Attorney No. 16980 

STATE OF ILLINOIS 

COUNTY OF COOK 

) 

) 

) 

SS 

FILED 

6/10/2020 11:10 AM 

DOROTHY BROWN 

CIRCUIT CLERK 

COOK COUNTY, IL 

2020L006204 

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 

COUNTY DEPARTMENT, LAW DIVISION 

EVANGELIA DEVETZI, 

Plaintiff, 

V. 

) 

TOYOTA MOTOR NORTH AMERICA, ) 

INC., a corporation; and TOYOTA MOTOR) 

SALES, U.S.A., INC., a corporation; ) 

) 

Defendants. ) 

Case No.: 

COMPLAINT AT LAW 

NOW COMES Plaintiff, EVANGELIA DEVETZI, by and through her attorney, Dean J. 

Caras, and complaining of Defendants, TOYOTA MOTOR NORTH AMERICA, INC. 

("TOYOTA NORTH AMERICA"), a corporation; and TOYOTA MOTOR SALES, U.S.A., 

INC. ("TOYOTA SALES"), a corporation; states as follows: 

COUNT I: STRICT PRODUCTS LIABILITY AGAINST TOYOTA NORTH AMERICA 

1. Plaintiff is a resident of the state of Illinois. 

2. Defendant, TOYOTA NORTH AMERICA, a corporation incorporated to do business 

in the state of California, does business in the City of Chicago, County of Cook, State 

of Illinois. 

3. On April 6, 2019, and for a long time prior to that date, Defendant, TOYOTA 

NORTH AMERICA, was engaged in the business of designing and manufacturing 

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motor vehicles for sale to members of the general public, including motor vehicles of 

the model name Yaris. 

4. Prior to April 6, 2019, Defendant, TOYOTA NORTH AMERICA, manufactured a 

2010 Toyota Yaris for ultimate sale to members of the general public, including 

Plaintiff herein. 

5. Prior to April 6, 2019, Plaintiffs spouse, Haralampos Karaidos, purchased a 2010 

Toyota Yaris with vehicle identification number (VIN) JTDKT4K34A5318318 

("Plaintiffs motor vehicle"). 

6. On April 6,2019, Plaintiffs daughter, Maria Karaindrou, was driving Plaintiff's 

motor vehicle, in which Plaintiff was the passenger, on Army Trail Road at or about 

its intersection with Gladstone Drive, in the Village of Glendale Heights, County of 

DuPage, State of Illinois. 

7. At the time and place previously mentioned, Plaintiff was involved in a motor vehicle 

collision in which Plaintiffs motor vehicle was struck on its rear end. 

8. At the time Plaintiff's motor vehicle was manufactured by and left the control of 

Defendant, TOYOTA NORTH AMERICA, the motor vehicle was in a condition that 

was unreasonably dangerous, defective, and unsafe in that: 

a. Plaintiff's motor vehicle was not reasonably safe for its reasonably 

foreseeable use, in that the seats of the motor vehicle were not adequately or 

sufficiently secured to its floor to withstand the impact of a motor vehicle 

accident without becoming detached from the floor of the motor vehicle; 

b. Plaintiff's motor vehicle was uncrashworthy in that a collision with a vehicle 

was likely and liable to cause its seats to become detached and cause injury to 

persons inside the motor vehicle; 

c. There were no adequate warnings as to the dangers of Plaintiff's motor 

vehicle, in particular the danger of the seats of said vehicle becoming 

detached from its floor in the event of an automobile accident; and 

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d. Plaintiff's motor vehicle was otherwise unreasonably dangerous, defective, 

and unsafe. 

9. One or more of these defects existed when Plaintiff's motor vehicle left Defendant 

TOYOTA NORTH AMERICA's control, making Plaintiff's motor vehicle 

unreasonably dangerous because it failed to perform in the manner reasonably to be 

expected in light of Plaintiff's motor vehicle's nature and intended function and/or 

- because the magnitude of the dangers outweighed the utility of Plaintiff's motor 

vehicle. 

10. As a direct and proximate result of the condition of Plaintiff's motor vehicle as 

aforesaid, the seats of Plaintiff's motor vehicle detached upon the rear-end impact of 

the motor vehicle accident on April 6, 2019, causing injuries to Plaintiff. 

