Case Document 1 Filed 01/14/19 Page 1 of 16 PageID 1

UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH DAKOTA
SOUTHERN DIVISION
MICAH ROEMEN, Civ. NO. 
Plaintiff,

VS.

UNITED STATES OF AMERICA, COMPLAINT

ROBERT NEUENFELDT, individually
and UNKNOWN SUPERVISORY
PERSONNEL OF THE UNITED
STATES, individually,

Defendants.

COMES NOW, Plaintiff Micah Roemen, by and through undersigned

attorneys, and for his complaint against Defendants, alleges as follows:

 

JURISDICTION
1. Plaintiff, Micah Roeman, iS a resident Of Minnehaha County, state
Of South Dakota.
2. Jurisdiction is proper pursuant to 28 U.S.C. ?1346(b) and the

Federal Tort Claims Act, 28 U.S.C. ?2671, et seq., as amended and Pub.L.No.'
103?138, Tit. 111, 308, NOV. 11, 1993, 107 Stat. 1416.

3. Jurisdiction is also proper pursuant to 42 U.S.C.A. 1981, 1983,
1985 and 1988 and Bivens 1). Six Unknown Named Agents Of Federal Bureau of
Narcotics, 403 US. 388, 397, 91 S. Ct. 1999, 29 L. Ed. 2d 619 (1971), as well
as under the United States Constitution, including its Fourth, Eighth and

Fourteenth Amendments, and the Constitution Of the State of South Dakota.

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4. At all relevant times herein, the United States, by and through its
Department of the Interior, Bureau of Indian Affairs, contracted with the
Flandreau Santee Sioux Tribe and its Police Department pursuant to 25 U.S.C.
45f, et seq., Indian Self Determination Act, to provide law enforcement services
on the Flandreau Santee Sioux Indian Reservation.

5. At all relevant times herein, the Flandreau Santee Sioux Tribe and
its Police Department operated a police department on the Flandreau Santee
Sioux Indian Reservation and employed numerous employees, who were
performing functions under the contract entered into pursuant to 25 U.S.C.
450f, et seq, which renders said employees, United States Government
employees.

6. At all relevant times herein, Defendant, Robert Neuenfeldt was
acting as Flandreau Chief of Police under the color of state and federal law,
and in violation Plaintiffs? federally protected rights.

7. On or about April 27, 2018, Plaintiff submitted an Administrative
Tort Claim in the amount of $150,000,000, as required by 28 USC 2675 to
the United States Department of the Interior, Office of the Solicitor, 5600
American Boulevard West, Suite 270, Bloomington, Minnesota, 55437.

8. On December 3, 2018, the United States Department of the
Interior denied Plaintiff?s administration claim, thereby allowing this
Complaint.

9. As to Defendant, United States, this action is timely pursuant to

28 U.S.C.A. ?2401(b) in that it was presented to the appropriate agency within

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two years of accrual, and this action was filed within six months of receipt of
1 the certified letter sent by the United States Department of the Interior denying
the claim.

10. Plaintiff further invokes this Court?s pendent jurisdiction over any
and all state law claims and causes of action that derive from the same
nucleus of operative facts that give rise to the federally based claims and

causes of action pursuant to 28 U.S.C.A. 1367.


11. On June 18, 2017, Micah Roemen was a passenger in a vehicle
driven by Tahlen Bourassa.
12. Also accompanying Mr. Bourassa was a young woman named

Morgan Ten Eyck.

13. In the early morning hours of June 18, 2017, the Flandreau Tribal
Police Officers, along with the Moody County Deputy Sheriffs, the South
fDakota Highway Patrol, and the City of Flandreau Police Department stopped a
vehicle driven by Tahlen Bourassa.
14. Robert Neuenfeldt, Chief of Police for Flandreau Santee Sioux
Tribe, threatened to take Bourassa to jail. Bourassa then ?ed.

15. euenfeldt and Logan Baldini, an uncertified deputy for Moody

County Sheriff?s Office, both got in Neuenfeldt?s tribal police cruiser and

initiated pursuit.

16. Sargent Kurtz, South Dakota Highway Patrol, was also initially

involved in the pursuit.

 

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17. It is believed that Tahlen Bourassa, Micah Roemen and Morgan
Ten Eyck had not committed any crimes to justify the pursuit.

