STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
FOREHEADTRIGGER,
Plaintiff(s),
v.
PALMER POLICE DEPARTMENT,
Defendant(s).
Case Number: RSC-AD-3027
Presiding: Hon. Xiqaq
ADMINISTRATIVE COMPLAINT
CIVIL COMPLAINT
PLAINTIFF, ForeheadTrigger, by and through the undersigned counsel, alleges the following:
JURISDICTION & VENUE
1. The court has jurisdiction to hear “all civil and criminal cases or controversies.”
Ridgeway State Constitution Article V, Section IV.
2. Venue is proper as the tortious actions alleged herein took place in Ridgeway County,
Ridgeway.
PARTIES
3. ForeheadTrigger (“Plaintiff”) is a resident of Ridgeway County. He is also a citizen of the
State of Ridgeway—his place of business and personal home address is unknown; but it
is understood that he resides within the applicable jurisdiction as hereinafter referenced
and applied in this case.
4. Palmer Police Department(“Defendant”) is a government department of the City of
Palmer. They are under the control of the Ridgeway State Government.
FACTS
I. Internal Affairs Investigation
5. On the 25th of April 2024, Plaintiff was contacted by the Palmer Police Department
Internal Affairs Unit regarding a complaint against him. This complaint alleged a
handbook violation relating to their vehicle policy.
6. Plaintiff agreed to answer questions for the Internal Affairs Unit. On the 27th of April
2024, the Interview began.
7. Plaintiff asked the Investigator for evidence relating to this complaint and alleged
violation and he was dismissed by the investigator multiple times, stating that the
evidence was “classified”.
8. The Interview continued until the 7h of May 2024. During this time, the Defendant failed
to provide evidence, or statements required that would allow Plaintiff the ability to put
forth an adequate defense.
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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II. Internal Affairs Outcome
9. On the 13th of May 2024, the Internal Affairs Unit concluded its investigation, and issued
a Disciplinary Action Report to Plaintiff. This Report detailed the violations, and how the
investigator came to their conclusion. As a result of the investigation, Plaintiff was issued
an Administrative Demerit - a Written Warning.
FIRST CAUSE OF ACTION
REVIEW OF ACTION - 2 R. STAT. § 3117
10. All prior paragraphs within this complaint are incorporated as if they were fully set forth
herein.
11. Per 8 R. Stat. § 2404, Internal Affairs Agencies are required to provide all statements to
the Defendant prior to being afforded the right to make a defense. During and prior to the
12-day interview, starting on the 25th of April, Defendant failed to provide all statements
including that of the complainants.
12. Per 8 R. Stat. § 2502, Internal Affairs Agencies are given 7 days to make a determination
in relation to a complaint that was filed. The Palmer Police Department failed to provide
a determination within 7 days as required, the Plaintiff’s interview taken nearly double
that.
13. When an Internal Affairs Division issues an administrative demerit without “due
observance of law”, a Plaintiff is entitled to seek a review from the administrative court.
The Internal Affairs Division issued an Administrative Demerit without due observance
of law, when they failed to uphold procedural rights and investigatory procedure.
RELIEF
WHEREFORE, Plaintiff requests the court to grant relief to redress the injury as follows:
a. Declaratory relief declaring that Defendant unlawfully issued an administrative demerit
to Plaintiff;
b. Declaratory relief declaring that Defendant violated Plaintiff’s due process rights;
c. Injunctive relief removing the Administrative Demerit from Plaintiff’s record.;
d. Granting Plaintiff such other further relief as the court finds just and proper.
June 10, 2024 Respectfully submitted,
MatthewSandringham
Counsel of Record
Clarke, Feelings & Associates, LLP.
Managing Partner
R. Bar. No. 16103
Br1452232
Clarke, Feelings & Associates, LLP.
Junior Associate
R. Bar. No. 28102
Attorneys for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
FOREHEADTRIGGER,
Plaintiff(s),
v.
PALMER POLICE DEPARTMENT,
Defendant(s).
Case Number: RSC-AD-3027
Presiding: Hon.
INITIAL DISCLOSURE
INITIAL DISCLOSURE
PLAINTIFF, ForeheadTrigger, by and through the undersigned counsel, submits this document
in the above-entitled matter, pursuant to Rid. Civ. P. 19 and Fed. R. Civ. P. 25.
INITIAL DISCOVERY
Plaintiff submits the following articles as initial discovery as to the tortious claims listed within
the civil complaint, pursuant to Rid. Civ. P. 19:
a. Exhibit A - Disciplinary Action Report
b. Exhibit B - IA Interview with Plaintiff
i. Exhibit B.I
ii. Exhibit B. II
iii. Exhibit B. III
iv. Exhibit B. IV
v. Exhibit B. V
vi. Exhibit B. VI
vii. Exhibit B. VII
viii. Exhibit B. VIII
June 10, 2024 Respectfully submitted,
MatthewSandringham
Counsel of Record
Clarke, Feelings & Associates, LLP.
Managing Partner
R. Bar. No. 16103
Br1452232
Clarke, Feelings & Associates, LLP.
Junior Associate
R. Bar. No. 28102
Attorneys for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
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