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IN THE CIRCUIT
COURT
OF
DAVIDSON COUNTY, TENNESSEE
AT NASHVILLE
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MEREDITH MANNING, )
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Plaintiff, )
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v.
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CORRECTIONS CORPORATION, )
OF
AMERICA, INC.
and
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THE
METROPOLITAN HOSPITAL )
AUTHORITY d/b/a NASHVILLE )
GENERAL HOSPITAL
at
MEHARRY, )
Defundanb. )
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Case No. 05C-2608
JURY
TRIAL
DEMANDED (12)
THIRD AMENDED COMPLAINT
COMES NOW
Plaintiff Meredith Manning, by Counsel, and files this Amended
Complaint against Defendant Corrections Corporation
of
American, Inc. (hereinafter "CCA")
and Defendant The Metropolitan Hospital Authority d/b/a Nashville General Hospital at Meharry
(hereinafter, "NGH"). The Complaint is amended to allege facts unintentionally omitted
in
the
previous complaint in Counts I, III,
V,
VI, VII, VIII, IX and
X.
In support
of
her action, Plaintiff
states the following grounds:
Parties, Jurisdiction,
and
Venue
1.
Plaintiff Meredith Manning, is a citizen and resident
of
Nashville, Davidson
County, Tennessee, and was, at
the
time
of
the actions which form
the
basis
of
this complaint, in
the custody
of
Defendant Corrections Corporation
of
America, Inc. located at 5115 Harding
Place,
Nashville, Davidson County, Tennessee 37211.
2. Defendant Corrections Corporation
of
America, Inc. is a Maryland corporation,
whose principal office is located at
10
Burton Hills Boulevard, Nashville, Davidson County,
Tennessee 37215. At all times relevant to this action,
CCA
conducted business within