Exhibit A

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2121 - Served

2221 - Not Served

2321 - Served By Mail

2421 - Served By Publication

ALIAS - SUMMONS

2120 - Served

2220 - Not Served

2320 - Served By Mail

2420 - Served By Publication

SUMMONS (2-81)CCG-l CO

CO

CO FN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, LAW DIVISION g

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ERNEST LANEY, )

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00 Plaintiff, •?: ) No. 19 L 9338

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o V. ) Please Serve: C!

C! ) Lyft Illinois, Inc.

c/o REGISTERED AGENT

CT Corporation System

208 South LaSalle Street, Suite 814

Chicago, IL 60604

m JOHN DOE and UBER TECHNOLOGIES, INC., et al. )

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Defendants. )

SUMMONS

To each defendant:

YOU ARE SUMMONED and required to file an answer in this case, or otherwise file your appearance in

the office of the clerk ofthis couit (located in the Richard J. Daley Center, Room 801, Chicago, Illinois 60602),

within 30 days after service ofthis summons, not counting the day ofservice. IF YOU FAIL TO DO SO, A

JUDGMENT BY DEFAULT MAY BE TAKEN AGAINST YOU FOR THE RELIEF ASKED IN THE

COMPLAINT, A COPY OF WHICH IS HERETO ATTACHED.

To the officer:

This summons must be returned by the officer or other person to whom it was given for service, with

endorsement ofservice and fees, if any, immediately after service. Ifservice cannot be made, this summons shall

be returned so indorsed. This summons may not be served later than 30 days after its date.

t' r

WITNESS , 2020

4/2/2020 9:48 AM DOROTHY BROWN

Clerk of Court

fjXl.K’l'li Date ofservice..............................

(to be inserted by officer on copy

left with defendant or other person)

, 2020 ^

Atty No. 30900

Name THE DERATANY FIRM

Attorneys for Plaintiff

Address 221 N LaSalle Street, Suite 2200

City Chicago, Illinois 60601

Telephone(312)857-7285

Fax: (312) 857-2004

DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

Exhibit B

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 7 of 21 PageID #:15
FILED

3/13/2020 10:42 AM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2019L009338

8854643

IN THE CIRCUIT COURT OF COOK COUNTY

COUNTY DEPARTMENT, LAW DIVISION

CO

CO

CO

g ERNEST LANEY, )

g

a )

Plaintiff, ) No. 2019L009338

)

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V. )

b

) JURY DEMANDED

JOHN DOE, individually and as actual or

apparent agent of UBER TECHNOLOG 1ES, INC. )

and/or LYFT, INC.; UBER TECHNOLOGIES,

INC., a Delaware Corporation; and LYFT, INC., a )

Delaware Corporation, also d/b/a LYFT ILLINOIS, )

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Defendants. )

SECOND AMENDED COMPLAINT AT LAW

NOW COMES the Plaintiff, ERNEST LANEY, by and through his attorneys, THE

DERATANY FIRM, and complains ofthe Defendants, JOHN DOE, individually and as actual

or apparent agent of UBER TECHNOLOG lES INC. and/or LYFT, INC., UBER

TECHNOLOGIES INC., and LYFT, INC. also d/b/a LYFT ILLINOIS, INC., alleging as

follows:

COUNT I - NEGLIGENCE

(JOHN DOE)

1. At all relevant times, Damen Avenue was a public roadway running in a.general

north and south direction in the city of Chicago, county ofCook, Illinois.

2. On or about September 27, 2018, between the hours of 5:00 p.m. and 5:36 p.m..

the Plaintiff ERNEST LANEY was riding a bicycle northbound on Damen Avenue in the bicycle

lane next to the roadway ofthe northbound lane on the east side of Damen Avenue at or near the

address of 745 North Damen Avenue, Chicago, Illinois.

