1) Sabrina Adkins filed a civil lawsuit against Ben Fields (a deputy sheriff), unknown supervisors of Fields, and the Letcher County Sheriff. She alleges Fields sexually abused her on multiple occasions when she was on home incarceration under his supervision.
2) Adkins claims Fields violated her 4th and 14th amendment rights. She also brings state law claims against Fields for various torts related to the abuse.
3) Adkins further claims the sheriff and Fields' supervisors were deliberately indifferent in failing to properly train and supervise Fields, which allowed the abuse to occur. She is seeking damages against all defendants.
Schied - Courtwatch Follow-up; Final Prima Facea Filing - District Court of t...Niki Hannevig
This document is a complaint filed in federal district court by David Schied against multiple defendants including Judge Karen Khalil, court reporter Cathleen Dunn, police officers Jonathan Strong, Joseph Bommarito, David Holt, James Turner, and "Police Officer" Butler. Schied alleges he was unlawfully subjected to terror, assault, seizure, kidnapping and false imprisonment while quietly observing court proceedings. He claims defendants violated his constitutional rights and caused damages. Schied is seeking damages and declaratory and injunctive relief from the court.
This document contains 15 problems related to determining stresses in beams undergoing bending and shearing. The problems involve calculating stresses in beams with various cross-sectional shapes under different loading conditions. The beams are made of materials like steel, wood, and brass. Parameters like moment of inertia, shear force, beam dimensions, and material properties are provided to calculate stresses.
This document provides an overview of engineering mechanics statics. It covers topics including:
- Defining mechanics as the science dealing with bodies at rest or in motion under forces.
- Dividing mechanics into statics, dynamics, and other subfields. Statics deals with bodies at rest.
- Introducing fundamental concepts of forces, units of measurement, and representing forces as vectors that add according to the parallelogram law.
- Providing examples of adding forces graphically using the parallelogram law and triangle rule to determine the resultant force.
- Discussing problems involving determining the magnitude and direction of resultant forces from multiple forces acting on structures, stakes, and brackets
The document discusses the design of various mechanical joints, levers, and offset links. It covers the design of cotter joints, knuckle joints, turnbuckles, hand/foot levers, bell crank levers, safety valve levers, and offset links. The document also discusses bending stress equations, section modulus, and provides two example problems calculating the diameter of an axle and the width and depth of a beam based on given bending stress limits.
Edwin Steakley filed a complaint against CoreCivic, Inc. and several employees alleging violations of his constitutional rights and negligence. Steakley claims he notified defendants on multiple occasions that his cellmate, Jeffery Reeves, was threatening sexual assault but defendants failed to act. On February 20, 2018, Reeves sexually assaulted Steakley with a shank. Steakley alleges defendants were deliberately indifferent to the threats, failed to protect him, and denied him adequate medical care after the assault. Steakley is suing for damages under 42 U.S.C. 1983 and state tort laws.
Stephen Slevin vs. Board of County Commissioners - Lawsuit Against Jail for M...Umesh Heendeniya
Stephen Slevin (59) left in solitary confinement (by jail director Chris Barela and former medical director Dr. Daniel Zemek) in the Dona Ana County, New Mexico jail for 2 years gets $15.5 million lawsuit settlement.
The tax payers are on the hook for $9.5 million while the county's liability insurance carriers will pay $6 million.
Former state water official files federal civil rights lawsuit against Las Ve...This Is Reno
Robert Coache has applied to receive an official exoneration by the State of Nevada after serving time in prison for crimes the Nevada Supreme Court later dismissed for lack of evidence. Whether he is granted that status, however, remains to be seen.
Coache, who spent 16 months in prison, could be eligible for $50,000 a year for each year served, under a 2019 law passed by the Nevada legislature.
It’s a drop in the bucket compared with the $5 million in damages he is now seeking in a federal civil rights lawsuit filed against Las Vegas Metropolitan Police Department (LVMPD) and the Clark County District Attorney’s Office.
Coache faced 49 charges, “spent over sixteen months in prison and was on parole for conspiracy to commit extortion by public officer or employee, extortion by public officer or employee, conspiracy to commit asking or receiving bribe by public officer, asking, or receiving bribe by public officer, conspiracy to commit money laundering, and forty-four counts of money laundering,” his attorneys said.
The Nevada Supreme Court in 2019 dismissed the 49 charges against him citing lack of evidence.
Schied - Courtwatch Follow-up; Final Prima Facea Filing - District Court of t...Niki Hannevig
This document is a complaint filed in federal district court by David Schied against multiple defendants including Judge Karen Khalil, court reporter Cathleen Dunn, police officers Jonathan Strong, Joseph Bommarito, David Holt, James Turner, and "Police Officer" Butler. Schied alleges he was unlawfully subjected to terror, assault, seizure, kidnapping and false imprisonment while quietly observing court proceedings. He claims defendants violated his constitutional rights and caused damages. Schied is seeking damages and declaratory and injunctive relief from the court.
This document contains 15 problems related to determining stresses in beams undergoing bending and shearing. The problems involve calculating stresses in beams with various cross-sectional shapes under different loading conditions. The beams are made of materials like steel, wood, and brass. Parameters like moment of inertia, shear force, beam dimensions, and material properties are provided to calculate stresses.
This document provides an overview of engineering mechanics statics. It covers topics including:
- Defining mechanics as the science dealing with bodies at rest or in motion under forces.
- Dividing mechanics into statics, dynamics, and other subfields. Statics deals with bodies at rest.
- Introducing fundamental concepts of forces, units of measurement, and representing forces as vectors that add according to the parallelogram law.
- Providing examples of adding forces graphically using the parallelogram law and triangle rule to determine the resultant force.
- Discussing problems involving determining the magnitude and direction of resultant forces from multiple forces acting on structures, stakes, and brackets
The document discusses the design of various mechanical joints, levers, and offset links. It covers the design of cotter joints, knuckle joints, turnbuckles, hand/foot levers, bell crank levers, safety valve levers, and offset links. The document also discusses bending stress equations, section modulus, and provides two example problems calculating the diameter of an axle and the width and depth of a beam based on given bending stress limits.
