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By Joseph Zrnchik for 5th Estate Media Email: [email protected] (Reporter)
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Schererville Police Officers Assault and Kidnap Innocent Man and Lie About It

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JOSEPH ZRNCHIK  )            IN THE SUPERIOR COURT

                              )            OF LAKE COUNTY

Plaintiff                   )           

                              )                3000 W. 93rd AVENUE

vs.             )            CROWN POINT, IN  46307                                                                              

                 )                          CAUSE NO. 45D04-0709-CT-00263

TOWN OF SCHERERVILLE  )

                       AND              )                   SPECIAL JUDGE

                                           )            JOHN M. SEDIA

)

OFFICER CHRISTOPHER GOLDASICH   )

In his official capacity as a Schererville     )

Police Officer                                           )

                                                               )

OFFICER DAVID NANGLE in his              )

Official Capacity as a Schererville             )

Police Officer                                          )

 )                                                           

OFFICER HIGHLAND WEAVER in his     )

Official Capacity as a Schererville            )

Police Officer                                         )

)

OFFICER NIGEL FLENAR in his            )

OFFICIAL CAPACITY as a Schererville  )

Police Officer                                        )

)

DEFENDANTS                                      )

 

 

 

PLAINTIFF’S 1st AMENDED COMPLAINT FOR DAMAGES

 

 

The Plaintiff, complaining of the Defendants, pro se, respectfully shows to this Court and alleges:

 

1.  Upon information and belief, that at all times hereinafter mentioned, the defendant Town Of Schererville was and still is a municipal corporation duly organized and existing under and by virtue of the laws of the State of State of Indiana.

2.  Upon information and belief, that at all times hereinafter mentioned, the defendant Town of Schererville, its agents, servants and employees operated, maintained and controlled the Police Department of the Town of Schererville, including all the police officers thereof.

3.  Upon information and belief, that at all times hereinafter mentioned, and on or prior to the 23rd of December 2006, Officer Goldasich and Officer Nangle, were employed by the defendant, Town of Schererville, as a police officer.

4.  That Notice of the Plaintiffs’ Claim and Notice of Intention to Sue for Damages, the nature of the claim and the date of, the time when, the place where and the manner in which the claim arose was duly served upon Clerk Treasurer of the defendant Town of Schererville on June 6th 2007 in person and sent certified mail return receipt requested on June 6th, 2007.

5.  That no hearing has been requested or required pursuant to Indiana law regarding notice of claim to a municipality

6.  That more than 30 days have elapsed since the Notice of Claim and Intention to Sue has been served upon the defendants and the said defendants have neglected or refused to make any adjustment or payment thereof.

7.  That this action is commenced within the applicable claim period after the cause of action arose.

FIRST CAUSE OF ACTION—FALSE ARREST

8.  The plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs marked 1 through 7 with the same force and effect as if more fully set forth herein.

9.  That on or about the 23th of December, 2006, at or about 3:00 pm , on the property of Wash Station, a carwash located at 1150 W Lincoln Hwy, Schererville located at 1204 U.S. Highway, Schererville, IN, the defendants, their agents, servants and employees wrongfully and falsely arrested and confined plaintiff, Joseph Zrnchik, without any right or grounds therefor.

10.  That on or about the December 23th 2006, the defendants wrongfully and falsely accused the plaintiff, Joseph Zrnchik of the crime of Disorderly Conduct and Trespassing.

11.  That the said arrest and police custody of plaintiff was caused by the defendants, their agents, servants and employees, without any warrant or other legal process and without authority of the law and without any reasonable cause or belief that the plaintiff, Joseph Zrnchik, was in fact guilty of such crimes.

12.  That on the aforesaid date, time and place, the plaintiff, who was lawfully and properly upon the private property there at to await his wife, was illegally grabbed and forced into a Officer Nangle’s police car by Officer Goldasich while other Schererville Police Officer watched. 