18. At the time the Bourassa vehicle was stopped, Neuenfeldt, and the
other officers at the scene, knew the identity of the driver, Tahlen Bourassa.

19. Neuenfeldt and the other officers at the scene, knew that Tahlen
Bourassa was actively being monitored by the South Dakota Parole Board
through a GPS ankle bracelet.

20. Notwithstanding that the officers knew specifically who was
driving the vehicle, knew that there had been no violations of the law, and
knew that two innocent passengers were in the vehicle, a high?speed pursuit
took place for over thirty minutes reaching speeds in excess of 100 miles per

hour on gravel roads.

21. On two occasions, spike strips were laid out without proper
authorization.
22. Just prior to the accident, spike strips were laid out and a

barricade of police cars forced Tahlen Bourassa to take a dead?end gravel road.
23. Defendants knew the dead?end road would result in an accident.
24. Prior to the catastrophic accident, which caused Claimant?s life?
threatening injuries, the South Dakota Highway Patrol aborted the pursuit.
25. It is believed that Neuenfeldt disregarded orders to terminate the

pursuit.

 

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26. Once the Highway Patrol terminated the pursuit, Neuenfeldt and
Baldini continued the pursuit causing Bourassa?s vehicle to lose control and
roll several times throwing all three occupants from the vehicle.

27. All occupants suffered incapacitating injuries and were life ?ighted
from the scene.

28. Micah Roemen sustained a serious closed head injury, pulmonary
contusion, broken wrist, vertebral body fractures at C1, C2, and C6 and
required a halo placement.

29. As a result of the accident, Plaintiff has sustained thousands of
dollars in medical bills.

COUNT I: NEGLIGENCE
Plaintiff realleges the information set forth in the paragraphs above and
further alleges:

30. Defendants owed a duty of care to Micah Roemen as an innocent
bystander and passenger of the ?eeing vehicle, and breached this duty by
failing to follow mandatory pursuit policies, causing severe and permanent
damages to Micah Roemen.

31. Defendants? numerous Violations of the pursuit policies constitute
reckless disregard for the safety of others.

32. Defendants? failed to follow the mandatory pursuit policy in the
following respects:

a. It is determined a vehicle pursuit is a use of force. This use of

force is confined to appropriate tribal jurisdiction. No pursuit can

 

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be initiated when it is outside their area of jurisdiction. In
addition, the officer failed to reasonably believe that the suspect, if
allowed to ?ee, presents potential danger to human life or may
cause serious injury;

b. In all areas of the jurisdiction,? officers are expected to end their
involvement of pursuit whenever the risk of their own safety or
safety of others outweigh the danger to the community if the
suspect is not apprehended;

c. It is mandatory that the officer in the primary unit notify the
dispatch of five items. No such notification occurred;

01. A secondary unit will be engaged to move into position and assume
the communication responsibility;

e. The secondary unit will coordinate the activities of other assessing
units;

f. The supervisor is ultimately responsible for terminating the
pursuit or allowing it to continue;

g. The supervisor will continually weigh the risk based on
information being received from dispatch and the pursuing unit;

h. The supervisor will immediately terminate the pursuit when the
pursuit is not in compliance with the requirements of this section;

i, Supervisors shall evaluate their actions based on the potential

benefits of their actions outweigh the risks that are involved;

 

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j. Pursuits are limited to two police vehicles. Additional units may
participateif directed by the supervisor or senior officer on duty;

k. If the pursuit extends off roadway, assessment of the risk must be
determined to decide whether to continue the pursuit;

1. Officers in pursuit must have received approved IPA training in the
use of tire de?ation devices;

m. Because use of tire de?ating devices is considered a roadblock,
only the chief of police or a supervisor can authorize their use.