Edwin Steakley filed a complaint against CoreCivic, Inc. and several employees alleging violations of his constitutional rights and negligence. Steakley claims he notified defendants on multiple occasions that his cellmate, Jeffery Reeves, was threatening sexual assault but defendants failed to act. On February 20, 2018, Reeves sexually assaulted Steakley with a shank. Steakley alleges defendants were deliberately indifferent to the threats, failed to protect him, and denied him adequate medical care after the assault. Steakley is suing for damages under 42 U.S.C. 1983 and state tort laws.
Stephen Slevin vs. Board of County Commissioners - Lawsuit Against Jail for M...Umesh Heendeniya
Stephen Slevin (59) left in solitary confinement (by jail director Chris Barela and former medical director Dr. Daniel Zemek) in the Dona Ana County, New Mexico jail for 2 years gets $15.5 million lawsuit settlement.
The tax payers are on the hook for $9.5 million while the county's liability insurance carriers will pay $6 million.
Former state water official files federal civil rights lawsuit against Las Ve...This Is Reno
Robert Coache has applied to receive an official exoneration by the State of Nevada after serving time in prison for crimes the Nevada Supreme Court later dismissed for lack of evidence. Whether he is granted that status, however, remains to be seen.
Coache, who spent 16 months in prison, could be eligible for $50,000 a year for each year served, under a 2019 law passed by the Nevada legislature.
It’s a drop in the bucket compared with the $5 million in damages he is now seeking in a federal civil rights lawsuit filed against Las Vegas Metropolitan Police Department (LVMPD) and the Clark County District Attorney’s Office.
Coache faced 49 charges, “spent over sixteen months in prison and was on parole for conspiracy to commit extortion by public officer or employee, extortion by public officer or employee, conspiracy to commit asking or receiving bribe by public officer, asking, or receiving bribe by public officer, conspiracy to commit money laundering, and forty-four counts of money laundering,” his attorneys said.
The Nevada Supreme Court in 2019 dismissed the 49 charges against him citing lack of evidence.
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORKNowseore
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer on the undersigned attorneys for Plaintiff, AIDALA, BERTUNA & KAMINS P.C., at 546 5th Avenue, New York, New York, 10036, within twenty (20) days after the service of this Summons and Complaint, exclusive of the day of service, or within thirty (30) days after the service is complete, if this Summons is not personally delivered to you within the State of New York.
COMPLAINT - Andrea Constand vs William H CosbyVogelDenise
WHY it is important to see documents for yourself. There are NO EXHIBITS to SUPPORT Sex Allegations made - Just MERE Words - with JEWS at the HELM OF THE SHIP!
Plaintiff Joan Silver was injured during a hypnotherapy session with Defendant Stanley Fine, a Baltimore County volunteer. Silver did not provide formal notice to the county of her potential lawsuit as required by law. Instead, some months later, she sent an informal email to her former boss, the County Executive, hinting at a possible lawsuit but not explicitly stating her intent. Defendant argues that Silver did not substantially comply with the notice requirement or show good cause for failing to comply. As such, Defendant's motion for summary judgment should be granted.
This document is a complaint filed in United States District Court against several officers of the Puerto Rico Police Department alleging discrimination and retaliation based on religious beliefs. The complaint states that the plaintiff, a police officer, was subjected to unwanted officially sponsored prayer and proselytizing at mandatory meetings called by his supervisors. It further states that after objecting to these practices due to his atheist beliefs, the plaintiff faced retaliation in the form of downgraded job responsibilities and a hostile work environment. The complaint brings claims under the US and Puerto Rico Constitutions as well as federal civil rights statutes seeking declaratory and monetary relief for these alleged violations of the plaintiff's constitutional rights to be free of state-sponsored religious practices and retaliation for object
This document summarizes a Supreme Court of the Philippines decision regarding two complaints of misconduct filed against Attorney Arturo B. Astorga. The first complaint alleges that Astorga, acting as administrator of an estate based on a power of attorney, disturbed the peaceful possession of a property by the complainants that they had occupied for over 40 years. The second complaint alleges that Astorga sold the same property to one of the complainants without proper authority to administer the estate. The court must determine if Astorga is guilty of conduct unbecoming a member of the bar based on these complaints.
The document is a motion filed by the defense attorney Ralph Megna on behalf of their client, who has been indicted on drug and paraphernalia charges. The motion requests several forms of relief from the court, including inspection of grand jury minutes, dismissal of indictment, a Huntley hearing on statements made by the defendant, a Wade hearing on identification procedures, disclosure of Brady material, a Sandoval hearing, and leave to make further motions. The attorney provides supporting arguments for each request.
Brayshaw v. City Of Tallahassee, Illegal David Record Searches Federal LawsuitTerry81
Brayshaw v. City Of Tallahassee, Illegal and Criminal DAVID Searches were conducted to the Brayshaws illegally for exposing the dumb and dirty cops of Annette Garrett and Mike Dilmore at The Tallahassee Police Department. Various Civil and Constitutional Rights Violations have been exposed for illegal actions of Tallahassee Police Officers especially for using their mafia tactics of free speech and free press suppression of illegal censorships conducted.
This document is a complaint filed in United States District Court against Judge Alice Beck Dubow and other defendants. It alleges that Judge Dubow's September 24, 2009 opinion prolongs child abuse of the plaintiff family by failing to enforce her own "Standing Order for Courtroom H". It claims this negligence exacerbated the prolonged kidnapping and child abuse of the plaintiff's children inflicted by court order. The complaint seeks damages and return of the kidnapped children to their natural guardian.
This document is a complaint filed in the United States District Court for the Eastern District of Pennsylvania by Deborah Young on behalf of her minor children Cameron and Briana Detwiler. The complaint names multiple defendants including Judge Alice Beck Dubow of the Philadelphia Family Court for her role in prolonging the alleged child abuse suffered by the plaintiffs. The complaint alleges that Judge Dubow failed to abide by her own "Standing Court Order for Courtroom H" which would have helped prevent the alleged civil rights violations against the plaintiffs that resulted in their kidnapping and prolonged abuse. The plaintiffs are seeking the return of the children to Young, as well as $400,000 in punitive damages.
