEDICAL TRANSPORTATION, LLC, in which Plaintiff was on board. 4. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, FILED DATE: 2/16/2024 3:40 PM 2024L063023 by and through their agents, drivers, servants and/or employees drove at a high rate of speed over a speed bump clearly marked on the street. 5. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC by and through its agents, drivers, servants and/or employees, became guilty of one or more of the following careless and negligent acts and/or omissions: a. Operated said vehicle at rate of speed that was greater than reasonable and proper with regard to traffic and/or weather conditions and the use of the highway, contrary to and in violation of 625 ILCS 5/11-601; b. Operated said vehicle without keeping a proper and sufficient lookout for other vehicles in and about the area; c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary to and in violation of 625 ILCS 5/12-301; d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and in violation of 625 ILCS 5/11-601; e. Failed to maintain proper control over said vehicle at all times; and f. Failed to provide its bus drivers with proper training. 6. That one or more of the aforesaid careless or negligent acts and/or omissions of the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts and/or omissions of Defendant, DEJAVUE GRIFFINS, its agent, servant and/or employee, was a proximate cause of the personal injuries hereinafter stated. 7. That as a direct and proximate result of one or more of the aforesaid careless and negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent injuries, both externally and internally, and was and will be hindered and prevented from attending to her usual duties and affairs, and has lost and will in the future lose the value of that time as 10 aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in the future continue to suffer. Plaintiff further expended and became liable for, and will expend FILED DATE: 2/16/2024 3:40 PM 2024L063023 and become liable for, large sums of money for medical care and services endeavoring to become healed and cured of said injuries. WHEREFORE, Plaintiff, ARDENCIA HILL, prays for judgment in her favor and against the Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs of this suit. COUNT II (Common Carrier Negligence Against All Defendants) (ARDENCIA HILL) 1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count I as Paragraphs 1 through 4 of Count II as though fully set forth herein. 5. That the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC, AND DEJAVUE GRIFFINS, by and through their agents, drivers, servants and/or employees, were operating said bus in the capacity as a common carrier and therefore owed the plaintiff the exercise of the highest duty of care. 6. That the Defendants breached said highest duty of care in one or more of the following ways; a. Operated said vehicle at rate of speed that was greater than reasonable and proper with regard to traffic and/or weather conditions and the use of the highway, contrary to and in violation of 625 ILCS 5/11-601; b. Operated said vehicle without keeping a proper and sufficient lookout for other vehicles in and about the area; c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary to and in violation of 625 ILCS 5/12-301; d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and in violation of 625 ILCS 5/11-601; 10 e. Failed to maintain proper control over said vehicle at all times; and f. Failed to provide its bus drivers with proper training. FILED DATE: 2/16/2024 3:40 PM 2024L063023 7. That one or more of the aforesaid careless or negligent acts and/or omissions of the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts and/or omissions of Defendant, DEJAVUE GRIFFINS, its agent, servant and/or employee, was a proximate cause of the personal injuries hereinafter stated. 8. That as a direct and proximate result of one or more of the aforesaid careless and negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent injuries, both externally and internally, and was and will be hindered and prevented from attending to her usual duties and affairs, and has lost and will in the future lose the value of that time as aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in the future continue to suffer. Plaintiff further expended and became liable for, and will expend and become liable for, large sums of money for medical care and services endeavoring to become healed and cured of said injuries. WHEREFORE, Plaintiff, ARDENCIA HILL, prays for judgment in her favor and against the Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs of this suit. COUNT III (Willful & Wanton Misconduct Against All Defendants) (ARDENCIA HILL) 1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count III as Paragraphs 1 through 4 of Count III as though fully set forth herein. 5. At the aforesaid time and place, it was the duty of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, to provide transportation 10 services in such a matter that they do not constitute reckless, and/or willful and wanton misconduct. FILED DATE: 2/16/2024 3:40 PM 2024L063023 6. That the Defendants, Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, by and through its agents, drivers, servants and/or employees breached that duty and was reckless and/or willful and wanton in one or more of the following ways: a. Recklessly operated said vehicle at rate of speed that was greater than reasonable and proper with regard to traffic and/or weather conditions and the use of the highway, contrary to and in violation of 625 ILCS 5/11-601; b. Recklessly operated said vehicle without keeping a proper and sufficient lookout for other vehicles in and about the area; c. Recklessly failed to have said vehicle equipped with proper and sufficient brakes, contrary to and in violation of 625 ILCS 5/12-301; d. Recklessly failed to reduce the speed of said vehicle to avoid an accident, contrary to and in violation of 625 ILCS 5/11-601; e. Recklessly failed to maintain proper control over said vehicle at all times; and f. Recklessly failed to provide its bus drivers with proper training. 