1

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 8 of 21 PageID #:16
3. At said time and place, the Defendant, JOHM DOE, who, on information and

CO belief, was a white male, operated a car which stopped in the northbound moving traffic lane of CO

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3 Damen Avenue. (J>

4. At said time and place, Plaintiffwas riding his bicycle in the bicycle lane

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approaching from behind Defendant’s stopped car. O

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5. At said time and place. Defendant JOHN DOE discharged a passenger by

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H allowing the passenger’s side rear door of Defendant’s car to be opened into the bicycle lane by, <

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LJJ =! on information and belief, a white male passenger, causing Plaintiffs bicycle to hit the open car

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door and resulting in Plaintiff being thrown from his bicycle.

6. At said time and place, immediately following the collision. Defendant and his

aforesaid passenger who opened the car door stated to the Plaintiffthat Defendant’s car was in

Uber service and/or Lyft service at the time ofthe aforesaid collision.

7. At said time and place, following the aforesaid collision, a woman who, on

information and belief, was working at the Sprout Home store located at 745 N. Damen Avenue,

assisted Plaintiff at the scene ofthe collision and allowed Plaintiffto wash up in her store and

leave his bicycle tied to the post in front ofthe Sprout Home store.

8. At said time and place, following the collision, at or about 5:36 p.m.. Plaintiff

used the Uber App on his mobile phone to obtain an Uber ride from the Sprout Home store to

Plaintiffs home.

9. At all relevant times. Defendant, JOHN DOE, owed the Plaintiff, ERNEST

LANEY and all others on the roadway, a duty to exercise ordinary care in the operation of a car.

10. Notwithstanding this duty, on or about September 27, 2018, the Defendant, JOHN

DOE was negligent in one or more ofthe following respects:

2

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 9 of 21 PageID #:17
a. Failed to exercise due care in the operation of a motor vehicle to avoid colliding

CO with a person operating a bicycle in violation ofthe Illinois Vehicle Code, 625 ILCS 5/11- CO

CO

Ol 1003.1;

2 b. Stopped a motor vehicle on the roadway side of any vehicle stopped or parked at

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d the curb of a street in violation ofthe Illinois Vehicle Code, 625 ILCS 5/11-303(a);

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c. Failed to exercise due care to avoid colliding with any person operating a bicycle

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h- in violation ofthe Municipal Code ofChicago, Section 9-40-160; <

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d d. Discharged a passenger of a motor vehicle allowing the passenger door of a motor

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vehicle stopped in the roadway to be opened on the side available to moving traffic or a bicycle

lane without first checking that it was reasonably safe to open the car door in violation ofthe

M unicipal Code ofChicago, Section 9-80-035;

e. Discharged a passenger of a motor vehicle stopped in the roadway on the side of

the vehicle available to a bicycle lane; and

f Allowed the passenger door of a motor vehicle stopped in the roadway to be

opened on the side available to a bicycle lane without first checking that it was reasonably safe to

open the car door.

That as a direct and proximate result of one or more ofthe above-mentioned

negligent acts and/or omissions by the Defendant, JOHM DOE, the Plaintiff, ERNEST LANEY

suffered injuries of a severe and permanent nature, and damages including but not limited to,

disfigurement, pain and suffering, loss of a normal life, medical expenses and loss of income.

WHEREFORE, the Plaintiff ERNEST LANEY, demandsjudgment in his favor and

against the Defendant, JOHN DOE, in an amount in excess of Fifty Thousand Dollars ($50,000),

together with the costs ofthis lawsuit.

3

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 10 of 21 PageID #:18
COUNT II

AGENCY/VICARIOUS LIABILITY - UBER TECHNOLOGIES INC. CO

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1-1 1. Plaintiff hereby restates and incorporates paragraphs 1-11 ofCount 1 as o>

paragraphs 1-11 ofthis Count 11.

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At all relevant times, the Defendant, UBER TECHNOLOGIES INC. ('‘UBER”), o 12.

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was a corporation incorporated in the state of Delaware, registered as a foreign corporation in

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LU 13. At all relevant times, the Defendant UB.ER made the driver version of its Uber

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App available for the use ofthe Defendant, JOHN DOE, such that the Uber App allowed the

Defendant, JOHN DOE, to connect with potential riders paying for transportation services.