11. By reason of the premises and as a direct and proximate result of the aforesaid 

condition of Plaintiff's motor vehicle, Plaintiff was caused to suffer temporary and 

permanent disabling injuries by reason of which Plaintiff has expended and incurred 

obligations of medical expenses and care and will in the future expend and incur such 

further obligations; Plaintiff has been and will be prevented from attending to her 

usual affairs and duties and has lost and will continue to lose great gains Plaintiff 

would otherwise have made and acquired, and has lost wages; Plaintiff has been and 

will continue to be subject to great pain and suffering. 

WHEREFORE, Plaintiff, EVANGELIA DEVETZI, asks for judgment against 

Defendant, TOYOTA MOTOR NORTH AMERICA, INC., in an amount in excess of the 

jurisdictional requirements of this Court plus costs, and for any such other relief this Honorable 

Court deems just and proper. 

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COUNT II: NEGLIGENCE AGAINST TOYOTA NORTH AMERICA 

12. Plaintiff restates and realleges all prior paragraphs as though fully stated herein. 

13. Defendant, TOYOTA NORTH AMERICA, had a duty to design, manufacture, sell, 

and/or distribute motor vehicles that were safe and would not cause harm to 

foreseeable users, including Plaintiff herein. 

14. At the time Defendant, TOYOTA NORTH AMERICA, manufactured Plaintiff's 

motor vehicle and said motor vehicle left Defendant TOYOTA NORTH AMERICA's 

control, Defendant, TOYOTA NORTH AMERICA, carelessly and negligently: 

a. Designed, manufactured, and/or distributed for ultimate sale a motor vehicle 

that was not reasonably safe for its reasonably foreseeable use and imposed an 

unreasonable risk of harm on the ultimate user, in particular Plaintiff herein, in 

that the seats of Plaintiff's motor vehicle were not adequately or sufficiently 

secured to its floor to withstand the impact of a motor vehicle accident 

without becoming detached from the floor of said motor vehicle; 

b. Designed, manufactured, and/or distributed for ultimate sale a motor vehicle 

that was uncrashworthy in that a collision with a vehicle was likely and liable 

to cause its seats to become detached and cause injury to persons inside the 

motor vehicle, in particular Plaintiff herein; 

c. Failed to provide adequate warnings as to the dangers of Plaintiff's motor 

vehicle, in particular the danger of the seats of said vehicle becoming 

detached from the floor of said vehicle in the event of an automobile accident; 

d. Failed to furnish adequate devices to secure the parts of Plaintiff's motor 

vehicle, in particular the connection between the seats and the floor of said 

vehicle, so that they would not come apart while in operation; and 

e. Was otherwise careless and negligent. 

15. As a direct and proximate result of one or more of the foregoing careless and 

negligent acts and/or omissions of Defendant, TOYOTA NORTH AMERICA, the 

seats of Plaintiff's motor vehicle detached upon the rear-end impact of the motor 

vehicle accident on April 6, 2019, causing injuries to Plaintiff. 

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16. By reason of the premises and as a direct and proximate result of the foregoing 

careless and negligent acts and/or omissions of Defendant, TOYOTA NORTH 

AMERICA, Plaintiff was caused to suffer temporary and permanent disabling injuries 

by reason of which Plaintiff has expended and incurred obligations of medical 

expenses and care and will in the future expend and incur such further obligations; 

Plaintiff has been and will be prevented from attending to her usual affairs and duties 

and has lost and will continue to lose great gains Plaintiff would otherwise have made 

and acquired, and has lost wages; Plaintiff has been and will continue to be subject to 

great pain and suffering. 

WHEREFORE, Plaintiff, EVANGELIA DEVETZI, asks for judgment against 

Defendant, TOYOTA MOTOR NORTH AMERICA, INC., in an amount in excess of the 

jurisdictional requirements of this Court plus costs, and for any such other relief this Honorable 

Court deems just and proper. 

