RIDGEWAY ADMINISTRATIVE COURT
XJVMMA,
Plaintiff,
v.
PIRATEHOOKTAIL,
Defendant.
Case No.
CIVIL COMPLAINT
INTRODUCTION
1. Lieutenant Jemma has been a law enforcement officer for a year and a half with the
Palmer Police Department. Throughout this time, the Lieutenant rose through the ranks
and is now the head of the Training Division where she teaches the future of law
enforcement in Ridgeway. She is a highly decorated law enforcement officer, a
well-respected leader, and most importantly, a recognizable figure in the Ridgeway
Community.
2. For the entirety of her law enforcement career, the Lieutenant has maintained a spotless
disciplinary and criminal record. That was until the Defendant, a well-known criminal
with nearly 90 records to his name, trimmed a video that made the Lieutenant appear to
commit a crime.
3. The Defendant, on his own admission, was not aggrieved by the Lieutenant’s actions, yet
filed a complaint with the Palmer Police Department Internal Affairs and the Department
of Justice. The reason? So that he could get back at her for having “disrespected” him.
4. Defendant filed a malicious complaint to two separate agencies which resulted in a full
internal and criminal investigation into the Plaintiff.
5. She has lost her reputation, she has lost her wages, and indeed, she has lost the respect
that a veteran officer of her standing is owed. She has lost 1 year and 6 months of
progress because the Defendant maliciously and vexatiously submitted complaints with
the intention of getting her in trouble. Not because he believed she did anything
wrong—instead, because he was vindictive.
6. Vengeful and malicious filings have no place in Ridgeway. Accordingly, Lieutenant
Jemma alleges as follows:
PARTIES
7. xJvmma (“Jemma”) is a citizen of the State of Ridgeway.
8. PirateHookTail (“Pirate”) is a citizen in the State of Ridgeway.
JURISDICTION
9. This court has original jurisdiction over all “civil…cases or controversies.” RW St.
Const. Article V, § IV.
10. This case is a tort action in accordance with 1 R. Stat. § 3112.
FACTS
11. Plaintiff Jemma is a long-standing member of the Ridgeway Community having been a
part of it for nearly 2 years.
12. Since the outset of her career, Jemma has been an exemplary law enforcement officer.
Having graduated from the Law Enforcement Training Center class 5 in June of 2021,
Jemma has worked as a Palmer Police Department Officer for a year and a half. She has
worked her way all the way up to the position of Lieutenant of the Training Division
where she is head of an entire law enforcement division which is chiefly in charge of
training new law enforcement officers so that they are best prepared for the road.
13. Since her start in the agency, Jemma had not received any recorded disciplinary action of
any kind, and exclusively received commendations from those in charge of her, allowing
her to move so quickly through the ranks.
14. Among these commendations is the Chief Commendation for excellence in commanding
the Training Division, the Instructor Decoration, achievement of Command Service on
07/12/2021, achievement of 6 Months Service on 02/15/2022, and 12 Months Service on
07/12/2022.
15. On December 4th, 2022, Lieutenant Jemma was patrolling with two recruit officers to
help orient them to the job of being a police officer.
16. While patrolling, her recruit officers noticed that there was a driver on the roadway who
was driving recklessly by swerving across the road and speeding.
17. The recruit officers initiated a traffic stop on the individual who was driving recklessly
near Tom’s Takeout in the City of Palmer.
18. The Defendant was the subject of the stop.
19. Jemma was providing cover to the recruit officers who were executing the stop when the
Defendant, Pirate, got out of the vehicle without being prompted and ran over to the
position of the officers.
20. PirateHookTail is a well-known criminal in the State of Ridgeway who has over 85
criminal records which range from multiple counts of stealing, to murder, to evasion, to
assault, among many others.
21. Having this record in mind, and identifying the driver as Pirate, Jemma remained extra
cautious when engaging in the traffic stop.
22. When the Defendant got out of the car and sprinted over to the sidewalk where the
Plaintiff, among many other officers was standing, Jemma, in her experienced, clicked on
the key to pull out a non-lethal weapon—the bean bag gun—as a means to bring the
Defendant under control.
23. Jemma did not realize, however, that the key she clicked on had the M2 firearm instead
of the bean bag gun that she intended to grab.
