DISTRICT COURT OF THE UNITED STATES

WESTERN DISTRICT OF TENNESSEE

MEMPHIS DIVISION
Case:11-2175-cv-JDT-cgc

We, the People

Chachiuma Sketchi tribesman of Empire Washitaw de Dugdahmoundyah COMPLAINT FOR DAMAGES
Erique Richardson [Constitutional Violations]
Citizen of the United States of America Republic RIGHTS VIOLATIONS

Petitioner

vs.

POLICE OFFICER T. JONES

201 Poplar Ave.
Memphis, TN 38128
vs.
POLICE OFFICER C. TURNER
201 Poplar Ave.
Memphis, TN 38128
vs.
POLICE OFFICER D. MANNING
201 Poplar Ave.
Memphis, TN 38128
vs.
DEPUTY SGT. A. L. WOODY
201 Poplar Ave.
Memphis, TN 38103
vs.
DEPUTY EWTON
201 Poplar Ave.
Memphis, TN 38103
vs.
DEPUTY ABDULLAH
201 Poplar Ave.
Memphis, TN 38103
vs.
MAYOR
A.C.WHARTON JR.

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125 N. Main St.#200
Memphis, TN 38103
vs.
MEMPHIS CITY COUNCIL
125 N. Main St. suite 514
Memphis, TN 38103
vs.
CHIEF OF POLICE
LARRY GODWIN
201 Poplar Ave.
Memphis, TN 38103
vs.
MAYOR
MARK LUTRELL
160 N. Main St. suite 450
Memphis, TN 38103
vs.
SHELBY COUNTY SHERIFF
BILL OLDHAM
201 Poplar Ave.
Memphis, TN 38103
vs.
GOVERNOR
PHIL BREDESEN
600 CHARLOTTE Ave.
Nashville, TN 37243
Defendants

COMES NOW; sikanu-bey-el:, a.k.a erique-jermaine-richardson-of the Chachiuma Sketchi Tribe of the
Empire Washitaw de Dugdahmoundyah Citizen of the [De Jure] United States, National of the United
States of America , Free Amuurindian, Natural Born Citizen, real hueman, true hueman, Tail estate of the
donor body, that has endured the regular order and course of inheritance being the absolute fee simple,
beneficiary of the express ‘Trust“ Constitution of the United States, posterity, known as We, the People
hereby complains of the actions of the defendants MEMPHIS POLICE DEPARTMENT LARRY
GODWIN in his official capacity , CITY OF MEMPHIS MAYOR A.C. WHARTON JR. in his official
capacity, SHELBY COUNTY SHERIFF DEPARTMENT BILL OLDHAM in his official capacity,
SHELBY COUNTY MAYOR MARK LUTTRELL in his official capacity, STATE OF TENNESSEE
PHIL BREDESEN in his official capacity, officer T. Jones ,officer Manning, officer C. Tuner, Sgt.
deputy A.L. Woody, deputy Ewton ,deputy Abdullah in there individual capacities, bond insurance
holding company follows:

Jurisdiction
Jurisdiction herein is invoked inter alia, 28 USC 1331,1333,1251,1253, Constitution of the United States
Article III, and 42 USC 1983,1985.

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 CAUSE OF ACTION

1. This is an action under 42 USC 1983,1985 for the Deprivation of petitioner privileges & immunities
afforded from Article 4, sec. 2 Constitution of the United States. Assault and Delayed Medical
Treatment for 11 days while illegally detained for 19 days. Plaintiff also claims relief from within
TCA 39-17-309; 40-7-103; 39-17-308; 39-12-101; 39-13-302; 71-6-117; and on LARRY GODWIN,
A.C. WHARTON J.R., BILL OLDHAM, MARK LUTTRELL, PHIL BREDESEN official bonds.

2. LARRY GODWIN, A.C. WHARTON J.R., BILL OLDHAM, MARK LUTTRELL, PHIL
BREDESEN are all residents of Shelby County, and/ or Memphis, TN. Each are being sued
separately in their official capacities.

3. LARRY GODWIN was responsible for supervising the training, instruction, discipline, and conduct
of officer T. Jones ,officer Manning, officer C. Tuner including, but not limited to, training,
instruction, discipline, control and conduct concerning jurisdiction, Constitution of the United States
procedures and Constitution of Tennessee provisions for arrest, breach of peace, civil rights
infringement. All which includes but limited to unreasonable search and seizure.