14. At all relevant times, the Defendant JOHN DOE, in using the driver version ofthe

Uber App, was representing the Defendant, UBER, with or without compensation for Defendant

UBER, in providing transportation services to a third person, who as a fare-paying passenger of

Defendant JOHN DOE's car opened the car door into the path of Plaintiffs bicycle being

operated in the bike lane.

15. At all relevant times, the Defendant JOHN DOE, in using the driver version ofthe

Uber App, was doing an activity of providing transportation services to a third person, the

aforesaid fare-paying passenger of Defendant JOHN DOE’s car, as may reasonably be said to

have been contemplated by the Defendant, UBER.

16. At all relevant times the Defendant UBER, by and through its agent, JOHN DOE,

owed the Plaintiff, ERNEST LANEY and all others on the roadway, a duty to exercise ordinary

care in the operation of a car.

4

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 11 of 21 PageID #:19
17. That the Defendant, USER, by and through its agent, JOHN DOE, breached that

CO duty in one or more ofthe ways alleged in the above paragraph 10. CO

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O) 18. That as a direct and proximate result of one or more ofthe above-mentioned

negligent acts and/or omissions by the Defendant, USER, by and through its agent, JOHN DOE,

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the Plaintiff, ERNEST LANEY suffered injuries of a severe and permanent nature, and damages O

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CO including but not limited to, disfigurement, pain and suffering, loss of a normal life, medical

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expenses and loss ofincome.. <

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LU WHEREFORE, the Plaintiff ERN EST LANEY, demandsJudgment in his favor and

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against the Defendant, UBER TECHNOLOGIES INC., in an amount in excess of Fifty

Thousand Dollars ($50,000), together with the costs ofthis lawsuit.

COUNT III

AGENCY/VICARrOUS LIABILITY - LYFT, INC.

1.-11. Plaintiff hereby restates and incorporates paragraphs I - I I ofCount 1 as

paragraphs 1-11 ofthis Count HI.

12. At all relevant times, the Defendant, LYFT, INC. (“LYFT”), was a corporation

incorporated in the state of Delaware, registered as a foreign corporation in Illinois with the

foreign assumed name Lyft Illinois, Inc., qualified to business in Illinois, and doing business in

Illinois.

13. At all relevant times, the Defendant LYFT made the driver version of its Lyft App

available for the use ofthe Defendant, JOHN DOE, such that the Lyft App allowed the

Defendant, JOHN DOE, to connect with potential riders paying for transportation services.

5

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 12 of 21 PageID #:20
14. At all relevant times, the Defendant JOHN DOE, in using the driver version ofthe

Lyft App, was representing the Defendant, LYFT, with or without compensation for Defendant

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LYFT, in providing transportation services to a third person, who as a fare-paying passenger of O)

5 Defendant JOFIN DOE’s car opened the car door into the path of Plaintiffs bicycle being

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o operated in the bike lane.

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15. At all relevant times, the Defendant JOHN DOE, in using the driver version ofthe

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ID=! aforesaid fare-paying passenger of Defendant JOHN DOE’s car, as may reasonably be said to

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have been contemplated by the Defendant, LYFT.

16. At all relevant times the Defendant LYFT, by and through its agent, JOHN DOE,

owed the Plaintiff, ERNEST LANEY and all others on the roadway, a duty to exercise ordinary

care in the operation of a car.

17. That the Defendant, LYFT, by and through its agent, JOHN DOE, breached that

duty in one or more ofthe ways alleged in the above paragraph 10.

18. That as a direct and proximate result of one or more ofthe above-mentioned

negligent acts and/or omissions by the Defendant, LYFT, by and through its agent, JOHN DOE,

the Plaintiff, ERNEST LANEY suffered injuries of a severe and permanent nature, and damages

including but not limited to, disfigurement, pain and suffering, loss of a normal life, medical

expenses and loss of income..