COUNT III: STRICT PRODUCTS LIABILITY AGAINST TOYOTA SALES 

17. Plaintiff restates and realleges all prior paragraphs as though fully stated herein. 

18. Defendant, TOYOTA SALES, a corporation incorporated to do business in the state 

of California, does business in the City of Chicago, County of Cook, State of Illinois. 

19. On April 6, 2019, and for a long time prior to that date, Defendant, TOYOTA 

SALES, was engaged in the business of sales, marketing, and distribution of motor 

vehicles for sale to members of the general public, including motor vehicles of the 

model name Yaris. 

20. Prior to April 6,2019, Defendant, TOYOTA SALES, put the 2010 Toyota Yaris into 

circulation for sale to members of the general public, including Plaintiff herein. 

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21. Prior to April 6, 2019, Plaintiff's spouse, Haralampos Karaidos, purchased Plaintiff's 

motor vehicle, a 2010 Toyota Yaris with vehicle identification number (V1N) 

JTDKT4K34A5318318 

22. On April 6, 2019, Plaintiff's daughter, Maria Karaindrou, was driving Plaintiff's 

motor vehicle, in which Plaintiff was a passenger, on Army Trail Road at or about its 

intersection with Gladstone Drive, in the Village of Glendale Heights, County of 

DuPage, State of Illinois. 

23. At the time and place previously mentioned, Plaintiff was involved in a motor vehicle 

collision in which Plaintiff's motor vehicle was struck on its rear end. 

24. At the time Plaintiff's motor vehicle was sold by and left the control of Defendant, 

TOYOTA SALES, the motor vehicle was in a condition that was unreasonably 

dangerous, defective, and unsafe in its design and manufacture in that: 

a. Plaintiff's motor vehicle was not reasonably safe for its reasonably 

foreseeable use, in that the seats of the motor vehicle were not adequately or 

sufficiently secured to its floor to withstand the impact of a motor vehicle 

accident without becoming detached from the floor of the motor vehicle; 

b. Plaintiff's motor vehicle was uncrashworthy in that a collision with a vehicle 

was likely and liable to cause its seats to become detached and cause injury to 

persons inside the motor vehicle; 

c. There were no adequate warnings as to the dangers of Plaintiff's motor 

vehicle, in particular the danger of the seats of said vehicle becoming 

detached from its floor in the event of an automobile accident; and 

d. Plaintiff's motor vehicle was otherwise unreasonably dangerous, defective, 

and unsafe. 

25. One or more of these defects existed when Plaintiff's motor vehicle left Defendant 

TOYOTA SALES's control, making Plaintiff's motor vehicle unreasonably 

dangerous because it failed to perform in the manner reasonably to be expected in 

, 

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light of Plaintiff's motor vehicle's nature and intended function and/or because the 

magnitude of the dangers outweighed the utility of Plaintiffs motor vehicle. 

26. As a direct and proximate result of the condition of Plaintiff's motor vehicle as 

aforesaid, the seats of Plaintiffs motor vehicle detached upon the rear-end impact of 

the motor vehicle accident on April 6, 2019, causing injuries to Plaintiff. 

27. By reason of the premises and as a direct and proximate result of the aforesaid 

condition of Plaintiffs motor vehicle, Plaintiff was caused to suffer temporary and 

permanent disabling injuries by reason of which Plaintiff has expended and incurred 

obligations of medical expenses and care and will in the future expend and incur such 

further obligations; Plaintiff has been and will be prevented from attending to her 

usual affairs and duties and has lost and will continue to lose great gains Plaintiff 

would otherwise have made and acquired, and has lost wages; Plaintiff has been and 

will continue to be subject to great pain and suffering. 

WHEREFORE, Plaintiff, EVANGELIA DEVETZI, asks for judgment against 

Defendant, TOYOTA MOTOR SALES, U.S.A., INC., in an amount in excess of the 

jurisdictional requirements of this Court plus costs, and for any such other relief this Honorable 

Court deems just and proper. 

Respectfully Submitted, 

/s/ Dean .1 Caras 

Dean J. Caras 

Dean J. Caras 

Attorney for Plaintiff 

320 W. Illinois St., Ste. 2312 

Chicago, IL 60654 

(312) 494-1500 

dean.caras@deancaras.com 

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