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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF ARIZONA
MARIA BRANDON and JERRYBRANDON, wife and husbandPlaintiff(s),vs.TOM LIDDY and STACY LIDDY, husbandand wife; ROCKY ARMFIELD and CHRISARMFIELD, husband and wife;MARICOPA COUNTY, a municipal entity;and JOHN DOES I-VDefendant(s).Case No.: ____________________
COMPLAINT
(Jury Trial Requested)Plaintiffs Maria Brandon and Jerry Brandon, for their Complaint against Defendants,hereby allege as follows:
Larry J. Cohen, Esq.Arizona State Bar No.: 010192The Cohen Law FirmP. O. Box 10056Phoenix, AZ 85064(602) 266-3080602-265-6866 FAXljc@ljcohen.comAttorney for Plaintiffs
Case 2:12-cv-00788-DKD Document 1 Filed 04/13/12 Page 1 of 29
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JURISDICTIONAL ALLEGATIONS
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
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-3-123456789101112131415161718192021222324252627Risk Management Department and an official and final policymaker for Maricopa County Risk Management Department. His actions and inactions constitute actions of Maricopa County, andthe County is vicariously and directly liable for his wrongful conduct, as alleged herein. As theappointed Risk Manager and/or Claims Manager/Assistant Risk Manager appointed by theMaricopa County Board of Supervisors, Armfield has official, vicarious, direct, individual,and/or supervisory liability for the County and its officers, agents, and employees.7. Chris Armfield is the spouse of Defendant Rocky Armfield and is so designatedbecause the wrongful conduct of Defendant Armfield was engaged in for the benefit of theirmarital community, thereby rendering his spouse and marital community liable for suchconduct.8. Between April 18, 2011 and June 27, 2011, Defendant Tom Liddy was the PracticeGroup Leader and supervisor of the newly-created Litigation Group of the Maricopa CountyAttorney’s Office (MCAO), Civil Services Division. As such, Defendant Liddy had authorityand responsibility for managing and assigning Maricopa County Risk Management lawsuitswithin his group, and had the authority and responsibility to establish policy, practices,customs, procedures, protocols and training for the Litigation Group, and was an official andfinal policymaker for MCAO and for Maricopa County. His actions and inactions constituteactions of MCAO and Maricopa County, and the County is vicariously and directly liable forhis wrongful conduct, as alleged herein.9. Stacy Liddy is the spouse of Defendant Tom Liddy and is so designated because thewrongful conduct of Defendant Liddy was engaged in for the benefit of their maritalcommunity, thereby rendering his spouse and marital community liable for such conduct.
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