CHRISTOPHER PENDER, individually, RYAN N. DUNPHY, individually, and JAMIE K. KNOX, individually, and alleges:
1. This is an action for injunctive relief and money damages under 42 U.S.C. §§1983 and
1988, the Driver’s Privacy Protection Act o
f 1994, 18 U.S.C. §§2721 et seq.
the Fourth Amendment, the Fourteenth Amendment, and other protections afforded by the United States Bill of Rights and the laws of the State of Florida to recover damages
for Defendants’ disregard and invasion of Plaintiff’s constitutionally protected
right to privacy. Jurisdiction of this Court is invoked pursuant 28 U.S.C. §1331 (federal question jurisdiction) and 28 U.S.C. §1343 (civil rights claim jurisdiction). 2. The amount in controversy exceeds Seventy Five Thousand Dollars ($75,000.00), including interests and costs. 3. All conditions precedent to the maintenance of this action have been performed or have been waived.
4. At all times pertinent hereto, Plaintiff, ROBERT BRAYSHAW, has been a resident of Leon County, Florida
5. At all times pertinent hereto, Plaintiff, STEPHANIE BRAYSHAW, has been a resident of Leon County, Florida
Case 4:14-cv-00361-RH-CAS Document 1 Filed 07/08/14 Page 2 of 16