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of BusinesVamsidhar Vurimindi
This document is a verified complaint filed by Vamsidhar Vurimindi against 18 defendants including the HSFLB Condominium Owners Association, the City of Philadelphia, the Commonwealth of Pennsylvania, and several individuals. Vurimindi alleges that the condo owners conspired with law enforcement to wrongfully arrest, detain, and issue a restraining order against him, violating his civil and constitutional rights. He is seeking injunctive relief from criminal charges as well as damages for the violation of his First, Fourth, and Fourteenth amendment rights.
civil rights handbook - unlawful discrimination coverPhyllis W. Cheng
This document summarizes California and federal laws against unlawful discrimination. It discusses California's Ralph Civil Rights Act and Bane Civil Rights Act, which provide civil remedies for victims of violence due to their race, religion, or other attributes. It also outlines state and federal employment discrimination laws, housing discrimination laws, and other topics. Government agencies that enforce these laws are listed that individuals can file complaints with.
Grievance Filing Against Belknap County (NH) Attorney Andrew Livernois and De...Rich Bergeron
This is a detailed complaint I filed recently regarding an attempt by the local prosecutor's office to eviscerate my First Amendment rights and deny me my rights to due process throughout the case.
1. Vickie Lynn Marshall filed a claim in federal bankruptcy court against E. Pierce Marshall for tortiously interfering with the inheritance she expected from J. Howard Marshall. The bankruptcy court ruled in her favor but the Ninth Circuit reversed, citing the probate exception.
2. The Supreme Court held that the probate exception did not apply because Vickie's claim did not require validating or invalidating a will. It was a recognized tort claim for interfering with an expected inheritance.
3. The Court also found that Vickie had a valid expectation of inheritance from J. Howard Marshall based on his promises, and that Pierce's actions of depleting assets and restricting access tortiously interfered with that expectation.
Petitioners filed an emergency motion in district court seeking declaratory and injunctive relief to challenge the results of the 2020 Michigan election. The district court denied the motion without a hearing. Petitioners now seek a writ of certiorari from the Supreme Court, arguing the district court erred in denying the emergency motion without considering the evidence, and in finding petitioners' claims barred by immunity, mootness, laches, abstention doctrine, and lack of standing. The petitioners assert they presented sufficient evidence of irregularities and fraud to support claims under Section 1983 and the US Constitution.
Order granting omnibus order granting defendants motions for sanctionsJusticebuilding
The court granted defendants' motions for sanctions against plaintiff and its counsel. The court found that plaintiff's lawsuit against former officials of the Miccosukee Tribe was filed to pursue political retribution rather than valid legal claims. Plaintiff's counsel failed to adhere to ethical standards in pursuing claims that lacked evidentiary support, including allegations of racketeering and conspiracy. The internal feud within the Miccosukee Tribe blinded counsel and caused them to pursue frivolous claims against the defendants.
This motion requests a temporary restraining order against the President of the Indianapolis-Marion County City-County Council. It summarizes that without the assistance of the Clerk and independent counsel, the Council cannot conduct business and perform its functions, which would cause irreparable harm. It also notes that preventing the Clerk from performing legal duties could jeopardize the validity of Council actions. The motion asks the court to restrain the Council President from preventing the Clerk and counsel from accessing their offices and equipment to perform their legal functions until the underlying claims can be resolved.
The document summarizes a majority opinion from an appeals court regarding the legal sufficiency of evidence to support a conviction for making a false report to police. The majority opinion holds that the evidence is legally insufficient because the State did not prove the report was made in bad faith or for reasons other than a valid grievance. It provides background on the case, including that the defendant contacted various law enforcement agencies to report improper access of his credit report during a criminal investigation against him in another state.
AMENDED MOTION TO STRIKE OPPOSITION TO PETITION FOR WRIT OF CERTIORARIFinni Rice
This document is an amended motion to strike an opposition brief filed in the Supreme Court of the United States. The petitioner, Kimberly Cox, argues that the opposition brief should be stricken for several reasons, including that the entities filing the opposition, NewRez LLC and The Bank of New York Mellon, lack standing because they were not named as respondents in the petition and were not involved in the underlying legal proceedings. Cox also argues that the corporate disclosure filed with the opposition is incomplete and misleading. The motion provides detailed arguments supporting Cox's position that the opposition brief should be stricken from the record.
As Indiana lawmaker attempt to hire their own counsel to represent them in the sexual harassment case involving Attorney General Curtis Hill, they also spell out their own defenses as to why the state is not liable.
The document discusses the results of a study on the impact of COVID-19 lockdowns on air pollution. Researchers found that lockdowns led to significant short-term reductions in nitrogen dioxide and fine particulate matter pollution globally as transportation and industrial activities declined substantially. However, the document notes that the improvements in air quality were temporary and pollution levels rose back to pre-pandemic levels as restrictions eased and activity increased again.
Martin County is one of a dozen Kentucky counties suing some of the world's largest social media networks for actions they say have contributed to a mental health crisis among America's youth.
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORKNowseore
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer on the undersigned attorneys for Plaintiff, AIDALA, BERTUNA & KAMINS P.C., at 546 5th Avenue, New York, New York, 10036, within twenty (20) days after the service of this Summons and Complaint, exclusive of the day of service, or within thirty (30) days after the service is complete, if this Summons is not personally delivered to you within the State of New York.
COMPLAINT - Andrea Constand vs William H CosbyVogelDenise
WHY it is important to see documents for yourself. There are NO EXHIBITS to SUPPORT Sex Allegations made - Just MERE Words - with JEWS at the HELM OF THE SHIP!
Plaintiff Joan Silver was injured during a hypnotherapy session with Defendant Stanley Fine, a Baltimore County volunteer. Silver did not provide formal notice to the county of her potential lawsuit as required by law. Instead, some months later, she sent an informal email to her former boss, the County Executive, hinting at a possible lawsuit but not explicitly stating her intent. Defendant argues that Silver did not substantially comply with the notice requirement or show good cause for failing to comply. As such, Defendant's motion for summary judgment should be granted.