4. BILL OLDHAM was responsible for supervising the training, instruction, discipline, and conduct of
Sgt. A.L. Woody, Deputy Ewton and Deputy Abdullah including, but not limited to, training,
instruction, discipline, control and conduct concerning jurisdiction, Constitution of the United States
procedures and Constitution of Tennessee provisions for arrest, breach of peace, civil rights
infringement. All which includes but not limited to (1) violations of petitioners’ right of protection
under First, Fourth, Fifth and Eighth Amendment rights to be free from an unreasonable arrest and
excessive force; (2) state law assault; (3) state law battery; (4) state law false arrest; (5) freedom of
speech and (6) due process of law.

5. A.C.WHARTON Jr. and MEMPHIS CITY COUNCIL was responsible for instituting policy for the
Memphis Police Department, which includes, but not limited to, setting policy guidelines for training
for police officers in arrest procedures violating Constitution of the United States procedures and
Constitution of Tennessee provisions for arrest, breach of peace, civil rights infringement. All which
includes but not limited to unreasonable search and seizure.

6. MARK LUTTRELL was responsible for instituting policy for the Shelby County Sheriff department,
which includes, but not limited to, setting policy guidelines for training officers in proper arrest
procedures without violating Constitution of the United States procedures and Constitution of

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 Tennessee provisions for arrest, breach of peace, civil rights infringement. All which includes but not
limited to (1) violations of petitioners’ right of protection under First, Fourth, Fifth and Eighth
Amendment rights to be free from an unreasonable arrest and excessive force; (2) state law assault;
(3) state law battery; (4) state law false arrest; (5) freedom of speech and (6) due process of law.

7. The established policy has created a custom to infringe upon any person or Citizen who is exercising
freedom of speech and/or demands due process of law rights guaranteed by Constitution of the
United States procedures and Constitution of Tennessee .A.C.WHARTON Jr. and MARK
LUTTRELL is responsible for the established climate and custom that allows officers and deputies to
use of deliberate unreasonable force because a man is exercising freedom of speech and other rights
granted by Constitution of the United States privilege, in connection with the Constitution of
Tennessee.
8. CITY OF MEMPHIS and SHELBY COUNTY are political subdivisions of the State of Tennessee.

9. Under TCA 39-17-309; 40-7-103; 39-17-308; 39-12-101; 39-13-302; 71-6-117; at all times pertinent,
was responsible for providing maintaining advocacy of unlawful acts by groups or individuals against
other person or groups in this case the Chief of Police and the Shelby County Sheriff, directly or
indirectly allowed, authorized the provoking and inciting damage creating bodily injury to me-
petitioner, which action is not constitutionally protected, poses a threat to public order and safety, and
should be subject to sanctions. Also deliberate, willful intention of Sgt. A.L. Woody, Deputy Ewton
and Deputy Abdullah by unnecessary force that was and is unreasonable that amounted to
head/bodily injury and assault on me- petitioner.

10. CITY OF MEMPHIS, MEMPHIS CITY COUNCIL and SHELBY COUNTY has final policy
making authority regarding the provisions on medical care, civil rights intimidation, false
imprisonment inter alia.
11. Defendant LARRY GODWIN is a resident of Shelby County/City of Memphis, TN. At all times
LARRY GODWIN is was duly elected and acting chief of the police of City of Memphis.

12. Defendant BILL OLDHAM is a resident of Shelby County/Memphis, TN. At All Times BILL
OLDHAM was duly elected and acting Sheriff of Shelby County ,TN.