The suspect must be a dangerous ?eeing felon;

11. Safety circumstances must be an important factor;

0. Determination of the most suitable safest location must be made;

p. Tire de?ation device must never be used if you believe the location
is unsafe;

q. Tire de?ation devices should never be deployed with pedestrians in
the immediate vicinity;

r. Only deploy a tire de?ation device after you have identified a safe
location to observe the pursuit;

s. A pursuit may only be extended beyond the reservation line if the
primary control of pursuit is relinquished as soon as practical to
police personnel of entered jurisdiction (here the pursuit was never
on tribal land);

t. Officers must follow LE Handbook Section 2?24?02, authorization

for pursuit when joining a pursuit initiated by another jurisdiction;

 

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u. OJ officers will discontinue pursuits initiated by another

jurisdiction when pursuit continues outside their jurisdiction
unless officer?s safety becomes a consideration;

v. High speed pursuits shall be limited to substantial crimes that
require immediate action;

W. High speed pursuits should not occur when the identity of the
driver is known; and

X. I High speed pursuits should be ended whenever the risks to the
safety of others outweigh the danger to the community if the

suspect is not apprehended.

33. Defendants violated every requirement as set forth in paragraph 32
above.
34. Defendants? actions also violated the policies regarding the use of

road blocks and spike strips.

35. The use of road blocks, and or spike strips, may only be used in
the case of suspected ?eeing felons whose escape poses a danger to life.

36. Tahlen Bourassa was not a ?eeing felon whose escape posed a
danger to life.

37. Defendants and the Bureau of Indian Affairs, an agency of the

United States of America, acting by and through their servants and employees,
all acting within the course and scope of their agency and employment with

Defendant, were negligent and reckless through numerous violations of their

own pursuit policies.

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38. If Defendant, United States, were a person, it would be liable in
accordance with the laws of South Dakota and the Flandreau Santee Sioux
Tribe.

39. As a direct legal result of Defendants? negligent, reckless, and
willful and wanton disregard for the safety of Plaintiff, Micah Roemen
sustained serious injuries and damages, which required substantial medical
care and have resulted in permanent injuries and future medical care.

COUNT II: 42 U.S.C.A 1983 (BIVENS 
Plaintiff realleges the information set forth in the paragraphs above and
further alleges:

40. This claim for relief is brought pursuant to Bivens 1). Six Unknown
Named Agents of Federal Bureau of Narcotics, 403 US. 288, 397, 91 S. Ct.
1999 29 L.Ed.2d 619 (1971), for Violations of Plaintiffs? rights under the Fourth
and Fifth Amendments of the United States Constitution when Defendant
Neuenfeldt used excessive, unreasonable, and unwarranted force during the
pursuit.

41. During all times herein, Defendant Neuenfeldt acted under color
and pretense of federal statutes, ordinances, regulations, policies, practices,
customs and uses of the United States of America.

42. On June 18, 2017, Plaintiff, Micah Roemen, had the right under

the Fourth Amendment to be free from unreasonable searches and seizures of

her person.

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43. On June 18, 2017, Plaintiff, Micah Roemen, possessed the rights
guaranteed by the Fifth Amendment to not be deprived of life and liberty
without due process of law, including but not limited to, the right not to suffer
physical harm from persons acting under the color of law that is intentionally
or wantonly in?icted or which is accomplished with deliberate, reckless, or
callous indifference to his constitutional rights.

44. On June 18, 2017, Plaintiff, Micah Roemen, had the rights
guaranteed by the Equal Protection Clause and the Due Process Clause of the
Fifth Amendment of the United States Constitution.

45. On June 18, 2017, Defendant Neuenfeldt, while acting under the
color of federal law as a United States Employee, intentionally deprived
Plaintiff, Micah Roemen, of his Fourth Amendment right to be free from
unreasonable seizures by subjecting her to excessive force during the pursuit.

46. On June 18, 2017, Defendant euenfeldt, while acting under color
of federal law as a United States Federal Employee, intentionally violated
Plaintiff, Micah Roemen?s rights guaranteed by the Fifth Amendment to not be
deprived of life and liberty without Due Process of law, including but not
limited to the right not to suffer physical harm from persons acting under color
of law that is intentionally or wantonly in?icted or which is accomplished with
deliberate, reckless, or callousindifference to his constitutional rights. While
acting under color of federal law as a United States Federal Agent, Defendant

Neuenfeldt was motivated by evil intent and conduct in which he engaged in by

10

 

Case Document 1 Filed 01/14/19 Page 11 of 16 PageID 11

use of excessive force in the pursuit and this conduct showed reckless or
callous indifference to her Constitutional rights.

47. Defendant Neuenfeldt, by using such unreasonable force, caused
injury and damage to Plaintiff, Micah Roemen, ultimately causing life
threatening injuries.