13.  While the plaintiff was so engaged, as aforesaid, the defendants, their agents, servants and employees, wrongfully and unlawfully, against the plaintiff’s wish, without probable or reasonable cause, and on these sole charges, then made, stated that plaintiff was violating Indiana Code in that he was allegedly Tresspassing and committing the misdemeanor of Disorderly Conduct.  Defendants then arrested and confined the plaintiff in a police car with full force of arms whereby they forcibly and violently seized, assaulted, laid hold of, and compelled him to go with said defendant police officers who refused to answer plaintiff’s question of whether plaintiff was under arrest or not and refused to tell plaintiff to where he was being taken when defendant demanded to know if he was under arrest and demanded to know where he was being taken.  Defendant Goldasich then told plaintiff’s wife, Paula Zrnchik, that plaintiff was under arrest and that she could get him from the police station after he was booked.  Defendant was taken without knowing as to where he was being transported and was dropped off on the corner of Route 30 and U.S. 41 by Officer Nangle. 

14.  That the defendants, their agents, servants and employees acting within the scope of their authority and within the scope of their employment, detained and imprisoned the plaintiff even though the defendants, their agents, servants and employees, had the opportunity to know or should have known, that the matters heretofore alleged, wrongfully, unlawfully and without a sufficient charge having been made against the plaintiff, directed that the plaintiff be searched and placed in confinement at said locations.

15.  That the plaintiff was wholly innocent of the said criminal charges and did not contribute in any way to the conduct of the defendants, their agents, servants and employees and was forced by the defendants to submit to the aforesaid arrest and imprisonment thereto entirely against his will.

16.  That as a result of the aforesaid false, wicked, and malicious accusations made by the defendants, their agents, servants and employees acting under their employment and within the scope of their authority, the plaintiff’s recording device was taken and the evidence destroyed prior to defendant being  taken and then released at corner of Route 30 and U.S.

17.  That the defendants, their agents, servants and employees, as set forth aforesaid on the aforementioned date, time and place, intended to confine the plaintiff; in that the plaintiff was conscious of the confinement; plaintiff did not consent to the confinement; and that the confinement was not otherwise privileged.

18.   That by reason of the false arrest, imprisonment and detention of the plaintiff, plaintiff was subjected to great indignities, humiliation and ridicule, in being so detained, and accused of various crimes, and was then and there prevented and hindered from performing and transacting his necessary affairs and business, and he was caused to suffer pain in both mind and body with the possible loss of employment and employment opportunities.

19.  That by reason of the aforesaid, the plaintiff has been damaged in the sum of TWENTY-THOUSAND  ($20,000) DOLLARS.

SECOND CAUSE OF ACTION—ASSAULT

20.  Plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs marked 1-19 with the same force and effect as if more fully and at length set forth herein.

21.  That on or about the 23RD of December, 2006,  at approximately  3:00 pm, while the plaintiff was lawfully and properly on the property near premises known and designated as QUEST, but not on QUEST property itself but instead on the property of a car wash adjacent to the property, the defendants, their agents, servants and employees, and particularly defendants Goldasich and Nangle, without just cause or provocation and with force and violence, seized, assaulted and laid hold of the plaintiff, Joseph Zrnchik, and forced him into a police car. 

22.  That the defendants, their agents, servants and employees, acting as agents and on behalf of defendants and within the scope of their employment, intentionally, willfully and maliciously assaulted plaintiff, Joseph Zrnchik, in that they had issued threats to cause imminent harmful and/or offensive bodily contact and intentionally threatened a violent and/or menacing act which caused apprehension in the plaintiff, and defendants, in a hostile, offensive, threatening, and menacing  manner threatening manner threatened plaintiff with an intention of causing harmful and/or offensive bodily contact to the plaintiff and caused such batter in and about his body and limbs.

23.  That by reason of the aforesaid intentional assault committed by the defendants, their agents, servants and employees, acting within the scope of their authority, and without probable or reasonable cause, the plaintiff suffered fear and anxiety. 