This document is a complaint filed in United States District Court against several officers of the Puerto Rico Police Department alleging discrimination and retaliation based on religious beliefs. The complaint states that the plaintiff, a police officer, was subjected to unwanted officially sponsored prayer and proselytizing at mandatory meetings called by his supervisors. It further states that after objecting to these practices due to his atheist beliefs, the plaintiff faced retaliation in the form of downgraded job responsibilities and a hostile work environment. The complaint brings claims under the US and Puerto Rico Constitutions as well as federal civil rights statutes seeking declaratory and monetary relief for these alleged violations of the plaintiff's constitutional rights to be free of state-sponsored religious practices and retaliation for object
This document summarizes a Supreme Court of the Philippines decision regarding two complaints of misconduct filed against Attorney Arturo B. Astorga. The first complaint alleges that Astorga, acting as administrator of an estate based on a power of attorney, disturbed the peaceful possession of a property by the complainants that they had occupied for over 40 years. The second complaint alleges that Astorga sold the same property to one of the complainants without proper authority to administer the estate. The court must determine if Astorga is guilty of conduct unbecoming a member of the bar based on these complaints.
The document is a motion filed by the defense attorney Ralph Megna on behalf of their client, who has been indicted on drug and paraphernalia charges. The motion requests several forms of relief from the court, including inspection of grand jury minutes, dismissal of indictment, a Huntley hearing on statements made by the defendant, a Wade hearing on identification procedures, disclosure of Brady material, a Sandoval hearing, and leave to make further motions. The attorney provides supporting arguments for each request.
Brayshaw v. City Of Tallahassee, Illegal David Record Searches Federal LawsuitTerry81
Brayshaw v. City Of Tallahassee, Illegal and Criminal DAVID Searches were conducted to the Brayshaws illegally for exposing the dumb and dirty cops of Annette Garrett and Mike Dilmore at The Tallahassee Police Department. Various Civil and Constitutional Rights Violations have been exposed for illegal actions of Tallahassee Police Officers especially for using their mafia tactics of free speech and free press suppression of illegal censorships conducted.
This document is a complaint filed in United States District Court against Judge Alice Beck Dubow and other defendants. It alleges that Judge Dubow's September 24, 2009 opinion prolongs child abuse of the plaintiff family by failing to enforce her own "Standing Order for Courtroom H". It claims this negligence exacerbated the prolonged kidnapping and child abuse of the plaintiff's children inflicted by court order. The complaint seeks damages and return of the kidnapped children to their natural guardian.
This document is a complaint filed in the United States District Court for the Eastern District of Pennsylvania by Deborah Young on behalf of her minor children Cameron and Briana Detwiler. The complaint names multiple defendants including Judge Alice Beck Dubow of the Philadelphia Family Court for her role in prolonging the alleged child abuse suffered by the plaintiffs. The complaint alleges that Judge Dubow failed to abide by her own "Standing Court Order for Courtroom H" which would have helped prevent the alleged civil rights violations against the plaintiffs that resulted in their kidnapping and prolonged abuse. The plaintiffs are seeking the return of the children to Young, as well as $400,000 in punitive damages.
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of BusinesVamsidhar Vurimindi
This document is a verified complaint filed by Vamsidhar Vurimindi against 18 defendants including the HSFLB Condominium Owners Association, the City of Philadelphia, the Commonwealth of Pennsylvania, and several individuals. Vurimindi alleges that the condo owners conspired with law enforcement to wrongfully arrest, detain, and issue a restraining order against him, violating his civil and constitutional rights. He is seeking injunctive relief from criminal charges as well as damages for the violation of his First, Fourth, and Fourteenth amendment rights.
civil rights handbook - unlawful discrimination coverPhyllis W. Cheng
This document summarizes California and federal laws against unlawful discrimination. It discusses California's Ralph Civil Rights Act and Bane Civil Rights Act, which provide civil remedies for victims of violence due to their race, religion, or other attributes. It also outlines state and federal employment discrimination laws, housing discrimination laws, and other topics. Government agencies that enforce these laws are listed that individuals can file complaints with.
Grievance Filing Against Belknap County (NH) Attorney Andrew Livernois and De...Rich Bergeron
This is a detailed complaint I filed recently regarding an attempt by the local prosecutor's office to eviscerate my First Amendment rights and deny me my rights to due process throughout the case.
1. Vickie Lynn Marshall filed a claim in federal bankruptcy court against E. Pierce Marshall for tortiously interfering with the inheritance she expected from J. Howard Marshall. The bankruptcy court ruled in her favor but the Ninth Circuit reversed, citing the probate exception.
2. The Supreme Court held that the probate exception did not apply because Vickie's claim did not require validating or invalidating a will. It was a recognized tort claim for interfering with an expected inheritance.
3. The Court also found that Vickie had a valid expectation of inheritance from J. Howard Marshall based on his promises, and that Pierce's actions of depleting assets and restricting access tortiously interfered with that expectation.
Petitioners filed an emergency motion in district court seeking declaratory and injunctive relief to challenge the results of the 2020 Michigan election. The district court denied the motion without a hearing. Petitioners now seek a writ of certiorari from the Supreme Court, arguing the district court erred in denying the emergency motion without considering the evidence, and in finding petitioners' claims barred by immunity, mootness, laches, abstention doctrine, and lack of standing. The petitioners assert they presented sufficient evidence of irregularities and fraud to support claims under Section 1983 and the US Constitution.
Order granting omnibus order granting defendants motions for sanctionsJusticebuilding
The court granted defendants' motions for sanctions against plaintiff and its counsel. The court found that plaintiff's lawsuit against former officials of the Miccosukee Tribe was filed to pursue political retribution rather than valid legal claims. Plaintiff's counsel failed to adhere to ethical standards in pursuing claims that lacked evidentiary support, including allegations of racketeering and conspiracy. The internal feud within the Miccosukee Tribe blinded counsel and caused them to pursue frivolous claims against the defendants.
This motion requests a temporary restraining order against the President of the Indianapolis-Marion County City-County Council. It summarizes that without the assistance of the Clerk and independent counsel, the Council cannot conduct business and perform its functions, which would cause irreparable harm. It also notes that preventing the Clerk from performing legal duties could jeopardize the validity of Council actions. The motion asks the court to restrain the Council President from preventing the Clerk and counsel from accessing their offices and equipment to perform their legal functions until the underlying claims can be resolved.
The document summarizes a majority opinion from an appeals court regarding the legal sufficiency of evidence to support a conviction for making a false report to police. The majority opinion holds that the evidence is legally insufficient because the State did not prove the report was made in bad faith or for reasons other than a valid grievance. It provides background on the case, including that the defendant contacted various law enforcement agencies to report improper access of his credit report during a criminal investigation against him in another state.