24. The traffic stop ended, and within a few minutes, the Plaintiff attempted to apologize to
the Defendant in front of the gas station in Palmer and even gave him $500 as an apology
which the Defendant accepted.
25. As this was happening, the Defendant asked Jemma to explain herself. When she
explained that she had actually intended to shoot the bean bag gun, the Defendant asked
Jemma to demonstrate.
26. Jemma then brought the Defendant out of the road that he was obstructing and shot the
bean bag gun at the Defendant as he had requested and consented to.
27. The Defendant had recorded all of these interactions.
28. On a separate day, the Defendant purports that Jemma had told him to “STFU.”
29. The Defendant, then, trimmed the video that he had recorded so that it only depicted
Jemma mistakenly shooting him with the M2, and shooting him as requested and
consented to with the shotgun and submitted them to the internal affairs division of the
Palmer Police Department along with the Department of Justice.
30. The Defendant says that he filed these cases because “he doesn’t take disrespect.”
Referring to when Jemma told him to “STFU.”
31. When asked whether the Defendant was actually injured by the actions of the Plaintiff he
responded that the answer was no because they were “just goofing around” and “kinda
chilling.”
32. The Defendant says that even though he was just goofing around, and wasn’t actually
injured, he figured he “could just use it against her after she disrespected me.”
33. The Defendant further noted that he does this often. He collects images and videos to use
against people in case they disrespect him.
34. The Defendant was not truly aggrieved by the actions of the Plaintiff, and does not
purport to be. He instead cut the video out of its context in order to present a situation
that would get the Plaintiff in trouble so that he could get back at her for disrespecting
him.
35. As a result of this malicious reporting, the Plaintiff has been suspended indefinitely since
December 22nd, 2022 causing her to miss out on wages by order of the Attorney General.
36. Additionally, she has received a permanent indication on her record which shows the
disciplinary action.
37. The Plaintiff has also suffered huge reputational damage in the community because the
Defendant has maliciously filed this case with such grave allegations, knowing that he
failed to completely represent the truth.
38. In addition to the indefinite suspension, the Agency, as a result of the complaint
submitted by the Defendant, caused the Plaintiff to face formal suspension from
December 14th, 2022-December 18th, 2022.
39. The internal affairs report submitted with regard to this case noted the Defendant’s good
conduct, her vital role, and her record as an exemplary employee.
FIRST CAUSE OF ACTION
(1 R. Stat. § 3112 Abuse of Legal Processes)
40. All allegations in this complaint are re-alleged and incorporated in full in this cause of
action.
41. The Defendant cut videos out of context and submitted them to the Internal Affairs
division of the Palmer Police Department and the Department of Justice so that he could
get back at Jemma for being “disrespectful.”
42. The Defendant submitted a complaint about an officer when he was not actually
aggrieved and did it solely out of malice because he was mad at her over something she
had later said.
43. The filed complaint resulted in a criminal court proceeding which was later dismissed, a
criminal investigation by the State Bureau of Investigations, and a complete investigation
by the Internal Affairs Division of the Palmer Police Department.
44. In maliciously submitting a report against the Plaintiff to both the Department of Justice
and to the Palmer Police Department, the Defendant abused legal processes with claims
that misrepresented the truth in order to get the Plaintiff in trouble, making the claims
vexatious and fraudulent.
RELIEF
WHEREFORE, Plaintiff requests that the court grant relief as follows:
A. Punitive damages of $2,500.
B. Compensatory damages of $5,000 for injury suffered to Plaintiff’s reputation as a
law enforcement officer, administrator, and community leader. As well as for time
spent fighting litigation in the form of a grand jury indictment. As well as time
spent defending herself in internal affairs proceedings.
C. Compensatory damages of $5,000 in lost wages for causing the Defendant’s
suspension for a period spanning from December 14th, 2022 and continuing past
the filing of this civil complaint.
D. Injunctive relief in the form of a restraining order prohibiting the Defendant from
filing any administrative complaints against the Defendant.
E. Injunctive relief in the form of a reversal of any administrative action taken by the
Palmer Police Department and Department of Justice with regard to this case.
F. Attorneys’ costs and fees associated with this litigation and all litigation related to
the filing of any report related to the incident at issue in this cas
G. Any other relief deemed necessary by this court.
Dated: December 30, 2022. Respectfully submitted.
CLIFFORD2
Counsel
10 000
TURNTABLE5000
Counsel
10 000