24.  That defendant Nangle grabbed plaintiff’s recording device which had been presented as a recording device to all officers and which had been in plaintiff’s possession from the time of Nangle’s arrival to the scene up until Nangle grabbed it from plaintiff approximately 20 minutes later while plaintiff was being forcibly placed in Nangle’s police car by Goldasich.  Nangle laughed after forcibly grabbing the recording device from plaintiff with the intent to destroy audiotaped evidence of the incident  while laughing at Plaintiff and stating,  “I was worried it might be a weapon.”.  While laughing Nangle began pressing the buttons on the device to turn off the recorder and delete the recording.   

25.  That by reason of the aforesaid, the plaintiff has been damaged in the sum of TWENTY-THOUSAND ($20,000) DOLLARS.

THIRD CAUSE OF ACTION—BATTERY

26.  Plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs marked 1-25 with the same force and effect as if more fully and at length set forth herein.

27.  That on or about the 23RD of December, 2006,  at approximately  3:00 pm, while the plaintiff was lawfully and properly on the property known and WASH STATION, the defendants, their agents, servants and employees, and particularly defendants Goldasich and Nangle, without just cause or provocation and with force and violence, seized, battered and laid hold of the plaintiff, Joseph Zrnchik, and forced him into a police car by twisting his arm behind his back and forcibly confining him. 

28.  That the defendants, their agents, servants and employees, acting as agents and on behalf of defendants and within the scope of their employment, intentionally, willfully and maliciously battered plaintiff, Joseph Zrnchik, in that they had the real or apparent ability to cause imminent harmful and/or offensive bodily contact and intentionally did a violent and/or menacing act which resulted in contact with the plaintiff, and that act(s) caused apprehension of such contact in the plaintiff, and defendants, in a hostile and/or offensive manner touched the plaintiff without his consent and with the intention of causing harmful and/or offensive bodily contact to the plaintiff and caused such battery in and about his body and limbs.

29.  That by reason of the aforesaid intentional battery committed by the defendants, their agents, servants and employees, acting within the scope of their authority, and without probable or reasonable cause, the plaintiff suffered conscious pain and was otherwise damaged.

30.  That defendant Nangle grabbed plaintiff’s recording device which had been presented as a recording device to all officers and which had been in plaintiff’s possession from the time of Nangle’s arrival to the scene up until Nangle grabbed it from plaintiff approximately 20 minutes later while plaintiff was being forcibly placed in Nangle’s police car by Goldasich.  Nangle laughed after forcibly grabbing the recording device from plaintiff with the intent to destroy audiotaped evidence of the incident  while laughing at Plaintiff and stating,  “I was worried it might be a weapon.”.  While laughing, Nangle began pressing the buttons on the device to turn off the recorder and delete the recording.   

31. That by reason of the aforesaid, the plaintiff has been damaged in the sum of TWENTY-THOUSAND ($20,000) DOLLARS.

FOURTH CAUSE OF ACTION—NEGLIGENCE IN PERFORMANCE OF DUTIES

32.  Plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs marked 1 through 31 with the same force and effect as if more fully set forth herein.

33.  That the defendants, its agents, servants and employees negligently, carelessly and recklessly performed their police duties in that they failed to use such care in the performance of their police duties as a reasonably prudent and careful police officer would have used under similar circumstances in that they carelessly, recklessly and negligently arrested the plaintiff without making a proper investigation, in that they were negligent, careless and reckless in the manner in which they operated; that the defendants, their agents, servants and employees negligently, carelessly and recklessly without provocation used the threat of physical force and actually used physical force upon the plaintiff thereat; and in that the defendants, their agents, servants and employees were otherwise careless, reckless and negligent.