13. City of Memphis has allowed Chief of Police LARRY GODWIN to perform the city policing duties.
Train officers, set policy, which has established certain customs that violate the Constitution of
Tennessee and Constitution of the United States provisions for arrest, breach of peace, civil rights
infringement. All which includes but not limited to (1) violations of petitioners’ right of protection
under First, Fourth, Fifth and Eighth Amendment rights to be free from an unreasonable arrest and
excessive force; (2) state law assault; (3) state law battery; (4) state law false arrest; (5) freedom of

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 speech and (6) due process of law violating TCA 39-17-309; 40-7-103; 39-13-302; and 39-12-103
inter alia
14. Shelby County has allowed Sheriff of Shelby County BILL OLDHAM to perform the County
policing duties. Train officers, set policy, which has established certain customs that violate the
Constitution of Tennessee and Constitution of the United States provisions responsible for the
established climate and custom that allows officers and deputies to use deliberate unreasonable force
because a man is exercising freedom of speech and other rights granted by Constitution of the United
States privilege, in connection with the Constitution of Tennessee. for arrest, breach of peace, civil
rights infringement. All which includes but not limited to (1) violations of petitioners’ right of
protection under First, Fourth, Fifth and Eighth Amendment rights to be free from an unreasonable
arrest and excessive force; (2) state law assault; (3) state law battery; (4) state law false arrest; (5)
freedom of speech and (6) due process of law violating TCA 39-17-309; 40-7-103; 39-13-302; and
39-12-103 inter alia.
15. At all times pertinent, officer T. Jones ,officer D. Manning, officer C. Tuner of the Memphis Police
Department and Sgt. deputy A.L. Woody, deputy Ewton ,deputy Abdullah of the Shelby County
Sheriff Department conspired as a group, had a meeting of minds, possessing the power to release, let
go or stop the established train of abuse committed unto me. They carry this authority to make sure
all of the orders, rules, instructions, policies, regulations promulgated are with the meaning of TCA
39-17-309 inter alia. They failed to stop the action that caused this suit of complaint, thus, verifying
and perpetuating the violations listed and to be discussed or lay out.

VENUE
16. CITY OF MEMEPHIS is being sued in its capacity as an employer and principal of officer T. Jones
,officer Manning, officer C. Tuner.

17. SHELBY COUNTY is being sued in its capacity as an employer and principal of Sgt. deputy A.L.
Woody, deputy Ewton ,deputy Abdullah .

18. STATE OF TENNESSEE is being sued in its capacity as a person. PHIL BREDESEN is responsible
for the policy of the State of Tennessee as the CEO or Manager, Governor who is directly or
indirectly involved due to the fact the violations complained of are unreasonable where as Governor,
Setting adequate policy and training where a climate of a custom has been established within the City
of Memphis ,Shelby County, Memphis police department, Shelby County Sheriff department that
lack training in proper procedure without violating the Constitution of the United States provisions
responsible for the established climate and custom that allows officers and deputies to use deliberate
unreasonable force because a man is exercising freedom of speech and other rights granted by
Constitution of the United States privilege, in connection with the Constitution of Tennessee. for
arrest, breach of peace, civil rights infringement. All which includes but limited to (1) violations of

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 petitioners’ right of protection under First, Fourth, Fifth and Eighth Amendment rights to be free
from an unreasonable arrest and excessive force; (2) state law assault; (3) state law battery; (4) state
law false arrest; (5) freedom of speech and (6) due process of law violating TCA 39-17-309; 40-7-
103; 39-13-302; and 39-12-103 inter alia,and lack of supervising in jurisdictional actions Citizens of
Chachiuma Sketchi Tribe of Empire Washitaw de Dugdahmoundyah American Indian origin who are
recognized by the United Nations with verification identification number 215.

CLAIM FOR RELIEF

19. I :sikanu-bey-el:, a.k.a erique-jermaine-richardson-of the Chachiuma Sketchi Tribe of the Empire
Washitaw de Dugdahmoundyah Citizen of the [De Jure] United States herein incorporates as
reference as if fully set forth herein the allegations of sections 1-18

20. CITY OF MEMPHIS is a person within the meaning of 42 USC 1983,1985.

21. SHELBY COUNTY is a person within the meaning of 42 USC 1983,1985.

22. CITY OF MEMPHIS is not entitled to 11th amendment sovereign immunity because it is local in
nature.

23. SHELBY COUNTY is not entitled to 11th amendment sovereign immunity because it is local in
nature.

24. STATE OF TENNESSEE is not entitled to sovereign immunity because of the purchase of insurance
in bond or otherwise.

25. Constitution of the United States Provides citizens, including petitioner with a civil right and
privilege, to be free to exercise those mentioned by freedom of speech, unreasonable search and
seizure, assaults and deprivation under color of law etc.

