Raven-Hansen Pleading

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Drafting Exercise

1. Plaintiff is a citizen of the State of Pennsylvania and defendant is a corporation incorporated under the laws of the State of Maryland having its principal place of business in a state other than the State of Pennsylvania. The matter in controversy exceeds, exclusive of interest and costs, the sum specified by 28 U.S.C. § 1332.

2. Defendant maliciously filed a criminal complaint against plaintiff, charging violation of the Pennsylvania bad check statute, 18 Pa.C.S.A. §4105, when the defendant knew that plaintiff had stopped payment on her check because of a dispute over defective merchandise. Store manager, assistant manager who filed the complaint and corporate president of the defendant corporation acknowledged to plaintiff that they was aware of the facts of the situation and condoned and supported the malicious prosecution of the plaintiff.

3. Plaintiff was aware that payment was not refused by the drawee for lack of funds and that defendant did not issue or pass the check knowing that it would not be honored because plaintiff had no account with the drawee.

4. Mrs. Rannels was acquitted of the criminal offense.

5. There was no probable cause that plaintiff had violated the Pennsylvania bad check statute because her bank had paperwork showing that plaintiff had an account with the bank, had sufficient funds for the payment and stopped payment on her check in dispute over defective merchandise.

Wherefore plaintiff demands judgment against the defendant in the sum of 2,800,000 dollars in damages.

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