AMENDED MOTION TO STRIKE OPPOSITION TO PETITION FOR WRIT OF CERTIORARIFinni Rice
This document is an amended motion to strike an opposition brief filed in the Supreme Court of the United States. The petitioner, Kimberly Cox, argues that the opposition brief should be stricken for several reasons, including that the entities filing the opposition, NewRez LLC and The Bank of New York Mellon, lack standing because they were not named as respondents in the petition and were not involved in the underlying legal proceedings. Cox also argues that the corporate disclosure filed with the opposition is incomplete and misleading. The motion provides detailed arguments supporting Cox's position that the opposition brief should be stricken from the record.
As Indiana lawmaker attempt to hire their own counsel to represent them in the sexual harassment case involving Attorney General Curtis Hill, they also spell out their own defenses as to why the state is not liable.
The document discusses the results of a study on the impact of COVID-19 lockdowns on air pollution. Researchers found that lockdowns led to significant short-term reductions in nitrogen dioxide and fine particulate matter pollution globally as transportation and industrial activities declined substantially. However, the document notes that the improvements in air quality were temporary and pollution levels rose back to pre-pandemic levels as restrictions eased and activity increased again.
Martin County is one of a dozen Kentucky counties suing some of the world's largest social media networks for actions they say have contributed to a mental health crisis among America's youth.
A copy of the lawsuit filed by the city of Pikeville against cable provider Suddenlink, alleging the company is in default on penalties owed due to violations of its franchise agreement with the city.
This document is a syllabus for the Supreme Court case Dobbs v. Jackson Women's Health Organization. It summarizes that the case concerns Mississippi's law banning most abortions after 15 weeks of pregnancy. The plaintiffs challenged the law, arguing it violated precedents establishing abortion rights. The District Court and Fifth Circuit agreed, but the Supreme Court took up the case to determine whether the Constitution confers a right to abortion. Overturning Roe v. Wade and Planned Parenthood v. Casey, the Court held that the right to abortion is not rooted in the nation's history or the Fourteenth Amendment, and authority to regulate abortion returns to state legislatures.
The document is a 3-page precinct report from an unofficial primary election in Pike County. It provides vote totals for each candidate in various races from one precinct (A101) on the first two pages, and a second precinct (A102) on the third page. In precinct A101, Rand Paul received the most votes for US Senator at 31 votes. Harold 'Hal' Rogers received the most votes for US Representative at 34 votes. In precinct A102, Rand Paul also received the most votes for US Senator at 30 votes, and Harold 'Hal' Rogers received the most votes for US Representative at 40 votes.
The document provides election results from various races in Perry County. Rand Paul won the US Senate race with 85.29% of the vote. Harold 'Hal' Rogers won the US House race with 77.14% of the vote. Minor B. Allen won the Jailer race with 69.70% of the vote. Rick Wooton won the 1st Magisterial District race with 75.76% of the vote. The results include voting totals from absentee, early, election day, and total voting for each choice in each race.
This document summarizes the results of the 2022 Martin County Primary Election held on April 26, 2022. It provides voter registration statistics and vote totals for each precinct and contest on the Republican and Democratic ballots. The precinct shown is A101 Lower Inez, which had 261 total ballots cast. Rand Paul received the most votes for US Senator and Norma Kirk McCormick received the most votes for State Representative in this precinct.
The document summarizes the unofficial results of the 2022 Magoffin County Primary Election held on May 17, 2022. It provides voter registration statistics and vote totals for various Republican and Democratic races at the county level, including United States Senator, United States Representative, Sheriff, Magistrate, and others. Precinct-level results are included for multiple precincts within Magoffin County.
In the 2022 Letcher County primary election, unofficial results show that in precinct A104 Eolia, Rand Paul received the most votes among Republican candidates for US Senator with 16 votes, and Charles Booker received the most votes among Democratic candidates with 13 votes. Sam Wright received the most votes among Democratic candidates for County Judge/Executive with 18 votes. Voter turnout percentages were not provided.
The document is an unofficial precinct report from a primary election held on May 17, 2022 in Lawrence County. It provides vote totals for each candidate in various races from one precinct (Precinct A101) containing 60 ballots cast. The highest vote getter in the US Senate race was Rand Paul with 47 votes (90.38% of ballots cast). In the race for County Judge/Executive, Phillip L. Carter received 40 votes (75.47% of ballots cast). For County Attorney, Brad Derfield received 29 votes (54.72% of ballots cast).
This document summarizes the unofficial results of the 2022 Knott County Primary Election held on February 5, 2022. It shows the number of registered voters and ballots cast in each precinct for Republican and Democratic candidates for U.S. Senate, U.S. Representative, County Judge/Executive, Magistrate, and Constable. Rand Paul and Tracy Neice received the most votes of the Republican and Democratic candidates respectively in the precinct summarized.
The document provides unofficial results from the 2022 Johnson County primary election held on May 17, 2022. It shows that in Precinct A105 Staffordsville, 275 Republican ballots and 49 Democratic ballots were cast out of 1,132 total registered voters. Rand Paul received 225 votes for United States Senator, while Harold 'Hal' Rogers received 227 votes for United States Representative and Bobby W. McCOOL received 217 votes for State Representative.
The document provides unofficial results from the 2022 Floyd County primary election held on May 17, 2022. It shows that 206 total ballots were cast, with 49 cast by registered Republicans and 156 by registered Democrats. For the Republican US Senate race, Rand Paul received 41 votes. For the Democratic Sheriff race, John P. Hunt received 118 votes. The document provides candidate vote totals for various federal, state and local primary races in Floyd County.
Rex Fought is charged with conspiracy to defraud the United States by impeding the Internal Revenue Service's ability to accurately assess and collect taxes. From 2014 to 2019, Fought directed his controller, M.M., to funnel money from coal companies into shell companies owned by Fought and his partner, and not report this money on their tax returns. M.M. also filed false tax returns for Fought, his partner, and the shell companies that underreported income and overreported expenses. If convicted, Fought faces up to 5 years in prison and significant fines.
