1. IN THE CUYAHOGA COUNTY COMMON PLEAS COURT
CUYAHOGA COUNTY, OHIO
)
JANE DOE ) CASE NO.: 2013 CV
3121 EUCLID AVE. )
CLEVELAND, OHIO 44115 ) JUDGE:
)
Plaintiff ) COMPLAINT
)
vs. )
)
CITY OF CLEVELAND HEIGHTS )
40 SEVERANCE CIRCLE )
CLEVELAND HEIGHTS, OH 4411 )
)
Defendant )
Now comes Plaintiff, Jane Doe, by and through her undersigned counsel, and for her
complaint, state as follows:
COUNT 1
1. Defendant City of Cleveland Heights (herein after referred to as the CITY) is a
municipal Corporation chartered under the Constitution of the State of Ohio.
COUNT II
2. Plaintiff hereby incorporates by reference the allegations contained in Paragraphs One
above, as if were fully written herein.
3. Defendant City’s Police Department issued a citation to Plaintiff for traveling 37
M.P.H. in a business district on Mayfield Road at Coventry Road, at 4:04 a.m., on February 28,
2013 in contravention of Ohio Revised Code.
4. Pursuant to Ohio Revised Code, Defendant is acting outside the scope of their police
powers as the site of the offense is not a business district.

2. 5. Plaintiff has been damaged by Defendant’s breach of their duty to the people of Ohio.
COUNT III
6. Plaintiff incorporates the allegations contained in Paragraphs One through Five above,
as if fully rewritten herein.
7. Defendant has been unjustly enriched in the amount of $3,000,000 annually in citation
revenues from this one location.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
3,000,000, interest, and her costs in this action, and such further relief as the Court may grant.
Respectfully submitted,
_______________________________________
ANNA HUFSTELER B00395298
Courthouse Square Suite 730
310 W. Lakeside Ave.
Cleveland, OH 44113-1021
(216) 241-6818