26. It also provides for while in government custody and imposes an affirmative duty that citizens,
including petitioner be provided with safe facilities while in custody also the free right to exercise the
freedom of speech, the right to bear arms without interfering in there duties which petitioner did.

27. CITY OF MEMPHIS and SHELBY COUNTY has delegated its statutory responsibility for, and final
policy making authority regarding, the assault on citizens, violating the constitutional provision of
safe medical to persons confined within a government facility held with out charges for 19 days while
being refused treatment for the first 13 days, to A.C.WHARTON Jr., MARK LUTRELL by allowing

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 A.C.WHARTON Jr, MARK LUTTRELL. to perform this function of city and county operation
without interference of correction.

28. A.C. WHARTON and MARK LUTTRELL has delegated final policy making authority regarding the
provision of medical care, safe arrest techniques, and jurisdictional action, by allowing LARRY
GODWIN and BILL OLDHAM to perform aspects of this function without interference of
correction.
29. The policy making decisions of Chief of Police-LARRY GODWIN, Shelby County Sheriff-BILL
OLDHAM, Governor PHIL BREDESEN with regard to the provision of medical care, safe facilities
while being in custody, arrest of Citizens who are not within the jurisdictional bounds of CITY OF
MEMPHIS or SHELBY COUNTY are imputed to Chief of Police-LARRY GODWIN, Shelby
County Sheriff-BILL OLDHAM.

30. The policy making decisions mentioned of Chief of Police-LARRY GODWIN, Shelby County
Sheriff-BILL OLDHAM including those imputed to LARRY GODWIN by the Memphis Police
Department are imputed to the CITY OF MEMPHIS and BILL OLDHAM by Shelby County Sheriff
Department are imputed to the COUNTY OF SHELBY by STATE OF TENNESSEE[ indirectly] by
Governor PHIL BREDESEN are imputed and serve to bind all three, STATE OF TENNESSEE,
SHELBY COUNTY -SHERIFF DEPARTMENT and CITY OF MEMPHIS-POLICE
DEPARTMENT directly or indirectly.

31. It is the official policy of SHELBY COUNTY and SHELBY COUNTY SHERIFF
DEPARTMENT,CITY OF MEMPHIS ,MEMPHIS CITY COUNCIL and MEMPHIS POLICE
DEPARTMENT to arrest Citizen for exercise any rights of privileges secured by the Constitution of
the United States of America or any other unalienable rights thereof.

32. In the alternative, the manner in which SHELBY COUNTY and SHELBY COUNTY SHERIFF
DEPARTMENT,CITY OF MEMPHIS , MEMPHIS CITY COUNCIL and MEMPHIS POLICE
DEPARTMENT Mayor, Lieutenants, Major’s, and officers are trained, including the design and
implementation of training programs and follow-up supervision of trainees, is a matter of policy.

33. These action committed has become widespread to recognize the quality of custom or usage. The
official duty of final policy makers of CITY OF MEMPHIS AND SHELBY COUNTY inter alia, to
be informed of custom or usage and, such policy makers had manifest opportunities to become
informed.

34. The actual or constructive knowledge of the existence of this custom or usage and intentionally or
with deliberate indifference, failed to correct or stop the practices and thus condoned it. This

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 condonement may fairly be attributed in part to CITY OF MEMPHIS and SHELBY COUNTY, and
part to MEMPHIS POLICE DEPARTMENT and SHELBY COUNTY SHERIFF DEPARTMENT.

35. The actions committed deprived petitioner of his Constitutional Privilege and Immunities to adequate
safe facilities while in custody legally or illegally, assault, battery ,unreasonable search and seizure
and directly or in directly violating II Amendment was in furtherance of an official policy, custom or
usage of CITY OF MEMPHIS and SHELBY COUNTY, MEMPHIS POLICE DEPARTMENT and
SHELBY COUNTY SHERIFF DEPARTMENT and such official policy , custom or usage, was a
direct and proximate cause of such deprivation.

36. PHIL BREDESEN is not entitled to qualified, sovereign immunity because of the purchase of “Bond
Insurance”.

37. LARRY GODWIN in his official capacity is a person within the meaning of 42 USC 1983.

38. BILL OLDHAM in his official capacity is a person within the meaning of 42 USC 1983.

39. Such conduct poses a pervasive and unreasonable risk of Constitutional violations and injury-such is
the violation here; to petitioner. LARRY GODWIN and BILL OLDHAM had actual and constructive
knowledge given to them by officers directly or indirectly. Having a meeting of minds officer
T. Jones ,officer Manning, officer C. Tuner, Sgt. deputy A.L. Woody, deputy Ewton ,deputy
Abdullah all decided to engage in conduct that posed pervasive and unreasonable risk of
Constitutional violations and injury to petitioner.