7. That as a direct and proximate result of one or more of the aforesaid acts and/or omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent injuries, both externally and internally, and was and will be hindered and prevented from attending to her usual duties and affairs, and has lost and will in the future lose the value of that time as aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in the future continue to suffer. Plaintiff further expended and became liable for, and will expend and become. liable for, large sums of money for medical care and services endeavoring to become healed and cured of said injuries. WHEREFORE, Plaintiff, ARDENCIA HILL, prays for judgment in her favor and against 10 the Defendants in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs of this suit. FILED DATE: 2/16/2024 3:40 PM 2024L063023 COUNT IV Negligence Against All Defendants (BOBIE HILL) 1. That on or about February 22, 2023, Plaintiff, BOBIE HILL, was on bus through Paratransit’s Dial-a-Ride service through the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC at or near 6600 block of S. Claremont Street, in the City of Chicago, County of Cook, and State of Illinois. The aforementioned Defendants own, manage, maintain and or control the Paratransit Dial-a-Ride service. 2. That on the aforesaid time and place, Defendant, DEJAVUE GRIFFINS, operated said motor vehicle individually and in the capacity of, agent, servant, and/or employee of the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC. 3. That at the aforesaid time and place, the vehicle being operated by Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, in which Plaintiff was on board. 4. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through their agents, drivers, servants and/or employees drove at a high rate of speed over a speed bump clearly marked on the street. 5. That on or about February 22, 2023, Plaintiff, BOBIE HILL, was on bus through Paratransit’s Dial-a-Ride service through the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC at or near 6600 block of S. Claremont Street, in the City of Chicago, County of Cook, and State of Illinois. The aforementioned Defendants own, manage, maintain and or control the Paratransit Dial-a-Ride service. 6. That on the aforesaid time and place, Defendant, DEJAVUE GRIFFINS, operated said motor vehicle individually and in the capacity of, agent, servant, and/or employee of the 10 Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC. 7. That at the aforesaid time and place, the vehicle being operated by Defendants, FILED DATE: 2/16/2024 3:40 PM 2024L063023 PACE and SCR MEDICAL TRANSPORTATION, LLC, in which Plaintiff. 8. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through their agents, drivers, servants and/or employees drove at a high rate of speed over a speed bump clearly marked on the street. 9. That the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC by and through its agents, drivers, servants and/or employees, became guilty of one or more of the following careless and negligent acts and/or omissions: a. Operated said vehicle at rate of speed that was greater than reasonable and proper with regard to traffic and/or weather conditions and the use of the highway, contrary to and in violation of 625 ILCS 5/11-601; b. Operated said vehicle without keeping a proper and sufficient lookout for other vehicles in and about the area; c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary to and in violation of 625 ILCS 5/12-301; d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and in violation of 625 ILCS 5/11-601; e. Failed to maintain proper control over said vehicle at all times; and f. Failed to provide its bus drivers with proper training. 10. That one or more of the aforesaid careless or negligent acts and/or omissions of the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts and/or omissions of Defendant, DEJAVUE GRIFFINS its agent, servant and/or employee, was a proximate cause of the personal injuries hereinafter stated. 11. That as a direct and proximate result of one or more of the aforesaid careless and negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent 10 injuries, both externally and internally, and was and will be hindered and prevented from attending to her usual duties and affairs, and has lost and will in the future lose the value of that time as FILED DATE: 2/16/2024 3:40 PM 2024L063023 aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in the future continue to suffer. Plaintiff further expended and became liable for, and will expend and become liable for, large sums of money for medical care and services endeavoring to become healed and cured of said injuries. WHEREFORE, Plaintiff, BOBIE HILL, prays for judgment in her favor and against the Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs of this suit. COUNT V (Common Carrier Negligence Against All Defendants) (BOBIE HILL) 1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count IV as Paragraphs 1 through 4 of Count V as though fully set forth herein. 