48. At the time of the June 18, 2017, pursuit, Plaintiff, Micah Roemen,
was not engaged in any assaultive behavior toward Defendant, Neuenfeldt or
any other persons.

49. The pursuit by Defendant Neuenfeldt was entirely unjustified by
any action of Plaintiff, Micah Roemen, and said pursuit constituted an
unreasonable and excessive use of force in violation of Plaintiff?s guaranteed
rights under the 14th Amendment of the United Stated Constitution, which
protects pretrial detainees from punishment.

50. Defendant Neuenfeldt acted specifically with the intent to deprive
Plaintiff, Micah Roemen, of the following rights and privileges guaranteed
under the United States Constitution:

1. Freedom from unreasonable seizures, in the form of the use of
excessive force;
2. Freedom from deprivation of liberty without Due Process of law;
3. Freedom from punishment prior to conviction for any crime; and
4. Equal protection of the laws.
51. After the pursuit, Plaintiff, Micah Roemen, suffered life

threatening, permanent injuries. Plaintiff suffered severe physical, emotional

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and damage as a result of the conduct of Defendant Neuenfeldt
and the Flandreau Santee Sioux Tribe.

52. Defendant Neuenfeldt and the Flandreau Santee Sioux Tribe
subjected Plaintiff, Micah Roemen to the aforementioned deprivations by either
actual malice or deliberate indifference and disregard of Plaintiff?s civil rights.

COUNT COMMON LAW ASSAULT AND BATTERY AGAINST
DEFENDANT EUENFELDT

Plaintiff realleges the information set forth in the paragraphs above and

further alleges:

53. The actions, set forth above, constitute common law assault and
battery.
54. The actions of the Defendants were malicious, reckless, intentional

and caused damages to the Plaintiffs.

55. Micah Roemen sustained a serious closed head injury, pulmonary
contusion, broken wrist, vertebral body fractures at C1, C2, and C6 and
required a halo placement. As a result of the accident, Plaintiff has sustained
thousands of dollars in medical bills.

COUNT IV: SECOND CLAIM FOR RELIEF FOR SUPVERVISORIAL
RESPONSIBILITY FOR VIOLATIONS OF THE CIVIL RIGHTS UNDER
COLOR OF LAW (BIVENS ACTION)
Plaintiff realleges the information set forth in the paragraphs above and
further allege:

56. This claim for relief is brought pursuant to Bivens 1). Six Unknown

Named Agents of Federal Bureau of Narcotics, 403 US. 288, 397, 91 S. Ct.

12

 

Case Document 1 Filed 01/14/19 Page 13 of 16 PageID 13

1999 29 L.Ed.2d 619 (1971), for violation of Plaintiff, Micah Roemen?s rights
under the Fourth and Fifth Amendments of the United States Constitution.

57. On and before June 18, 2017, Defendants implemented and
maintained customs, policies, and/ or practices to encourage the use of
excessive force by Defendant Neunfeld. Defendant Neuenfeldt intentionally,
deliberately, and or was indifferent to the violation of the constitutional rights
of persons in the same situation as and including Plaintiff Micah Roemen.

58. On June 18, 2017, Defendant participated in, encouraged,
fostered, condoned, and ratified the conduct of Defendant Neuenfeldt when
Defendant Neuenfeldt used excessive force in the pursuit and injuring Plaintiff
Micah Roemen, even though Plaintiff was defenseless, had no weapon of any
kinds, and was not threatening the Defendant or any third party.

59. As a direct and proximate result of Defendants intentional,
deliberate, and or indifference to the use of excessive force by Defendant
Neuenfeldt, Plaintiff Micah Roemen sustained life?threatening injuries on June
18, 2017.

60. By consciously and deliberately overlooking the use of excessive
force by Defendant Neuenfeldt, the Unknown Supervisory Personnel of the
United States established a pattern, custom, and practice of condoning and
ratifying such misconduct and criminal activity and established a tolerated
pattern of constitutional violations amongst their subordinate officers including
Defendant Neuenfeldt. The condoning of misconduct by Defendant Neuenfeldt

was so comprehensive and?well known that Unknown Supervisory Personnel of

13

 

Case Document 1 Filed 01/14/19 Page 14 of 16 PageID 14

the United States was emboldened to blatantly violate the constitutional rights
of Plaintiff, Micah Roemen and to commit crimes such as the excessive force
used in the pursuit.

