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IN THE CIRCUIT COURT FOR

HOUSTON COUNTY, ALABAMA

SUZETTE OSBORNE, )

)

Plaintiff, ))

v. ) Case No. CV-2012-____________

)

ANDREW OSBORNE, )

) Jury Trial Demanded

Defendant. )

____________________________ )

COMPLAINT

COMES NOW the Plaintiff in the above-styled matter, by and through counsel, and

hereby submits the following Complaint against the Defendant, to be answered in accordance

with, and pursuant to the time constraints of, the Alabama Rules of Civil Procedure.

STATEMENT OF THE PARTIES

1. Plaintiff, Suzette Osborne, is over the age of nineteen (19) years and is a resident

citizen of Houston County, Alabama.

2. Defendant, Andrew Osborne, is over the age of nineteen (19) years and is a

resident citizen of Houston County, Alabama.

STATEMENT OF THE FACTS

3. Plaintiff and Defendant, formerly husband and wife, were divorced by decree of

this Court on October 18, 2012.

4. During and throughout a substantial portion of the parties marriage, Plaintiff was

the victim of multiple instances of violent physical abuse at the hands of the Defendant.

ELECTRONICALLY FILED10/19/2012 2:14 PMCV-2012-900428.00

CIRCUIT COURT OFHOUSTON COUNTY, ALABAM

CARLA H. WOODALL, CLERK

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5. The final, and most severe, episode of abuse occurred on October 19, 2010, when

Defendant physically assaulted Plaintiff in the parties home, in the presence of the parties

minor children, and savagely beat her, causing serious and permanent injuries to the Plaintiff.

COUNT ONE

ASSAULT

6. Plaintiff re-affirms all prior paragraphs as if set out here in full.

7. Defendant did intentionally cause Plaintiff to be in fear of great bodily harm,

causing her to suffer mental anguish and emotional distress for which Plaintiff seeks damages

more fully described herein below.

COUNT TWO

BATTERY

8. Plaintiff re-affirms all prior paragraphs as if set out here in full.

9. Defendant did physically beat, strike, torture, and batter the Plaintiff, causing her

to suffer severe and permanent physical injuries, emotional distress, mental anguish, pain and

suffering, scarring, disfigurement, and medical expenses, for which Plaintiff seeks damages more

fully described herein below.

PRAYER FOR RELIEF

10. Plaintiff re-alleges all prior paragraphs as if set out here in full.

11. As a direct an proximate result of Defendant intentional, willful, tortuous and

criminal conduct as described herein above, Plaintiff was caused to suffer injuries and losses in

the form of severe and permanent physical injuries, emotional distress, mental anguish, pain and

suffering, scarring, disfigurement, and medical expenses.

12. Plaintiff requests that compensatory damages be awarded to her against the

Defendant, in an amount deemed appropriate by a struck jury, in excess of this Courts minimum

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jurisdiction, plus attorneys fees, costs of court, and any and all other equitable relief deemed

appropriate by this Court.

13. Plaintiff further requests that punitive damages be levied against the Defendant, in

an amount deemed appropriate by a struck jury.

Respectfully submitted this the 19th day of October, 2012.

TRIAL BY JURY DEMANDED ON ALL COUNTS.

/s/ M. Adam Jones

M. ADAM JONES (JON-126)

Attorney for the Plaintiff

Of Counsel:JACOBY & MEYERS, LLC

111 East Main Street

P.O. Box 5551Dothan, AL 36302

Tel: 334.794.8000Fax: 334.699.6885

SERVE DEFENDANT VIA CERTIFIED MAIL AS FOLLOWS:

Andrew Osborne

123 N. Idlewild Path

Dothan, AL 36303