under the supplemental jurisdiction of this Court to entertain claims arising under state law.
3.01.Venue is proper in the Northern District of Texas, Dallas Division, pursuant to 28U.S.C. § 1391(c ) as Geheb is subject to personal jurisdiction in the Dallas Division of the Northern District of Texas and City of Keene is located in the Dallas Division of the Northern District of Texas.
IV. Factual Background
4.01.On or about August 18, 2012, Geheb effected a traffic stop of the vehicle beingoperated by Plaintiff within the City of Keene, Texas.4.02.Geheb established contact with Plaintiff and informed her that she was stopped for speeding, but within less than thirty seconds of first speaking with her, he forcibly yankedher from the driver seat of her SUV and threw her to the ground.4.03.Plaintiff was then handcuffed and detained in the back of Geheb’s patrol car.4.04.At the time of the traffic stop set forth above, Plaintiff was 77-years old and agrandmother.4.05.Plaintiff suffered
a painfully-bruised tailbone, bruising on her arm, and a soreshoulder as a result of being yanked to the ground out of her driver’s seat by Geheb.
4.06.At all time relevant to the facts set forth in this complaint, Defendant Geheb wasacting under his own capacity and the color of the statutes, ordinances, regulations, customs
Lynn Shelton Bedford v. Keene,
. -Plaintiff’s Original ComplaintPage 2 of 7
Case 3:14-cv-02944-N Document 1 Filed 08/15/14 Page 2 of 7 PageID 2