40. The deliberate indifference to or tacit authorization of, such unconstitutional conduct shows the
response of actual or constructive knowledge of this pervasive and unreasonable risk of
Constitutional violations and injury to petitioner.

41. A reasonable person in the position of defendants would have known that his or her actions violated
petitioners Article 4, section 2 Constitutional Privileges and Immunities along with certain state
statutory provisions.

42. LARRYGODWIN is liable under the law of Tennessee for such actions of officer T. Jones, officer C.
Turner, officer D. Manning based on the doctrine of respondent superior

43. BILL OLDHAM is liable under the law of Tennessee for such actions of Sgt. deputy A.L. Woody,
deputy Ewton ,deputy Abdullah based on the doctrine of respondent superior

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44. Treble damages are entitled to be given to petitioner for such wrong or injury pursuant to Tennessee
law.
45. Petitioner is asking for and immediate judicial estoppel on case related to this complaint indictment
number 10 07107 pending the out come of this complaint.

46. Defendants conduct was willful or wanton in that it constituted the conscious and intentional
disregard of, and indifference to, the privileges and immunities also rights. Of petitioner, which said
defendants knew or should have known was reasonably likely to result in injury, damage or other
harm.

FACTS

47. On or about June 23, 2010 I was traveling in my private road machine down signal street in
Memphis, TN.

48. As I turn the corner I witnessed officers stand in the street with speeding radars

49. When I came pass abiding by the limit of speed I heard an officer shout window tint.

50. Officers urge me to pull over and stop and I did without any knowledge of breaking any laws.

51. Officer T. Jones , officer D. Manning ,officer C. Turner approached the window I handed officer
Jones my qualification to drive card he immediately told me to step out the car I ask the officer T.
Jones why did I need to step out my road machine he just told me to exit my private road machine
now.

52. When I stepped out officer T. Jones searched my body and felt my pistol on my right hip officers
immediately slammed me to the car and stated that if I move I will be shot.

53. Officer T. Jones put in his police vehicle I ask the officer what was the problem he didn’t respond but
only keep filling out paper work.

54. After three hours the officer T. Jones took me to the Shelby county jail and filed and affidavit of
complaint against me charging me with Tinted Windows TCA 55-9-107 and Unlawful weapons
possession TCA 39-17-1307.

55. Law enforcement waiver of immunity was sent to the police officer to sign form and waive there

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 immunity to testify to the incident that occurred on June 23, 2010. “see attached”

56. Officer where to return the waive to the clerk before testifying August 27,2010 officer did not return
waive or engage in the court proceeding in any form.

57. Officers where deemed unreliable witness because they didn’t respond or sign and return the waive of
immunity form to waive there immunity to testify.

58. On or about August 27, 2010 entered into 201 POPLAR AVENUE courthouse to deliver
constructive notice certified mail number# EH912996786US as to the previously stated offense that I
was charged with violating to JUDGE Louis J. Montesi Jr. through process of service by hand
delivery after previous failed attempts.

59. When witnesses and I arrived and entered court room immediately Shelby County Sherriff deputy
Burriage gave me a roll sheet to sign, after signature she took Division 13 court roll sheet to co-
worker deputy Ewton, showing my signature to him. They both briefly laughed and approached me
and other citizens forcing us to leave courtroom. After explaining that we have a right to be in that
specific court room also consistently informing deputies that they are violating the Tennessee
Constitution that states “the courts shall be open to all public”, deputies still refused to allow my
witnesses back into court room;

60. The judge then called an unusually early recess. I previously informed deputy Ewton and Burriage
that all people on the scene where of Chachiuma Sketchi tribe of the Empire Washitaw De
dugdahmounyah Indigenous Nation 215 , also Tennessee Citizens of the Republic with full
declarations on record and demanded that he contact his superior.

61. . Superiors did arrive (Sgt. Gray etc…), but approved actions and illegal detainment by stating “we
don’t give a fuck about any constitutions”.