Cockfighting indictment, Nicholas and Fleming countiesMountain Top News
Walter Mitchell, Jerrard McVey, and Linda McVey were charged with conspiracy to violate laws prohibiting animal fighting. They allegedly owned and operated an animal fighting venture called the Valley, located in Kentucky, that hosted weekly cockfighting events. They are accused of organizing fights, collecting admission fees, and selling concessions. On specific dates in June and July 2021, they allegedly organized cockfighting events at the Valley that drew over 100 people and involved entering roosters into fights. If convicted, they each face a maximum of 5 years in prison, a $250,000 fine, and 3 years of supervised release.
Cruz Alejandro Mercado-Vazquez was indicted on three counts by a federal grand jury. He was charged with twice attempting to bribe a county sheriff to protect planned animal fighting ventures (Counts 1-2), and with selling, buying, possessing, training, transporting and receiving roosters for use in an animal fighting venture (Count 3). If convicted, he faces up to 10 years in prison and fines of $250,000 for each bribery count, and up to 5 years in prison and $250,000 fine for the animal fighting count. He would also forfeit any animals involved and costs of their care.
1) Rickie D. Johnson, Jacklyn R. Johnson, and Harold "Fuzzy" Hale are charged with conspiracy to violate laws prohibiting animal fighting by operating a cockfighting ring called Bald Rock between May and July 2021.
2) Orville D. Asher, Dallas M. Cope, and Hiram B. Creech Jr. are each charged with attempting to sponsor or exhibit roosters in an animal fighting venture at Bald Rock on July 10, 2021.
3) If convicted, the defendants each face a maximum of 5 years in prison, a $250,000 fine, and 3 years of supervised release per count, as well as mandatory assessments and potential restitution.
A federal lawsuit filed by Levi Newsom and N.R., a minor represented by her parent, Mikey Ratliff, challenging Pike County Schools' mask mandate as unconstitutional.
Youngest c m in India- Pema Khandu BiographyVoterMood
Pema Khandu, born on August 21, 1979, is an Indian politician and the Chief Minister of Arunachal Pradesh. He is the son of former Chief Minister of Arunachal Pradesh, Dorjee Khandu. Pema Khandu assumed office as the Chief Minister in July 2016, making him one of the youngest Chief Ministers in India at that time.
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1. 1
Electronically Filed
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF KENTUCKY
PIKEVILLE DIVISION
CIVIL ACTION NO. ___________________
)
SABRINA ADKINS )
)
PLAINTIFF )
)
V. )
)
BEN FIELDS, Individually )
And in his Official capacity as )
a Deputy Sheriff with the )
Letcher County Sheriff’s Department ) COMPLAINT
)
UNKNOWN SUPERVISORS )
OF BEN FIELDS )
)
AND )
)
MICKEY STINES, LETCHER COUNTY )
SHERIFF )
)
DEFENDANTS )
__________________________________________________________________
Comes the Plaintiff, Sabrina Adkins (“Plaintiff” or “Sabrina”), by and through
counsel, and for her Complaint against the Defendants, states as follows:
INTRODUCTION
This is a civil action for damages for violation of the Constitutional rights of
Plaintiff by the Defendants, acting under color of state law. In addition, the Plaintiff
alleges that the Defendant Ben Fields (“Defendant Fields”) is liable under state law.
Plaintiff asserts that the Defendant Fields, in his individual and official capacities,
violated Plaintiff’s rights secured by the Fourth and Fourteenth Amendments to the
Case: 7:22-cv-00007-REW-EBA Doc #: 1 Filed: 01/31/22 Page: 1 of 12 - Page ID#: 1
2. 2
United States Constitution, as well as Sections 1, 2 and 10 of the Kentucky Constitution,
by subjecting Plaintiff to arbitrary action, unreasonable search and seizure, and
deprivation of liberty. The Plaintiff also alleges that Defendant Fields is liable under
state law for damages for false imprisonment, assault and battery, malicious prosecution,
intentional infliction of emotional distress, negligence, and gross negligence. Defendant
Fields’ unknown supervisors and Defendant Letcher County Sheriff is alleged to be liable
to Plaintiff for deliberate indifference in failing to adequately train and supervise
Defendant Fields.
JURISDICTION AND VENUE
1. This Court has original jurisdiction over this action pursuant to 28 U.S.C. §1331,
actionable by virtue of 42 U.S.C. §1983. In addition, the Court has supplemental jurisdiction
over the state law claims pursuant to 28 U.S.C. §1367.
2. Venue is appropriate in this Court pursuant to 28 U.S.C §1391.
PARTIES
3. The Plaintiff a resident of Pike County, Kentucky.
4. Defendant Fields was at all times relevant to this Complaint acting as a Letcher
County Deputy Sheriff. Defendant Fields is sued in his official capacity on the declaratory
relief and damages claims, and in his individual capacity as to all claims set forth herein.
Upon information and belief Defendant Fields is a resident of Letcher County, Kentucky.
5. At all times relevant hereto, Defendant Fields was acting under color of state law
in performing the acts or omissions complained of in this Complaint.
6. Defendant Mickey Stines is the duly elected Letcher County Sheriff, elected
pursuant to the Kentucky Constitution, Section 99, and regulated by KRS Chapter 70.
FACTUAL ALLEGATIONS
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3. 3
All preceding Paragraphs are incorporated herein by reference thereto, as if fully
set out herein.
7. Plaintiff was arrested in Letcher County, Kentucky in April, 2021.
8. From April, 2021 though June 2, 2021, Plaintiff was incarcerated at the Letcher
County Jail.
9. In early June, 2021 Plaintiff was released from the Letcher County Jail and placed
on home incarceration.
10. Defendant Fields, a deputy sheriff with the Letcher County Sheriff’s Department,
was assigned to be Plaintiff’s home incarceration officer.
11. After she was released, Plaintiff had a difficult time finding housing
accommodations in Letcher County.
12. Defendant Fields was aware of Plaintiff’s housing issues, as well as Plaintiff’s
domestic issues.
13. Defendant Fields visited Plaintiff in the evening the night she was released from
the Letcher County Jail to bring her cigarettes, and to console her.
14. At this time Plaintiff notified Defendant Fields that she did not have the money to
pay for her ankle bracelet, but she was terrified to return to the Letcher County Jail.
15. Defendant Fields made flirtatious comments about Plaintiff’s looks and body,
and told her that he was confident that they could “work something out.”
16. Plaintiff understood these communications to mean that she would receive
favorable treatment from Defendant Fields if she provided him with sexual favors.