WHEREFORE, the Plaintiff ERNEST LANEY, demandsJudgment in his favor and

against the Defendant, LYFT, INC., in an amount in excess of Fifty Thousand Dollars ($50,000),

together with the costs ofthis lawsuit.

6

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 13 of 21 PageID #:21
00 Respectfully submitted,

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O) s/Grei^orv J. 01mstead

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csj One of Plaintiffs Attorneys

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THE DERATANY FIRM

221 N. LaSalle Street, Suite 2200

Chicago, IL 60601

(312)857-7285

Firm ID No. 30900

ARDC No. 6188659

01in stead@1 awi n i u rv. com

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Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 14 of 21 PageID #:22
(^0. Wolters Kluwer

PROCESS SERVER DELIVERY DETAILS

Date: Thu, Apr 9, 2020

Server Name: Steven Simon

Location: Chicago, IL-CHI

Entity Served Lyft Illinois Inc.

Agent Name

Case Number 2019L009338

Jurisdiction IL-CHI

Exhibit C

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 15 of 21 PageID #:23
DATE OF BIRTH

SR 1050C JANUARY 2013 

Printed by authority of the State of llinois

TAKEN TO

TELEPHONE

CITY STATE ZIP INJURY EJECT

27 28

SEX SAFT AIR

25 26

DRIVER LICENSE NO. STATE CLASS

EMS AGENCY

CIRCLE NUMBER(S)

FOR DAMAGED AREA(S)

00 - NONE

10 - UNDER CARRIAGE

11 - TOTAL (ALL AREAS)

12 - OTHER

99 - UNKNOWN

POINT OF

FIRST CONTACT

CIRCLE NUMBER(S)

FOR DAMAGED AREA(S)

00 - NONE

10 - UNDER CARRIAGE

11 - TOTAL (ALL AREAS)

12 - OTHER

99 - UNKNOWN

POINT OF

FIRST CONTACT

COUNTY

/ / mo day yr

36 DATE OF CRASH TIME

DAMAGE TO ANY

ONE PERSON’S

VEHICLE / PROPERTY

38 NUMBER MOTOR

VEHICLES INVLD

: AM

PM

INSURANCE CO.

TELEPHONE POLICY NO.

MAKE MODEL YEAR

PLATE NO. STATE YEAR

VIN

VEHICLE OWNER (LAST, FIRST M.I.)

OWNER ADDRESS (STREET, CITY, STATE, ZIP)

INSURANCE CO.

TELEPHONE POLICY NO.

MAKE MODEL YEAR

PLATE NO. STATE YEAR

VIN

VEHICLE OWNER (LAST, FIRST M.I.)

TAKEN TO OWNER ADDRESS (STREET, CITY, STATE, ZIP)

TELEPHONE

CITY STATE ZIP

DRIVER LICENSE NO.

EMS AGENCY

34 ADDRESS NO. HIGHWAY or STREET NAME

(CIRCLE) (CIRCLE)

F T / M I N E S W

AT INTERSECTION WITH (NAME OF INTERSECTION OR ROAD FEATURE)

TYPE OF REPORT

ON SCENE

NOT ON SCENE (DESK REPORT)

AMENDED

YR

1 DRAC 2 PEDV 3 TRFD 4 TRFC 5 WEAT 6 DRVA 7 VIS 8 VEHD 9 LGHT 10 COLL 11 MANV 12 PPA 13 PPL

/ /

/ /

/ /

/ /

/ /

U

N

I

T

U

N

I

T

43 DAMAGED PROPERTY OWNER NAME DAMAGED PROPERTY

PROPERTY OWNER ADDRESS CITY STATE ZIP

ARREST NAME SECTION CITATION NO.