62. After about fifteen minutes, Deputy Ewton called for all people who have cases in Division 13 and
shouted, “No witnesses or spectator will be allowed in the courtroom, only if you have a case will
you be allowed to enter”. I entered Division 13 alone without witnesses, whom arrived with met, and
took a seat on left side of courtroom.

63. Sheriff deputy Ewton announced “turn off cell phone, do not put them on vibrate or we will take
them”.

64. I reached in his pocket to check my cell phone immediately Ewton singled me out shouting in a

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 raging voice “Son! Son! Your mama calls you son doesn’t it”, laughing looking around at other co-
workers as I calmly stayed seated.

65. I did not acknowledge anything that was stated by the deputy driving the deputy in even more of a
rage as he began to approach me.

66. Deputy Ewton then grabbed me with both hands snatching me from my seat.

67. Sgt. A. L. Woody and Abdullah joining in ramming my head and body into wooden court furniture
and then into inmate holding cell door, splitting the right side of my head, assaulting me in rage.

68. During assault, I constantly warned deputies that I was not a 14th Amendment Citizen and had not
violated any laws, and continued warning that no probable cause existed for the deputies’ actions.

69. At all times I reminded deputies of my lawful status as a Chachiuma Sketchi tribesman of the Empire
Washitaw De dugdahmoundyah Citizen and Tennessee citizen of the Republic, constitutional
standing, international human rights and treaty protections, ignored at all times by Sheriff deputies
illegally kidnapping and assaulting me.

70. During the assault, people in the courtroom ran out traumatized by the conduct of the Sheriff
Deputies.

71. The other Washitaw citizens and my family immediately began attempting to get inside of courtroom
to witness me being assaulted by deputies.

72. Other deputies attempted to block the doors saying, “I have been detained and will not be heard in
court that day 8-27-2010”.

73. Deputies advised my hired court reporter, friends and family to leave the court area and where
shadowed by other deputies as they left the building.

74. Approximately 30 to 45 minutes later, deputies forcibly bought me before judge Louis J. Montesi Jr.
after being illegally detained in recess by deputies.

75. I stated on the court record. “ I now challenge jurisdiction under Hagens v. Lavine, Standard v.
Olsen, Smith v. McCollough; United Nations Rights of Indigenous people Article 5 also for the
record that division 13 was in accompanying violation of title 18 U.S.C. section 241 Screws V.
US illegal kidnapping of my body” .

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76. Sgt. A.L. Woody Sr. brutally drags me out of the courtroom.

77. Throwing me into the wall of the holding cell threatening to”Fuck me up if I didn’t shut the fuck up”
as he stated in anger.

78. This is the third time Iwas tossed into a cell during the course of one hour.

79. I was forced to Shelby County Jail in Shelby county for (19) days, held without charges against my
free will.

80.  was held for (19 days) exactly four hundred-sixty six hours), and was refused access to a
Magistrate, and Delayed medical attention up until the thirteenth day of illegal detention Sherriff
deputies acted outside the scope of their discretionary authority, which stand as evidenced in the
conspired Affidavit of Complaint, which reflects Affiant’s constant declaration of not being a U.S.
Citizen. Affiant repeatedly stated that he was here on special appearance in propria persona sui
juris also giving deputis notice of constitutional and international law violations. Therefore, it
appears as though their actions were in violation of their Constitutional Oaths and Affiant’s Human,
Civil and Property rights.

81. While having no official complaint, charges, warrant, nor indictment, Sheriff deputies and Memphis
police officers violated 1st, 4th , 5th, and 8th Amendment protections, and this including police officer
T. Jones , officer D. Manning ,officer C. Turner ;and deputy Sgt. A.L. Woody, Deputy Ewton and
Deputy Abdullah who is also responsible for assaulting and illegally detaining me

82. Deputy Sgt. Woody, Deputy Ewton, and Deputy Abdullah injured my head, neck, and back which
were not examined because I was illegally detained and was refused medical attention for 13 days.