34.  That the aforesaid occurrence, to wit: the false arrest and police custody, and the assault and battery and the resulting injuries to plaintiff’s mind and attack on the body there from, were caused wholly and solely by reason of the negligence of the defendant, its agents, servants and employees without any negligence on the part of the plaintiff.  Goldasich, since the time of the incident, has threatened the Plaintiff and the Schererville Police Department  has refused to document the incident.

35.  That by reason of the aforesaid, the plaintiff was injured in mind and body, still suffers and upon information and belief, will continue great mental pain and incurred expenses in an effort to cure himself of said injuries to extricate himself from the indignities and humiliation foisted upon him by the actions of the defendants, their agents, servants and employees, including legal costs and

other disbursements; and upon information and belief, will expend further sums in that direction, and the plaintiff has been otherwise damaged.

36. That by reason of the aforesaid, the plaintiff has been damaged in the amount of  TWENTY-THOUSAND ($20,000) DOLLARS.

FIFTH CAUSE OF ACTION—CRIMINAL CONFINEMENT

37.  Plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs marked 1 through 36 with the same force and effect as if more fully set forth herein.

38.  That on or about the 23RD of December, 2006,  at approximately  3:00 pm, while the plaintiff was lawfully and properly on the property known and WASH STATION, the defendants, their agents, servants and employees, and particularly defendants Goldasich and Nangle, without just cause or provocation and with force and violence, seized, battered and laid hold of the plaintiff, Joseph Zrnchik, and forced him into a police car by twisting his arm behind his back and forcibly confining him. 

39.  That the defendants, their agents, servants and employees, acting as agents and on behalf of defendants and within the scope of their employment, intentionally, willfully and maliciously battered plaintiff, Joseph Zrnchik, in that they had the real or apparent ability to cause imminent harmful and/or offensive bodily contact and intentionally did a violent and/or menacing act which resulted in contact with the plaintiff, and that act(s) caused apprehension of such contact in the plaintiff, and defendants, in a hostile and/or offensive manner touched the plaintiff without his consent and with the intention of causing harmful and/or offensive bodily contact to the plaintiff and caused such battery in and about his body and limbs.

40.  That by reason of the aforesaid intentional battery committed by the defendants, their agents, servants and employees, acting within the scope of their authority, and without probable or reasonable cause, the plaintiff suffered conscious pain and was otherwise damaged.

41.  That Defendant Goldasich grabbed and pushed plaintiff into a police car and confined him to that police car against plaintiff’s will and plaintiff was conscience of that confinement, that plaintiff demanded his release, whereupon his demands were ignored and he was driven against his will to what was an undisclosed location and that the disclosure of the transport of plaintiff was not made to the police dispatcher.   

42.  That defendant Nangle grabbed plaintiff’s recording device which had been presented as a recording device to all officers and which had been in plaintiff’s possession from the time of Nangle’s arrival to the scene up until Nangle grabbed it from plaintiff approximately 20 minutes later while plaintiff was being forcibly placed in Nangle’s police car by Goldasich.  Nangle laughed after forcibly grabbing the recording device from plaintiff with the intent to destroy audiotaped evidence of the incident  while laughing at Plaintiff and stating,  “I was worried it might be a weapon.”.  While laughing Nangle began pressing the buttons on the device to turn off the recorder and delete the recording.  

43. That Defendants Nangle and Goldasich knowingly or intentionally confined plaintiff without the plaintiff’s consent and removed plaintiff by force, and the threat of force, from one place to another.

44.  That the confinement caused plaintiff shame, disgrace indignation and emotional harm. 

45.  That by reason of the aforesaid, the plaintiff has been damaged in the sum of TWENTY-THOUSAND ($20,000) DOLLARS.

SIXTH CAUSE OF ACTION  – THEFT OF PROPERTY

46.  Plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs marked 1 through 45 with the same force and effect as if more fully set forth herein.