61. Because of their failure to prevent the continuing constitutional
violations by the subordinates and because the establishment of the policies
and practices described above as well as their failure to adequately train their
subordinates, Unknown Supervisory Personnel of the United States are
individually liable for the constitutional violations committed by Defendant
Neunfeld inclusive and for the injuries to Plaintiff, Micah Roemen as a result of
the June 18, 2017 pursuit.

62. Because of their acts and or omission in their failure to prevent
the continuing constitutional violations by their subordinates and because of
their establishment of the policies and practices described above as well as
their failure to adequately train their subordinates, Defendant Neuenfeldt is
liable for his own independent acts and or omissions which were a
contributing factor in causing the constitutional violations which caused the
injuries to Plaintiff, Micah Roemen as a result of the June 18, 2017 pursuit.

63. Defendant Neuenfeldt?s actions were intentional, willful, malicious,
egregious, grossly reckless and negligent, and unprovoked.

WHEREFORE, Plaintiff respectfully prays that this Court will:
a. - Award compensatory damages to the Plaintiff, and against the

Defendants, jointly and severally, in the amount of $150,000,000.

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Case Document 1 Filed 01/14/19 Page 15 of 16 PageID 15

b. Award punitive damages to Plaintiff, and against Defendants,
jointly and severally.

c. Award Plaintiff costs and attorneys fees, pre-judgment and post
judgment interest, all other damages allowed by law, and such other further
relief the Court deems just and equitabldea?

Respectfully submitted this day of January, 2019.

BEARDSL Y, JENSEN 85 LEE, Prof. L.L.C.


 

Michael Beardsley

4200 Beach Drive, 'Suite 3

PO. Box 9579 .

Rapid City, SD 57709

Telephone: (605) 721?2800

Facsimile: (605) 721?2801

Email: sbeards@blackhillslaw.com

mbeardsley@blackhillslaw.com
Attorney for Plaintiff

DEMAND FOR JURY TRIAL
Pursuant to the provisions of Federal Rule of Civil Procedure 38, as to
causes of action against Defendants Neuenfeldt and Unknown Supervisory
Personnel of the United States, pursuant to Bivens and it?s progeny, Plaintiffs

hereby demand a trial by jury of any issue triable of right by jury.

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Case Document 1 Filed 01/14/19 Page 16 of 16 PageID 16

13 44 (Rev- 06/17) CIVIL COVER SHEET 

The IS 44 civil cover sheet and the information contained herein neither re lace nor supplement the ?lin and service of pleadings or other papers as re uired by law, except as
provrded by local rules of court. This form, approved by the Judicial Con erence of the United States in eptember 1974, is required for the use of the lerk of Court for the
purpose of Initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

 

 

 

I. PLAINTIFFS DEFENDANTS
Micah Roemen United States of America, Robert Neuenfeld, INDIVIDUALLY. and
Unknown Supervisory Personnel of the United States
County of Residence of First Listed Plaintiff Min nehaha County, SD County of Residence of First Listed Defendant 
(EXCEPTIN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONL 

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

 

 

 

 

 

  

 

 

       

 

 

 

   

 

 

   

 

 

 

 

 

 

 

 

 

 