17. Thereafter, Plaintiff and Defendant Fields communicated on a regular basis by
text messages.
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4. 4
18. In late June, 2021 Defendant Fields asked Sabrina to meet her at the Letcher
County Courthouse in the evening after dark.
19. Defendant Fields took Plaintiff into District Judge Mullins’ chambers, telling
Plaintiff that he wanted to meet her there because there were no cameras.
20. At this time Defendant Fields took off Plaintiff’s ankle monitor and told her that
she would not have to pay the associated fees any longer, but could remain out on home
incarceration.
21. Between late June and December, 2021 Defendant Fields met Plaintiff at the
Letcher County Courthouse in the evening or early morning hours approximately six (6)
times.
22. During these meetings Defendant Fields’ behavior escalated from flirtatious
comments to forcible kissing, to oral sex, to intercourse with Plaintiff, all of which occurred
at the Letcher County Courthouse after hours, in Judge Mullins’ Chambers (hereinafter the
“sexual abuse”).
23. Plaintiff was coerced and compelled to comply with Defendant Fields’ advances
given Defendant Fields’ position of power, and because she could not afford to pay for the
ankle monitor and did not want to return to the Letcher County Jail.
24. Plaintiff did not consent to the sexual abuse.
25. These meeting would typically occur the night before Plaintiff had a court
appearance, and Defendant Fields would put Plaintiff’s ankle monitor back on and otherwise
fix it so that she would appear compliant with her home incarceration the following day.
26. Upon information and belief, in late December, 2021 certain persons at the
Letcher County Courthouse were notified that Defendant Fields was having inappropriate
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5. 5
communications and/or relations with Plaintiff and were provided text messages evidencing
the inappropriate communications and relations.
27. Upon information and belief Defendant Fields became aware of the information
contained in the preceding paragraph.
28. In late December. 2021 Defendant Fields stopped communicating with Plaintiff
by text message or otherwise.
29. Upon information and belief, in early January, 2022 Defendant Fields filed a
complaint against Plaintiff claiming that she was not complying with the terms of her home
incarceration.
30. Upon information and belief this complaint was filed maliciously by Defendant
Fields, in an effort to punish Plaintiff and in an attempt to save his own job and reputation.
31. Plaintiff was arrested on January 26, 2022, in Pike County, Kentucky.
32. Plaintiff is terrified that she will be transferred to the Letcher County Jail where
upon information and belief Defendant Fields’ wife is employed as an officer, and where
upon information and belief Defendant Fields was previously employed.
33. Plaintiff has serious concerns for her safety and welfare if she were to be
transferred to the Letcher County Jail.
34. Upon information and belief there are other women who Defendant Fields has
similarly abused.
35. Upon information and belief, the Letcher County Sheriff, and unknown
supervisors of Defendant Fields, failed to adequately train and supervise Defendant Fields.
36. Upon information and belief, the Letcher County Sheriff knew or should have
known that Defendant Fields was sexually abusing females, including Plaintiff, in his charge.
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6. 6
37. Upon information and belief, the Letcher County Sheriff did not reasonably
respond to reports or suspicions of sexual abuse perpetrated by Defendant Fields.
38. The Defendants’ conduct described above has caused severe injury to Plaintiff,
for which she is entitled to recover actual damages in an amount to be determined at trial.
COUNT I
(Defendant Fields Violated Plaintiffs’ Rights
Secured By United States Constitution, Amendments IV)
All preceding Paragraphs are incorporated herein by reference thereto, as if fully
set out herein.
39. Defendant Fields knowingly and recklessly engaged in the above-described
sexual abuse of Plaintiff, and such physical contact was objectively unreasonable.
40. Defendant Fields’ sexual abuse of Plaintiff was not rationally related to any
legitimate governmental purpose, and was otherwise excessive.
41. Plaintiff did not consent to the physical contact with Defendant Fields.
42. Plaintiff was coerced by Defendant Fields, and to the extent she complied with
Defendant Fields’ physical contact did so only because she was intimidated by Defendant
Fields who provided Plaintiff with privileges in exchange for sexual favors.
43. The above-described actions of Defendant Fields constitute a violation of
Plaintiff’s right to be free from unreasonable search and seizure, secured by United States
Constitution Amendments IV, which is actionable pursuant to 42 U.S.C. § 1983.
44. Plaintiff is entitled to recover compensatory damages against the Defendant Fields
in an amount sufficient to fully compensate her for the damages she suffered as a result of
this Constitutional violation.
45. Defendant Fields willfully, wantonly, recklessly, and maliciously engaged in the
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unconstitutional conduct described above.
46. Plaintiff is entitled to recover punitive damages against Defendant Fields in an
amount sufficient to punish said Defendant Fields, as well as deter him and others similarly
situated from committing such violations in the future.
COUNT II
(Defendant Fields Violated Plaintiffs’ Rights
Secured By United States Constitution, Amendments XIV)
All preceding Paragraphs are incorporated herein by reference thereto, as if fully
set out herein.
47. Plaintiff had a fundamental right to personal security and bodily integrity
extending specifically to the right to be free from sexual abuse.
48. Defendant Fields sexually abused Plaintiff in violation of this fundamental right.
49. Defendant Fields’ conduct was so oppressive that it shocks the conscious.
50. Defendant Fields’ conduct was intended to injure Plaintiff in a way unjustifiable
by any government interest.
51. The above-described actions of Defendant Fields constitute a violation of
Plaintiff’s substantive due process rights, secured by United States Constitution Amendments
IV, which is actionable pursuant to 42 U.S.C. § 1983.
52. Plaintiff is entitled to recover compensatory damages against the Defendant Fields
in an amount sufficient to fully compensate her for the damages she suffered as a result of
this Constitutional violation.
53. The Defendant Fields willfully, wantonly, recklessly, and maliciously engaged in
the unconstitutional conduct described above.
54. Plaintiff is entitled to recover punitive damages against Defendant Fields in an
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8. 8
amount sufficient to punish said Defendant Fields, as well as deter him and others similarly
situated from committing such violations in the future.
COUNT III
(Deliberate Indifference/ Failure to Supervise and Train Actionable
Pursuant To 42 U.S.C. § 1983 against Letcher County
Sheriff and Unknown Supervisors of Defendant Fields)
All preceding Paragraphs are incorporated herein by reference thereto, as if fully
set out herein.
