AFFIDAVIT OF JERRY JERNIGAN

BEFORE ME, the undersigned, a Notary Public in and for said county, personally appeared,
Jerry Jernigan, who being first duly sworn deposes and states as follows:
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My name is Jerry Jernigan, and I am of sound mind. I have personal knowledge of the
facts below and make this affidavit upon oath and affirmation of belief that the things,
matters and facts set forth are true and correct.
I understand that this affidavit is sworn testimony subject to the penalties of perjury,
and I am giving true testimony based on my first hand knowledge of the situation
described. I am over the age of nineteen (19) years old and I reside in Montevallo,
Shelby County, Alabama.
I am the husband of Peggy Jernigan. We have been married for 44 years.
We reside together at 155 Depot Street in Montevallo, Alabama. We have lived there
since 2009.
My wife was involved in an incident on a Clas Tran bus on or around October 31,
2014. She sustained bodily injuries in the incident and has suffered with continuous
pain, discomfort, treatment issues, lifestyle displacement, and daily life disruptions
ever since the incident. I have been her daily caretaker since the incident and have
listed below the primary changes I have seen Peggy suffer through and the disruptions
she and our family now encounter:
a. Loss of Use. Peggy suffers continuous pain in her left shoulder and left leg since
the incident. Specifically, she has lost range and usage of her shoulder/arm and
usage of her leg. This has crippled her movement and created a need for constant
care.
b. Disruption in sleep. We both no longer can have restful nights sleep because of
her limited movement since the incident. I get up with her 2-4 times per night to
help her reposition her body for comfort.
c. Confinement to home. Since the incident, Peggy suffers so much pain that we
have to limit travel for necessity only, such as dialysis treatments, doctors
appointments, and hospital visits.
d. Quality of life. Peggys quality of life has diminished greatly since the incident
and it has affected our entire family. It has been a physical, mental and emotional
struggle for us. Our daily lives have completely changed as we have taken on new
roles in the household.
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JERRY JERNIGAN

State of ALABAMA
County of Shelby

Affidavit of Jerry Jernigan page 2

VERIFICATION
Before me, the undersigned notary public in and for said county and state, personally
appeared, JERRY JERNIGAN, who is known to me and who is being first duly sworn by me,
deposes and says that JERRY JERNIGAN has knowledge of the facts and circumstances
contained in the above complaint and that the same are true and correct.
FURTHER AFFIANT SAITH NOT.
Sworn to and subscribed before me, this the

day of ___________, 2015.

NOTARY PUBLIC
My Commission Expires:_______________