47.  That on or about the 23RD of December, 2006,  at approximately  3:00 pm, while the plaintiff was lawfully and properly on the property known and WASH STATION, the defendants, their agents, servants and employees, and particularly defendants Goldasich and Nangle, without just cause or provocation and with force and violence, seized, battered and laid hold of the plaintiff, Joseph Zrnchik, and forced him into a police car by twisting his arm behind his back and forcibly confining him. 

48.  That the defendants, their agents, servants and employees, acting as agents and on behalf of defendants and within the scope of their employment, intentionally, willfully and maliciously battered plaintiff, Joseph Zrnchik, in that they had the real or apparent ability to cause imminent harmful and/or offensive bodily contact and intentionally did a violent and/or menacing act which resulted in contact with the plaintiff, and that act(s) caused apprehension of such contact in the plaintiff, and defendants, in a hostile and/or offensive manner touched the plaintiff without his consent and with the intention of causing harmful and/or offensive bodily contact to the plaintiff and caused such battery in and about his body and limbs.

49.  That by reason of the aforesaid intentional battery committed by the defendants, their agents, servants and employees, acting within the scope of their authority, and without probable or reasonable cause, the plaintiff suffered conscious pain and was otherwise damaged.

50.  That Defendant Goldasich grabbed and pushed plaintiff into a police car and confined him to that police car against plaintiff’s will and plaintiff was conscience of that [confinement, that plaintiff demanded his release, whereupon his demands were ignored and he was driven against his will to what was an undisclosed location and that the disclosure of the transport of plaintiff was not made to the police dispatcher.   

51.  That defendant Nangle grabbed plaintiff’s recording device which had been presented as a recording device to all officers and which had been in plaintiff’s possession from the time of Nangle’s arrival to the scene up until Nangle grabbed it from plaintiff approximately 20 minutes later while plaintiff was being forcibly placed in Nangle’s  police car by Goldasich.  Nangle laughed after forcibly grabbing the recording device from plaintiff with the intent to destroy audiotaped evidence of the incident  while laughing at Plaintiff and stating,  “I was worried it might be a weapon.”.  While laughing Nangle began pressing the buttons on the device to turn off the recorder and delete the recording.  

52.  That Defendant Nangle illegally exerted control over plaintiff’s recording device and took by force the property to deny plaintiff use of his property, and this taking of plaintiff’s property was unauthorized and without plaintiff’s consent and that Defendant Nangle continued to exert control over plaintiff’s recording device to deny plaintiff the use of that device for the purpose of documenting plaintiff’s actions and the actions of all Schererville police officers present at the time and place of the taking of plaintiff’s recording device. 

53.  That this taking and maintaining control of plaintiff’s recording device caused emotional distress. 

54.  That by reason of the aforesaid, the plaintiff has been damaged in the sum of TWENTY-THOUSAND ($20,000) DOLLARS.

SEVENTH CAUSE OF ACTION —-DESTRUCTION OF PROPERTY
 

55.  Plaintiff repeats, reiterates and realleges each and every allegation contained in paragraphs marked 1 through 49 with the same force and effect as if more fully set forth herein.

56.  That on or about the 23RD of December, 2006,  at approximately  3:00 pm, while the plaintiff was lawfully and properly on the property known and WASH STATION, the defendants, their agents, servants and employees, and particularly defendants Goldasich and Nangle, without just cause or provocation and with force and violence, seized, battered and laid hold of the plaintiff, Joseph Zrnchik, and forced him into a police car by twisting his arm behind his back and forcibly confining him. 

57.  That the defendants, their agents, servants and employees, acting as agents and on behalf of defendants and within the scope of their employment, intentionally, willfully and maliciously battered plaintiff, Joseph Zrnchik, in that they had the real or apparent ability to cause imminent harmful and/or offensive bodily contact and intentionally did a violent and/or menacing act which resulted in contact with the plaintiff, and that act(s) caused apprehension of such contact in the plaintiff, and defendants, in a hostile and/or offensive manner touched the plaintiff without his consent and with the intention of causing harmful and/or offensive bodily contact to the plaintiff and caused such battery in and about his body and limbs.

