The estate of the late Bobbi Kristina Brown has filed an amended wrongful death lawsuit against her ex boyfriend Nick Gordon alleging that on the day she was found unconscious in her bathtub he gave her a “toxic cocktail” to knock her out then placed her there.

Brown’s court-appointed conservator, Bedelia C. Hargrove, who filed the amended complaint, told PEOPLE in a statement, “I have filed today an amended complaint against Nicholas Gordon adding a count for wrongful death and for pain and suffering, filed the amended complaint. We will leave no stone unturned in seeking justice for Bobbi Kristina Brown.”

The complaint accuses Gordon of arriving at the couple’s townhouse early in the morning on January 31 after being “out all night on a cocaine and drinking binge.” It continues by stating that careful review of camera footage, Brown’s conversations that night and eyewitness statements, revealed that Gordon and Brown “became embroiled in a loud argument” in their master bedroom.

The papers go on to allege that the “Defendant screamed at Bobbi Kristina accusing her of cheating, going so far as to call her a ‘whore,’ a ‘bitch,’ and other names, and the argument lasted for about thirty minutes and then everything abruptly became quiet.”

The lawsuit claims that Gordon then gave Brown a “toxic cocktail” which left her unconscious. The papers highlight another unidentified woman who was present at the townhouse at the time of the incident who says that Gordon left the master bedroom without Brown then “laid his head on female guest’s ankle and stated, ‘Now I want a pretty little white girl like you.’”

It wasn’t until fifteen minutes later that someone else at the townhouse went to check on Bobbi Kristina, who was then found unresponsive and face down in the bathtub, the lawsuit alleges.

The amended lawsuit also includes a detailed history of domestic violence between Gordon and Brown describing a time where he once punched her repeatedly in the face.

Gordon’s legal team has responded with a statement to PEOPLE: “The recent lawsuit against Nick is slanderous and meritless. Nick has been heartbroken and destroyed over the loss of his love and it’s shameful that such baseless allegations have been presented publicly. Nick has engaged civil counsel and intends to defend the lawsuit vigorously and expose it for what it is: a fictitious assault against the person who loved Krissy most.”

After being placed in a medically induced coma, Brown passed away in hospice care on July 26.

Gordon was not allowed to visit Brown in the hospital or while she was under hospice care and did not attend her funeral.

To read more details from this shocking lawsuit, visit