46 STAR NO. SIGNATURE 47 BEAT 48 SUPERVISOR SIGNATURE/STAR NO.

44 ARREST NAME SECTION CITATION NO.

1

2

3

1

2

3

(EVNO) (MOST) (EVNT) (LOC)

29 30

REMEMBER TO USE BLACK INK, PRESS HARD, PRINT LEGIBLY AND COMPLETE ALL REQUIRED F

CONTRIBUTORY

CAUSE(S)

PRIMARY

SECONDARY

TIME NOTIFIED

DID CRASH 

IN A WORK 

WORKERS 

IF YES CHE

: AM

PM

: AM

PM

CONSTR

MAINTE

UTILITY

UNKNOWN 

45 DATE POLICE NOTIFIED

mo /day /yr

COURT DATE

mo /day /yr

COURT TIME

INTERSECTION

RELATED Y N

PRIVATE

PROPERTY Y N

HIT & RUN Y N

STREET ADDRESS

UNIT UNIT

U U U U U U U U U U

POSTED

SPEED

LIMIT

INVESTIGATING AGENCY

STREET ADDRESS

No Injury / Drive Away

Injury and / or Tow Due To Crash

A

B

(LAST, FIRST, MI)

DRIVER PARKED DRIVERLESS PED PEDAL EQUES NMV NCV DATE OF BIRTH

DRIVER PARKED DRIVERLESS PED PEDAL EQUES NMV NCV 

NAME

(LAST, FIRST, MI)

$500 OR LESS

$501 - $1,500

OVER $1,500

NAME

Y

N

DOORING

WITH

PEDALCYCLIST?

Y 

TOWED

DUE TO CRASH

FIRE

CELLPHONE

EXCEED SPEED LIMIT

COM VEH

* IF YES SEE SIDEB

/ / mo day yr

*

Y 

TOWED

DUE TO CRASH

FIRE

CELLPHONE

EXCEED SPEED LIMIT

COM VEH

* IF YES SEE SIDEB

*

INJURY EJECT 27 28

SEX SAFT AIR

25 26

STATE CLASS

/ / mo day yr

(UNIT) (SEAT)

24

(DOB) (SEX) (SAFT)

25

(AIR)

26

(INJ)

27

(EJCT)

28

40 PASSENGERS & WITNESSES ONLY (NAME) / (ADDR) / (TEL) 41 (HOSP) 42 (EMS)

(CIRCLE) CITY

N E S W

37

Y

PHOTO(S)

TAKEN

BEAT OF OCCURREN

33 R.D. NUMBER

CHICAGO POLICE DEPARTMENT

CHICAGO

COOK

STATEME

TAKE

N Y 

31 32

35

39

39

1 1 1 1 1

1

1

JB492119 1 1 1

6

1

CHICAGO 9IL 

0

99 UNKNOWN IL 

NONE 1

JEFFERSON, WANDA 22 

1

27 11 X

2 2 2 2 2

2

2

1

04 2

606 M

UNKNOWN 13 

01 

1

1

1221 5

1

1

13 2

(

9

N/A 

LANEY IV, ERNEST, J. UNKNOWN N/A 474 P. KONTIL / 1391 2018 0

2018 NONE DAMEN AVE 45 

1

UNKNOWN / , , IL, / 1702 

09 C1190819

56 99 10 2018 27 7

UNKNOWN 03 

99 

25 *CP002*

*X001336062*

RedactedRedactedRedacted RedactedRedacted Redacted Redacted

Exhib
INDICATE NORTH

BY ARROW

(Refer to vehicle by Unit No.)

COMMERCIAL MOTOR VEHICLE (CMV)

IF MORE THAN ONE CMV IS INVOLVED, USE SR 1050A

ADDITIONAL UNITS FORMS.

A CMV is defined as any motor vehicle used to transport

passengers or property and:

1. Has a weight rating of more than 10,000 pounds (example: truck

or truck/trailer combination); or

2. Is used or designed to transport more than 15 passengers,

including the driver (example: shuttle or charter bus); or

3. Is designed to carry 15 or fewer passengers and operated by a

contract carrier transporting employees in the course of their

employment (example: employee transporter usually a van type

vehicle or passenger car); or

4. Is used or designated to transport between 9 and 15 passengers,

including the driver, for direct compensation (example: large van used

for specific purpose); or

5. Is any vehicle used to transport any hazardous material

(HAZMAT) that requires placarding (example: placards will be

displayed on the vehicle).