55. Defendant Fields was inadequately trained in the areas of proper supervision and
interaction with female criminal defendants on home incarceration.
56. The Defendants Letcher County Sheriff and unknown supervisors of Defendant
Fields (together the “Letcher County Sheriff’s Department”) knew or should have known that
Defendant Fields was abusing his power and taking advantage of females on home
incarceration under his control and supervision.
57. The inadequate training of home incarceration officers employed by the Letcher
County Sheriff’s Department is likely to result in the ongoing violation of constitutional
rights.
58. The Letcher County Sheriff’s Department policymakers have been deliberately
indifferent to this need for adequate training.
59. The Letcher County Sheriff’s Department’s Failure to adequately train, supervise,
or discipline their employees proximately caused the violation of Plaintiff’s constitutional
rights.
60. The Letcher County Sheriff’s Department substantially caused a constitutional
tort to Plaintiff through its customs, policy statements, ordinances, regulations, and decisions
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officially adopted and promulgated by that body's officers.
61. The acts and omissions of the Letcher County Sheriff’s Department, in failing to
adequately train and supervise Defendant Fields, as set forth in this Complaint, amount to
deliberate indifference to the Constitutional rights of Plaintiff and a complete disregard for
the known and obvious consequences of such indifference; all of which resulted in the
Constitutional violations and tortious conduct described in this Complaint, and are therefore
actionable pursuant to 42 U.S.C. § 1983.
62. Plaintiff is entitled to recover compensatory damages against Defendant Letcher
County Sheriff’s Department in an amount sufficient to fully compensate Plaintiff for the
damages she suffered as a result of the conduct set forth herein.
63. Defendant Letcher County Sheriff’s Department acted willfully, wantonly,
recklessly, and maliciously engaged in the conduct set forth herein.
64. Plaintiff is entitled to recover punitive damages against Defendant Letcher County
Sheriff’s Department in an amount sufficient to punish said Defendant for the conduct set
forth herein, as well as deter said Defendant and others similarly situated from engaging in
such conduct in the future.
COUNT IV
(Negligence, Gross Negligence, Assault and Battery against Defendant Fields)
All preceding Paragraphs are incorporated herein by reference thereto, as if fully
set out herein.
65. The above-described actions of Defendant Fields were negligent, grossly
negligent, and constitute assault and battery.
66. Defendant Fields had a duty to reasonably supervise Plaintiff while she was on
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10. 10
home incarceration.
67. Defendant Fields violated the duty he had to the Plaintiff.
68. Defendant Fields’s violation of the duty of care he owed to Plaintiff proximately
caused the Plaintiff damages.
69. Plaintiff is entitled to recover compensatory damages against Defendant Fields in
an amount sufficient to fully compensate her for the damages she suffered as a result of the
tortious conduct of Defendant Fields.
70. Defendant Fields willfully, wantonly, recklessly, and maliciously engaged in the
tortious conduct.
71. Plaintiff is entitled to recover punitive damages against the Defendant Fields in an
amount sufficient to punish him for the tortious conduct, as well as deter him and others
similarly situated from engaging in such conduct in the future.
COUNT V
(Grossly Negligent Infliction Of Emotional Distress)
All preceding Paragraphs are incorporated herein by reference thereto, as if fully
set out herein.
72. As a direct and proximate result of the above-described grossly negligent conduct
of Defendant Fields, Plaintiff suffered and continues to suffer severe emotional distress.
73. Plaintiff is entitled to recover compensatory damages from Defendant
Fields in an amount sufficient to fully compensate her for the damages she suffered as a
result of the tortious conduct.
74. Because the conduct of the Defendant Fields was grossly negligent,
Plaintiff is entitled to recover punitive damages against Defendant Fields in an amount
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11. 11
sufficient to punish him for the tortious conduct, as well as deter him and others similarly
situated from engaging in such conduct in the future.
COUNT VI
(Intentional Infliction Of Emotional Distress)
All preceding Paragraphs are incorporated herein by reference thereto, as if fully set.
75. The above-described actions of Defendant Fields were intentional and are
outrageous and offend generally accepted community standards of decency and morality.
76. As a direct and proximate result of the above-described actions of
Defendant Fields, Plaintiff suffered and continues to suffer severe emotional distress.
77. Plaintiff is entitled to recover compensatory damages against Defendant Fields in
an amount sufficient to fully compensate her for the damages she suffered as a result of the
tortious and wrongful conduct.
78. Defendant Fields willfully, wantonly, recklessly and maliciously engaged in the
tortious conduct above described.
79. Plaintiff is entitled to recover punitive damages against Defendant Fields in an
amount sufficient to punish him for his malicious and intentional tortious conduct, as well as
deter Defendant Fields and others similarly situated from engaging in such conduct in the
future.
WHEREFORE, the Plaintiff respectfully demands the following relief:
A. An award of compensatory damages against the Defendants in an amount
sufficient to compensate Plaintiff for damages she suffered as a result of the Federal
Constitutional violations described herein;
B. An award of compensatory damages against Defendants, in an amount
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12. 12
sufficient to compensate Plaintiff for damages she suffered as a result of the above-
described bases for liability arising under state law;
C. An award of punitive damages against Defendants, in an amount sufficient
to punish the Defendants and deter them, as well as others similarly situated, from
engaging in unlawful and unconstitutional conduct in the future;
D. An award of Plaintiff’s costs incurred in prosecuting this action, including
reasonable attorneys’ fees and any expert fees pursuant to 42 U.S.C. § 1988;
E. An award of any and all other relief to which Plaintiff may appear entitled,
and
F. The Plaintiff respectfully demands a trial by jury on all Counts so triable.
Respectfully submitted,
/s/ Bethany N. Baxter
JOE F. CHILDERS
BETHANY N. BAXTER
CHILDERS & BAXTER, PLLC
The Lexington Building
201 West Short Street
Suite 300
Lexington, Kentucky 40507
Telephone: (859) 253-9824
Facsimile: (859) 259-1909
joe@jchilderslaw.com
bethany@jchilderslaw.com
NED PILLERSDORF
PILLERSDORF LAW OFFICES
124 West Court Street
Prestonsburg, Kentucky 41653
Telephone: (606) 886-6090
COUNSEL FOR SABRINA ADKINS
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