83. Deputy Sgt. A.L. Woody, Deputy Ewton, and Deputy Abdullah conduct violated the "clear and
obvious principle that once an arrest has been fully secured and any potential danger or risk of flight
vitiated," a Sherriff deputy cannot employ "severe and unnecessary force." Lee, 284 F.3d at 1200.
Where a principle is "clear and obvious,"

84. Deputy Sgt. Woody, Deputy Ewton and Deputy Abdullah cannot argue that they had no warning that
their conduct was verboten,

85. While I was subdued and assaulted; I had not been formally charged but was vigorously thrown in a
holding cell, cuffed in holding cell incapable of going anywhere,

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86. At all times demonstrated no level of urgency and necessity to have excessive force used upon me
before subduing or even after subduing me for allegedly “not getting up and leaving the court room”
which actually belongs to me according with Tennessee Constitution, Davis vs. Mississippi along
with various other laws;

87. The assault against me exercising my rights as Chachiuma Sketchi Indigenous Washitaw American
Indian clearly is a personal action, a colorable action in violation of constitutional protections and
rights.
88. In order to determine whether the amount of force used by a Police officer, Sherriff deputies was
proper, a determination must be made asking 'whether a reasonable deputy would believe that this
level of force to get me to allegedly “get up and leave court room” as stated by Deputy Ewton was
necessary in the situation at hand. Lee, 284 F.3d at 1197 (quoting Willingham v. Loughnan, 261 F.3d
1178, 1186 (11th Cir. 2001)).

89. The Eleventh Circuit has explained and the Supreme Court has established that, in order to balance
the necessity of using some force attendant to an arrest against the arrestee's constitutional rights,
evaluation of a number of factors must be considered, including the severity of the crime at issue,
whether the suspect poses an immediate threat to the safety of the officers or others, and whether
he/she is actively resisting arrest or attempting to evade arrest by flight. Lee, 284 F.3d at 1198 (citing
Graham v. Connor, 490 U.S. 386, 394-95, 104 L. Ed. 2d 443, 109 S. Ct. 1865 (1989) and Leslie v.
Ingram, 786 F.2d 1533, 1536 (11th Cir. 1986)).

90.  was held for (19 days exactly four hundred-sixty six hours), and was refused access to a Magistrate,
and Delayed medical attention up until the thirteenth day after illegal detention .( See attached)

91. I demanded to speak with a Magistrate and continued to ask to see the Complaint, or the Charging
Instrument not provided to him.

92. The actions against me were illegal and unwarranted, and it was unlawful for deputies to damage my
body, which has been creating great mental stress and duress from the recurring pain during illegal
detention of me.

93. Probable cause exists where an arrest is objectively reasonable based on the totality of the
circumstances. Rankin v. Evans, 133 F.3d 1425, 1435 (11th Cir. 1998). This standard is met when the
facts and circumstances presented to a deputy "would cause a prudent person to believe, under the
circumstances shown, that the suspect has committed, is committing, or is about to commit an
offense." Id. (quoting Williamson v. Mills, 65 F.3d 155, 158 (11th Cir. 1995).

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I herein incorporate the above 1-93 as reference to be incorporated herein

WHEREFORE;

1 Petitioner requests to have and recover of defendants compensatory damages in an amount to be determined at
trial;

2 That compensatory damages from LARRY GODWIN, BILL OLDHAM, PHIL BREDESEN, CITY OF
MEMPHIS, MEMPHIS CITY COUNCIL , SHELBY COUNTY, MEMPHIS POLICE
DEPARTMENT,SHELBY COUNTY SHERIFF DEPARTMENT, STATE OF TENNESSEE, Officers T.
Jones, D. Manning, C. Turner, Deputy Sgt. A.L. Woody, Deputy Ewton, and Deputy Abdullah , on
petitioner’s statutory claims of TC 39-17-309(d)(e); 40-7-103;39-17-308; 39-12-101; 39-12-103; 39-13-302; 71-6-
117; 39-16-401 (2)(F); along with Article 4, section 2 Constitution of the United States, and Constitution of
Tennessee. Also, 42 USC 1983; 1985.

This ______ day of __________________________________ 2011.

______________________________________________________________
Erique Jermaine Richardson

JURAT
BEFORE me affirmed this day of ___ of ______________________________ 2011 appeared

_________________________________________________, proving to be the petitioner in this matter

and has subscribed her signature this day.

STATE_______________________________]
]
COUNTY_____________________________]

______________________________________
NOTARY

My commission expires: SEAL

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