Did HAZMAT spill from the vehicle (do not consider fuel from the

vehicle’s own tank)? Y N UNK

Did HAZMAT Regulations violation contribute to the crash? 

Y N UNK

Did Motor Carrier Safety Regulations (MCS) violation contribute to

the crash? Y N UNK

Was a Driver/Vehicle Examination Report form completed?

HAZMAT Y N UNK Out of Service? Y N

MCS Y N UNK Out of Service? Y N

Form No. _____________________________

56 IDOT PERMIT NO. ______________ WIDE LOAD? Y N

TRAILER WIDTH(S): 0 96” 97 102” >102”

TRAILER 1

TRAILER 2

TRAILER LENGTH(S): 1 ________ ft TRAILER 2 ________ ft

TOTAL VEHICLE LENGTH _______ ft NO. OF AXLES ______ 

CRASH LOCATION: CITY OF OR NEAREST CITY

_________ MILES N E S W OR ____________________________

SELECT CODES FROM BACK COVER OF CRASH BOOKLET:

VEHICLE CONFIGURATION ________

CARRIER NAME ___________________________________________

ADDRESS ________________________________________________

________________________________________________

CITY/STATE/ZIP ___________________________________________

54 USDOT NO. ______________________ ILCC NO.______________

52 Source of above info. Side of Truck Papers Driver Log Book

53 Gross Vehicle Weight Rating (GVWR)________________________________ 

Were HAZMAT placards displayed on the vehicle? Y N

If yes, name on placard _________________________________________

4-digit UN no. __________________ 1-digit Hazard Class no. ________

N

SEX - RACE AGE HAIR COL DISTINGUSHING MARKS / CLOTHING DESCRIPTION UNIT NO. VEH. COLOR

SSINGEDDATE ASSINGED SUPV. STAR NO. IF CASE CLEARED HOW

ARREST PROSECUTION

CITATION NO.

OURT DATE TIME AM

PM

CHARGES EXC. CLEARED

TIM CANNOT ID OFFENDER NO INVESTIGATIVE LEADS VEH. STOLEN-RD NO.

LETTER TO CONTACT RETURNED BY POST OFF. WARRANT OBTAINED OTHER (Specify)

VEH. REGISTRATION UNAVAILABLE INSUFFICIENT EVIDENCE FOR ARREST

NATURE STAR NODATE (Day-Mo-Yr) APPROVED SIGNATURE STAR NO

55

57

CHICAGO

CIRCLE ONE CITY NAME

R. D. NUMBER 51

JB492119

 #06169 - IN SUMMARY, UNIT 2 CAME INTO DISTRICT RELATING THAT HE

DING HIS BICYCLE NB ON DAMEN AVENUE WHEN UNIT 1'S (UNKNOWN)

NGER DOOR OPENED AND HIT UNIT 2 CAUSING UNIT 2 TO LAND ON THE

ND AND OBTAIN ASSISTANCE FROM A STORE OWNER FROM SPROUT

 LOCATED 745 N. DAMEN. UNIT 2 FURTHER RELATES HE DID NOT OBTAIN

FORMATION ON THE VEHICLE NOR DID HE GO TO THE HOSPITAL ON THE

F THE ACCIDENT.

RELATES THAT HE DID NOT GO TO THE HOSPITAL UNTIL A COUPLE OF

ATER BECAUSE HE COULDN'T WALK.

BECAUSE OF INJURIES UNIT 2 COULD NOT COME IN TO PERFORM

T.

1336062

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 17 of 21 PageID #:25
Exhibit E

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 18 of 21 PageID #:26
Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 19 of 21 PageID #:27
Exhibit F

Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 20 of 21 PageID #:28
Case: 1:20-cv-02811 Document #: 1-1 Filed: 05/08/20 Page 21 of 21 PageID #:29