58.  That by reason of the aforesaid intentional battery committed by the defendants, their agents, servants and employees, acting within the scope of their authority, and without probable or reasonable cause, the plaintiff suffered conscious pain and was otherwise damaged.

59.  That Defendant Goldasich grabbed and pushed plaintiff into a police car and confined him to that police car against plaintiff’s will and plaintiff was conscience of that confinement, that plaintiff demanded his release, whereupon his demands were ignored and he was driven against his will to what was an undisclosed location and that the disclosure of the transport of plaintiff was not made to the police dispatcher.   

60.  That defendant Nangle grabbed plaintiff’s recording device which had been presented as a recording device to all officers and which had been in plaintiff’s possession from the time of Nangle’s arrival to the scene up until Nangle grabbed it from plaintiff approximately 20 minutes later while plaintiff was being forcibly placed in Nangle’s police car by Goldasich.  Nangle laughed after forcibly grabbing the recording device from plaintiff with the intent to destroy audiotaped evidence of the incident  while laughing at Plaintiff and stating,  “I was worried it might be a weapon.”.  While laughing Nangle began pressing the buttons on the device to turn off the recorder and delete the recording.  

61.  That Defendant Nangle illegally exerted control over plaintiff’s recording device and took by force the property to deny plaintiff use of his property, and this taking of plaintiff’s property was unauthorized and without plaintiff’s consent and that Defendant Nangle continued to exert control over plaintiff’s recording device to deny plaintiff the use of that device for the purpose of documenting plaintiff’s actions and the actions of all Schererville police officers present at the time and place of the taking of plaintiff’s recording device. 

62.  That this taking and maintaining control of plaintiff’s recording device caused emotional distress. 

63.  That Defendant Nangle with malicious intent and or wanton disregard destroyed

 

plaintiff’s  recording of the event that was created to protect plaintiff from police

 

misconduct and to document all of plaintiff’s actions on December 23, 2006,  and this a

 

audio-recording amounted to property, and the recording was not the defendant’s

 

property.  The defendant acted voluntarily and not by mistake or accident.  The

 

defendant acted either with the intent to injure or destroy the property or with a conscious disregard of known and substantial risks of harm that were likely to result to the property from his actions.  Furthermore, the defendant acted without mitigation.

64.  That the destruction of the recording by Defendant Nangle destroyed plaintiff’s

 

evidence and thusly seriously damaging his ability to prove his case. 

 

65.  This destruction of recorded evidence denied plaintiff the opportunity prove his

 

case thereby causing severe emotional distress.

66.  That by reason of the aforesaid, the plaintiff has been damaged in the sum of

TWENTY-THOUSAND ($20,000) DOLLARS.

 
EIGHTH CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

 

67.  Plaintiff repeats, reiterates and re-alleges each and every allegation contained in paragraphs marked 1-66  with the same force and effect as if more fully and at length set forth herein.

68.  That on or about the 23RD of December, 2006,  at approximately  3:00 pm, while the plaintiff was lawfully and properly on the property known and WASH STATION, the defendants, their agents, servants and employees, and particularly defendants Goldasich and Nangle, without just cause or provocation and with force and violence, seized, battered and laid hold of the plaintiff, Joseph Zrnchik, and forced him into a police car by twisting his arm behind his back and forcibly confining him. 

69.  That the defendants, their agents, servants and employees, acting as agents and on behalf of defendants and within the scope of their employment, intentionally, willfully and maliciously battered plaintiff, Joseph Zrnchik, in that they had the real or apparent ability to cause imminent harmful and/or offensive bodily contact and intentionally did a violent and/or menacing act which resulted in contact with the plaintiff, and that act(s) caused apprehension of such contact in the plaintiff, and defendants, in a hostile and/or offensive manner touched the plaintiff without his consent and with the intention of causing harmful and/or offensive bodily contact to the plaintiff and caused such battery in and about his body and limbs.

