IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT

LAKE COUNTY, ILLINOIS

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Kelly Morgan,
Plaintiff,
vs.
Casey Jones,
Defendant.

Docket #:

COMPLAINT
NOW COMES the Plaintiff, Kelly Morgan, by and through her attorney, Alexandra Mitich,
alleging the following for the Civil Complaint against the Defendant, Casey Jones.
1.

Plaintiff resides in Loganville, Lake County, Illinois.

2.

Defendant resides in Loganville, Lake County, Illinois.

3.

On May 16, 2014, Plaintiff returned from work to her residence at or around 7 p.m.

4.

On the same date, at or around 11:30 p.m., Plaintiff was in the bathroom and heard the front door

of her residence open.

5.

That at or around the same time, Defendant entered Plaintiffs residence and appeared in the

doorway of the bathroom wearing a hooded mask.

6.

Plaintiff alleges that Defendant initiated a physical struggle, during which she was injured with a

stun gun on her torso and struck in the face by Defendant.

7.

During the physical altercation, Plaintiff and Defendant fell out of the side door of the residence

onto the ground, where the struggle continued.

8.

Plaintiff broke away from the struggle with Defendant and ran to the home of a neighbor, who

called police.
9.

Plaintiff returned to her residence with police to discover her purse, keys, and cara red two-

door Toyota Celicamissing from the property.

COUNT I TRESPASS TO LAND

10.

The allegations in Paragraphs 1-5 above are incorporated by reference in this Count One as if

fully restated herein.

11.

Defendant did commit the tort of trespass to land, when he entered Plaintiffs residence

intentionally and without her consent.

WHEREFORE, Plaintiff Kelly Morgan prays that judgment be entered in her favor and against the
Defendant Casey Jones for a sum in excess of $50,000, plus costs for personal injuries, pain and
suffering, medical expenses, and for such other relief as this Court deems just and equitable.

COUNT II - ASSAULT
12.

The allegations in Paragraphs 1-5 above are incorporated by reference in this Count Two as if

fully restated herein.

13.

Defendant did act intentionally to commit the tort of assault by appearing maskedunannounced

and uninvitedin Plaintiffs residence, thereby creating an immediate threat of harmful contact.
WHEREFORE, Plaintiff Kelly Morgan prays that judgment be entered in her favor and against the
Defendant Casey Jones for a sum in excess of $50,000, plus costs for personal injuries, pain and
suffering, medical expenses, and for such other relief as this Court deems just and equitable.

COUNT III - BATTERY

14.

The allegations in Paragraphs 1-7 above are incorporated by reference in this Count Three as if

fully restated herein.

15.

Defendant did commit the tort of battery by intentionally and willfully engaging in non-

consensual contact with Plaintiff with the intent to cause harm.

WHEREFORE, Plaintiff Kelly Morgan prays that judgment be entered in her favor and against the
Defendant Casey Jones for a sum in excess of $50,000, plus costs for personal injuries, pain and
suffering, medical expenses, and for such other relief as this Court deems just and equitable.

COUNT IV TRESPASS TO CHATTEL

16.

The allegations in Paragraphs 1, 2, and 9 above are incorporated by reference in this Count Four

as if fully restated herein.

17.

Defendant did commit the tort of trespass to chattel by intentionally and unlawfully interfering

with Plaintiffs right to property interest without her consent.

WHEREFORE, Plaintiff Kelly Morgan prays that judgment be entered in her favor and against the
Defendant Casey Jones for a sum in excess of $50,000, plus costs for personal injuries, pain and
suffering, medical expenses, and for such other relief as this Court deems just and equitable.
PLAINTIFF DEMANDS A TRIAL BY JURY.
Respectfully submitted,
Kelly Morgan, Plaintiff

By her attorney
Alexandra Mitich

Prepared by:
Alexandra Mitich
RIZZO, MITICH & ASSOCIATES
19351 W. Washington St., Suite 100
(847) 543-1900
ARDC #: 123457