1. Plaintiffs have satisfied all the provisions of A.R.S. § 12-821.01 by timely servingNotice of Claim more than sixty (60) days prior to the date of the filing of this Complaint.Defendants denied the Notice of Claim by failing to respond thereto.2. Plaintiffs bring this action pursuant to 42 U.S.C. § 1983, the United States Constitution(certain Amendments), and other pendent statutory and state common laws.3. This Court has jurisdiction of Plaintiffs’ federal law claims pursuant to 28 U.S.C. § 1331and 42 U.S.C. §1988. Additionally, this Court has jurisdiction over Plaintiffs’ state and federalclaims pursuant to Article 6, Section 14 of the Arizona Constitution.4. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b), as the parties areresidents of Maricopa County, Arizona, and the events underlying this lawsuit occurred inMaricopa County.
GENERAL LITIGATION ALLEGATIONS
5. At all times material herein, Plaintiffs Maria Brandon (“Brandon” or “Plaintiff” or“Plaintiff Brandon”) and Jerry Brandon were a married couple residing in Maricopa County,Arizona. Between September 1979 and June 2011, Plaintiff Maria Brandon was employed topractice law by Defendant Maricopa County in various capacities and in various offices.6. At all times material herein, Defendant Rocky Armfield (“Armfield” or Risk ManagerArmfield”) was the Risk Manager and/or the Risk Management Claims Manager or AssistantRisk Manager of Maricopa County with authority and responsibility for the Maricopa CountyRisk Management Department, its employees and agents, and with the authority andresponsibility to establish policy, practices, customs, procedures, protocols and training for the
Case 2:12-cv-00788-DKD Document 1 Filed 04/13/12 Page 2 of 29