5. That the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC, AND DEJAVUE GRIFFINS, by and through their agents, drivers, servants and/or employees, were operating said bus in the capacity as a common carrier and therefore owed the plaintiff the exercise of the highest duty of care. 6. That the Defendants breached said highest duty of care in one or more of the following ways; a. Operated said vehicle at rate of speed that was greater than reasonable and proper with regard to traffic and/or weather conditions and the use of the highway, contrary to and in violation of 625 ILCS 5/11-601; b. Operated said vehicle without keeping a proper and sufficient lookout for other vehicles in and about the area; c. Failed to have said vehicle equipped with proper and sufficient brakes, contrary to and in violation of 625 ILCS 5/12-301; 10 d. Failed to reduce the speed of said vehicle to avoid an accident, contrary to and in violation of 625 ILCS 5/11-601; FILED DATE: 2/16/2024 3:40 PM 2024L063023 e. Failed to maintain proper control over said vehicle at all times; and f. Failed to provide its bus drivers with proper training. 7. That one or more of the aforesaid careless or negligent acts and/or omissions of the Defendants, PACE and SCR MEDICAL TRANSPORTATION, LLC, by and through the acts and/or omissions of Defendant, DEJAVUE GRIFFINS, its agent, servant and/or employee, was a proximate cause of the personal injuries hereinafter stated. 8. That as a direct and proximate result of one or more of the aforesaid careless and negligent acts and/or omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent injuries, both externally and internally, and was and will be hindered and prevented from attending to her usual duties and affairs, and has lost and will in the future lose the value of that time as aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in the future continue to suffer. Plaintiff further expended and became liable for, and will expend and become liable for, large sums of money for medical care and services endeavoring to become healed and cured of said injuries. WHEREFORE, Plaintiff, BOBIE HILL, prays for judgment in her favor and against the Defendants, in a sum in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs of this suit. COUNT VI (Willful & Wanton Misconduct Against All Defendants) (BOBIE HILL) 1-4 Plaintiff adopts and realleges Paragraphs 1 through 4 of Count IV as Paragraphs VI 10 through 4 of Count VI as though fully set forth herein. 5. At the aforesaid time and place, it was the duty of the Defendants, PACE, SCR FILED DATE: 2/16/2024 3:40 PM 2024L063023 MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, to provide transportation services in such a matter that they do not constitute reckless, and/or willful and wanton misconduct. 6. That the Defendants, Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, by and through its agents, drivers, servants and/or employees breached that duty and was reckless and/or willful and wanton in one or more of the following ways: a. Recklessly operated said vehicle at rate of speed that was greater than reasonable and proper with regard to traffic and/or weather conditions and the use of the highway, contrary to and in violation of 625 ILCS 5/11-601; b. Recklessly operated said vehicle without keeping a proper and sufficient lookout for other vehicles in and about the area; c. Recklessly failed to have said vehicle equipped with proper and sufficient brakes, contrary to and in violation of 625 ILCS 5/12-301; d. Recklessly failed to reduce the speed of said vehicle to avoid an accident, contrary to and in violation of 625 ILCS 5/11-601; e. Recklessly failed to maintain proper control over said vehicle at all times; and f. Recklessly failed to provide its bus drivers with proper training. 7. That as a direct and proximate result of one or more of the aforesaid acts and/or omissions of the Defendants, PACE, SCR MEDICAL TRANSPORTATION, LLC and DEJAVUE GRIFFINS, Plaintiff sustained severe and permanent injuries, both externally and internally, and was and will be hindered and prevented from attending to her usual duties and affairs, and has lost and will in the future lose the value of that time as aforementioned. Plaintiff also suffered great pain and anguish, both in mind and body, and will in the future continue to suffer. Plaintiff further expended and became liable for, and will expend and become liable for, 10 large sums of money for medical care and services endeavoring to become healed and cured of said injuries. FILED DATE: 2/16/2024 3:40 PM 2024L063023 WHEREFORE, Plaintiff, BOBIE HILL, prays for judgment in her favor and against the Defendants in a s um in excess of FIFTY THOUSAND DOLLARS ($50,000.00), and costs of this suit. Respectfully submitted, /s/ Patrick Quinn Patrick Quinn Attorney for Plaintiff Patrick Quinn Attorney for Plaintiff 350 S. Northwest Highway, Suite 300 Park Ridge, IL 60068 pat@pquinnlaw.com 847-232-7180 847-232-7181 10 FILED DATE: 2/16/2024 3:40 PM 2024L063023 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT ARDENCIA HILL AND BOBIE HILL, Plaintiff, v. No. PACE SUBURBAN BUS SERVICE, A DIVISION OF THE REGIONAL TRANSPORTATION AUTHORITY a/k/a PACE SUBURBAN BUS SERVICE, SCR MEDICAL TRANSPORTATION, LLC AND AND DEJAVUE GRIFFINS. Defendants. AFFIDAVIT PURSUANT TO SUPREME COURT RULE 222(B) Pursuant to Supreme Court Rule 222(B), counsel for the above-named plaintiff certifies that plaintiff seeks money damages in excess of FIFTY THOUSAND AND 00/100 DOLLARS ($50,000.00). Respectfully submitted, /s/ Patrick Quinn Patrick Quinn Attorney for Plaintiff Patrick Quinn Attorney for Plaintiff 350 S. Northwest Highway, Suite 300 Park Ridge, IL 60068 pat@pquinnlaw.com 847-232-7180 847-232-7181 10