THE STATE OF RIDGEWAY
RIDGEWAY COUNTY COURT
Tomskipetski5,
-against-
LewisMedvedeva, In His Official and Personal
Capacity as Chief of the Palmer Police
Department
Defendant.
Case No. CCRV-CV-1308
RESPONSE TO CIVIL COMPLAINT
Presiding Judge: Honorable Antradz
RESPONSE
1. The plaintiff alleges that the defendant is liable for the following torts:
a) 5 R. Stat. §401 - Official Misconduct
b) 5 R. Stat. §315 - Review of Administrative actions
The defense asserts that the requested tort, 5 R. Stat. §401, is inapplicable due to the fact that the
plaintiff does not possess statutory powers to prosecute or hold individuals or government employees
liable under 5 R. Stat. §401, which is listed under Chapter 4: Additional Criminal torts.
The defense also asserts that, within the civil complaint, the plaintiff admits guilt to violating the
Non-Disclosure agreement that he or she has signed . The complaint states “The plaintiff provided this 1
piece of evidence to assist his friend, Mr_Bot47, in being able to file a complaint; meaning the plaintiff
was essentially acting as a whistleblower on misconduct, for which he was punished for. It is the
opinion of the counsel for the plaintiff that it is absurd for officials from the Palmer Police Department
to contest that his actions constituted a “severe” violation of the department’s Non-Disclosure
Agreement, when he was acting in good faith to assist a friend in exposing allegedly illegal conduct by
the police.” The plaintiff asserted that he “acted” in good faith, as a ‘whistleblower’, to violate the
Non-Disclosure Agreement.
The defense asserts that there are no statutory provisions or protections for government
employees to act as whistleblowers against their departments, and or divisions. Good faith doctrine has
been established by the United States Supreme Court, outlinted in United States vs Leon 468 U.S. 897, as
an exception to the 4th amendment exclusionary rule. The exclusionary rule only applies when the
government gains evidence from an unreasonable search or seizure in violation of the 4th amendment.
This ultimately means that the ‘Good Faith’ doctrine is inapplicable to the legal merits of this case. The
administrative actions, taken against the plaintiff, were reasonable and lawful. Clause 5 of the
Non-Disclosure Agreement states that any breach of this agreement may result in termination of his or her
employment. The Non-Disclosure Agreement does not state or outline any exceptions or exclusions to
Clause 5.
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The defense also asserts that, within the civil complaint, the Plaintiff admits guilt to violating
Palmers Police Department SOP(Standard Operating Procedure). The plaintiff states the following “The
only part that the plaintiff has ever violated in this policy is one of the last points which says that the
complainant must remain in compliance with department policies which I apparently violated by the
ride along policy. In the “Ride Along Policy” the complainant has violated no points outside of
forgetting to send the screenshot of the signed waiver to my superior directly ....”. The Plaintiff
negligent actions did not provide any screenshot to his supervisor of the signed waiver , which releases 2
civil liability from Palmer Police Departments and it’s officers. Because of the plaintiff's negligent
actions, the plaintiff created civil liability for the department, and himself.
The Plaintiff asserts that the placement of Administrative Leave, searching of personal vehicles,
and the entire investigation was biased and unlawful. Pursuant to the Standard Search Agreement signed
by the plaintiff, it states “I hereby forego any expectation of privacy granted to a private citizen. I grant
the right and ability for the county government, including criminal investigation entities of it, to search
my vehicles, person, house, and other properties with reason. I consent and grant the ability for
departments to conduct randomized searches on my vehicles, such that those searches do not violate
any law, regulation, or constitutional provision and are equally applied.” Thus, meaning the search was
lawful conducted by Palmer Police Department criminal investigation division(s). The Plaintiff also lacks
evidence to prove that their was biased within the investigation, thus rendering a baseless claim aimed at
Palmer Police Department
DATED: June 17th, 2021
Respectfully submitted,
Jaredft45
Assistant District Attorney
Counsel for Defendant
/s/ jaredft45
2 https://prnt.sc/156kp88