70.  That by reason of the aforesaid intentional battery committed by the defendants, their agents, servants and employees, acting within the scope of their authority, and without probable or reasonable cause, the plaintiff suffered conscious pain and was otherwise damaged.

71.  That defendant Nangle grabbed plaintiff’s recording device which had been presented as a recording device to all officers and which had been in plaintiff’s possession from the time of Nangle’s arrival to the scene up until Nangle grabbed it from plaintiff approximately 20 minutes later while plaintiff was being forcibly placed in Nangle’s police car by Goldasich.  Nangle laughed after forcibly grabbing the recording device from plaintiff with the intent to destroy audiotaped evidence of the incident  while laughing at Plaintiff and stating,  “I was worried it might be a weapon.”.  While laughing Nangle began pressing the buttons on the device to turn off the recorder and delete the recording.   

72.  Plaintiff suffered indignation at the hands of the Defendant Schererville Police Officers while they stuffed him into the police car, deprived him of the use of his recording device, deleted the recording thereby destroying what would have been key evidence for this cause action, all done in public on a busy thoroughfare.  Furthermore, while pressing all the buttons on the recording device, Defendant police officers laughed at and ridiculed Plaintiff while mockingly saying they needed to take his recording device, because “it might be a weapon”.

73.  This intentional infliction of emotional distress cause plaintiff shame, disgrace and indignation. 

74.    That by reason of the aforesaid, the plaintiff has been damaged in the amount of TWENTY-THOUSAND ($20,000) DOLLARS.

 

85.  That for all reasons aforesaid, the plaintiff requests the following relief:

            a)              Plaintiff requests a ONE-HUNDRED EIGHTY-THOUSAND ($180,000)

a)       Plaintiff requests a trial by jury of all issues involved in this complaint;

b)         Such other and further relief as this court may deem just and proper under the circumstances.

 

 

Dated:  ______________________    Signed____________________________

Joseph Zrnchik, Pro Se

9306 Saric Drive

Highland, IN 46322

219-588-8243

 

I, ________________________________ declare under the penalty of perjury under the laws of the State of Indiana, that I have read the above complaint and I know it is true of my own knowledge, except as to those things stated upon information and belief, and as to those I believe to be true.

 

I ___________________________________certify that on or about the _______day of  _________, 2008, service of a true and complete copy of the foregoing pleading or paper was made by depositing the same in the U.S. mail in the enveloped properly addressed with each having sufficient first-class postage affixed upon: Austgen, Kuiper & Associates P.C. 130 N Main Street, Crown Point, IN 46307  

 



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    • Joseph Zrnchik for 5th Estate Media Email: [email protected]

      I won this case and Schererville Police Department settled!

      They are the most lying and corrupt police department in Lake County, Indiana. Just a step behind the Highland Police Department who also brought false charges of Resisting Arrest, Interferring with Law Enforcement, Battery and Disorderly Conduct against me only to see their case fall apart because a lying little weasel named Officer Lee Natelborg ended up destroying himself in a deposition.

      Deputy Prosecutor Edgar Rodriguez kept up his charade of prosecution for 2 1/2 years and made a complete jackass of himself in front of Judge Villalpando’s court.

      And, the case cost me nothing as I was granted a Public Defender because the Court wanted me to have a public defender because it did not want to allow me to make Rodriguez look stupid.

      I did my own Defendant’s Answer, Motions in Limine, Witness List, Evidence List, List of Affirmative Defenses, Post Trial Motions and Jury Instructions, and my own Subpoena Duces Tecum. I caught the police in so many lies as they were on the phone and radio that I was actually looking forward to the jury trial.

      Cops are now so lazy and stupid that they can’t even lie good anymore and yet we have to pay these clowns wages.

      So now I am 3-for-3 destroying false Police State charges in Highland, Valparaiso and Schererville.

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