DOCUMENT 2 ELECTRONICALLY FILED 5/31/2018 3:53 PM 70-CV-2018-900079.00 CIRCUIT COURT OF TALLAPOOSA COUNTY, ALABAMA PATRICK CRADDOCK, CLERK
IN THE CIRCUIT COURT OF TALLAPOOSA COUNTY, ALABAMA SANDRA MACHEN,
) ) PLAINTIFF, ) ) VS. ) CIVIL ACTION NO. ) CHARLES SHAW, ) AN INDIVIDUAL, ) ) CHARLES SHAW, in his official capacity ) as mayor of Alexander City, and Alexander ) City, AL, a municipal corporation, and ) ) FICTITIOUS DEFENDANTS, 1 - 10, ) being the persons or entities ) which intentionally, negligently, recklessly, ) maliciously, willfully, and/or wantonly, harmed ) the Plaintiff by committing some or all of the ) acts and/or omissions set out in this Complaint, ) and whose identity are unknown to the Plaintiff ) and will be added by amendment when ) ascertained. ) DEFENDANTS. ) COMPLAINT COUNT ONE PARTIES 1. Plaintiff, Sandra Machen, is a resident of Tallapoosa County, Alabama, and is subject to the jurisdiction of this court (hereinafter referred to as “Plaintiff”). Plaintiff is over the age of 19 years. 2. Plaintiff is the former Finance Director (an unelected employee) of the City of Alexander City, Alabama, a municipal corporation. 3. Defendant, Charles Shaw, upon information and belief, is a resident of Tallapoosa County, Alabama, and is subject to the jurisdiction of this court (hereinafter referred to as