(C) Attorneys (F inn Name, Address. and Telephone Number) Attomeys ([fKnown)
Steven C. Beardsley, Beardsley Jensen Lee, Prof. L.L.C.
P.O. Box 9579
Rapid City. South Dakota 57709
II. BASIS OF JURISDICTION (Place an in One Box Only) CITIZENSHIP OF PRINCIPAL PARTIES (Place an in One Box for Plaimrf
(For Diversior Cases Only) and One Box for Defendant)
El 1 U.S. Government Cl 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State IX 1 l3 1 Incorporated or Principal Place El 4 4
of Business In This State
2 U.S. Government El 4 Diversity Citizen of Another State El 2 El 2 Incorporated and Principal Place CI 5 El 5
Defendant (Indicate Citizenship of Parties in Item 111) of Business In Another State
Citizen or Subject ofa CI 3 El 3 Foreign Nation [3 6 CI 6
orei? Country
IV. NATURE OF SUIT (Place an in One Box Only) Click here for: Nature Of Suit Code Descri tions.
r5 .2 irrorgrs r'?iie we 
El 110 Insurance PERSONAL INJURY PERSONAL INJURY El 625 Drug Related Seizure Cl 422 Appeal 28 USC 158 375 False Claims Act
Cl 120 Marine Cl 310 Airplane 365 Personal Injury - ofProperty 21 USC 881 CI 423 Withdrawal 130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(3))
CI 140 Negotiable Instrument Liability El 367 Health Care! 400 State Reapportionment
El 150 Recovery of Overpayment El 320 Assault, Libel Pharmaceutical 1? El 410 Antitrust 
Enforcement of Judgment Slander Personal Injury 820 Copyrights El 430 Banks and Banking
El 151 Medicare Act El 330 Federal Employers? Product Liability El 830 Patent El 450 Commerce
El [52 Recovery of Defaulted Liability El 368 Asbestos Personal El 835 Patent - Abbreviated Cl 460 Deportation
Student Loans El 340 Marine Injury Product New Drug Application El 470 Racketeer In?uenced and
(Excludes Veterans) CI 345 Marine Product Liability Cl 840 Tradenik Corrupt Organizations
Cl 153 Recovery of Overpayment Liability PERSONAL PROPERTY 3? .. [3 480 Consumer Credit
of Veteran's Bene?ts [26 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards [3 861 HIA (1395ff) 490 Cable/Sat TV
CI 160 Stockholders? Suits Cl 355 Motor Vehicle Cl 371 Truth in Lending Act Cl 862 Black Lung (923) 850 Securities/Commodities/
El 190 Other Contract Product Liability El 380 Other Personal 720 Labor/Management El 863 (405(g)) Exchange
13 195 Contract Product Liability Cl 360 Other Personal Property Damage Relations 864 SSID Title XVI El 890 Other Statutory Actions
Cl 196 Franchise Injury Cl 385 Property Damage CI 740 Railway Labor Act 865 RSI (405(g)) CI 891 Agricultural Acts
El 362 Personal Injury - Product Liability Cl 751 Family and Medical El 893 Environmental Matters
Medical Malpractice Leave Act Cl 895 Freedom of Information
133:; 3:32 r1113" i i 790 Other Labor Litigation TAX Act
Cl 210 Land Condemnation CI 440 Other Civil Rights Habeas Corpus: Cl 79] Employee Retirement [j 870 Taxes (U.S. Plaintiff 896 Arbitration
220 Foreclosure El 441 Voting Cl 463 Alien Detainee Income Security Act or Defendant) 899 Administrative Procedure
Cl 230 Rent Lease Ejectment 442 Employment CI 510 Motions to Vacate CI 871 IRS~Third Party ActfReview or Appeal of
Cl 240 Torts to Land El 443 Housing] Sentence 26 USC 7609 Agency Decision
CI 245 Tort Product Liability Accommodations El 530 General 950 Constitutionality of
CI 290 All Other Real Property 445 Amer. wlDisabilities - Cl 535 Death Penalty 5:373. State Statutes
Employment Other: Cl 462 Naturalization Applicatio
El 446 Amer. w/Disabilities - 540 Mandamus Other [3 465 Other Immigration
Other Cl 550 Civil Rights Actions
El 448 Education El 555 Prison Condition
560 Civil Detainee -
Conditions of
Con?nement
V. ORIGIN (Place an in One Box Only)
1 Original El 2 Removed from El 3 Remanded from El 4 Reinstated or Cl 5 Transferred from El 6 Multidistrict Cl 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation 
(specij) Transfer Direct File

 

Cite the U.S. Civil Statute under which you are ?ling (Do not cite jurisdictional statutes unless diversity):
28 

Brief description of cause:
Motor vehicle accident - Plaintiff was passenger in vehicle.

VI. CAUSE OF ACTION

 

 

 

 

 

 

 

VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND - Amount to be CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, PROV-P. determined by 5? JURY DEMAND: tat Yes 
RELATED . .
IF ANY (See instructions). JUDGE DOCKET BER
DATE SIGNATURE OF ATTORNEY OF RECORD
01/1 41201 9 Isl Steven C. Beardsley
FOR OFFICE USE ONLY 

RECEIPT it AMOUNT APPLYING IFP JUDGE MAG. JUDGE