COMPLAINT
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Transcript of COMPLAINT
United States District Court For the Middle District of Alabama
COMPLAINT
Plaintiff Laura Raskin Case No. 3648829A
-vs-
Defendant Bradley Harper Judge John Doe
Comes now plaintiff and for her cause of action against defendant alleges:
1. Plaintiff Laura Raskin and the decedent’s estate sue Defendant Bradley Harper for the
injuries and wrongful death of the decedent sustained in an automobile accident caused by
the negligence of the plaintiff. Jurisdiction of this court is based on 28 U.S.C.A. §
1332(a). The amount in controversy in Plaintiff Laura Raskin’s claim equals or exceeds
$75,000, exclusive of interests and costs. This court has supplemental jurisdiction to hear
and determine the claim of plaintiff Laura Raskin under 28 U.S.C.A. § 1367(a). Venue is
in conformity with the provisions of 28 U.S.C.A. § 1391(a).
2. Plaintiff Laura Raskin resides at 413 Monty Road, Destin, Okaloosa County, Florida.
3. Defendant Bradley Harper resides at 334 Green Road, Montgomery, Montgomery
County, Alabama.
4. On October 17th, 2000, Defendant Bradley Harper was operating his pickup truck along
County Road 13. Mr. Nordby was also driving along the same road just ahead of Mr.
Harper.
5. At the above mentioned time and place, Defendant Bradley Harper drove his vehicle at en
excessive rate of speed, which caused him to collide with the rear side of Mr. Nordby’s
car.
6. The above mentioned collision was caused by the negligence of the defendant. Such
negligence included, but was not limited to, driving at an excessive rate of speed, failing
to maintain control of the pickup, improperly passing, failing to signal a pass, and failing
to keep a proper lookout, all in violation of the motor vehicle laws and regulations then
and there in full force and effect in the State of Alabama.
7. As a direct and proximate result of the negligence of the defendant, as mentioned above,
Decedent William Nordby sustained serious and permanent injuries that led to his death.
During Mr. Nordby’s treatment, he also incurred $115, 345 in medical expenses. Plaintiff
Laura Raskin then incurred $4,772 in funeral and burial expenses for Mr. Nordby.
WHEREFORE, Plaintiff Laura Raskin demands judgment for relief against the defendant
in an amount to be determined at trial, but no less than $400,000, plus costs.
PLAINTIFF DEMANDS A JURY
________________________
Plaintiff
Sworn to and subscribed before me on this the 17th day of March, 2014.
_________________________
Notary Public
Respectfully submitted this the 17th day of March, 2014.
_________________________
Attorney For Plaintiff