justin cosma

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI

DB, minor child, ) by and through his next friend, ) Tami Bennett, )

) Plaintiff, ) )

vs. ) Case No. Pending ) JURY TRIAL DEMANDED JEFFERSON COUNTY SHERIFFS ) DEPARTMENT ) Serve: Oliver Glenn Boyer )

Sheriff ) 510 1st St ) Hillsboro, MO 63050 ) )

SHERIFF OLIVER GLENN BOYER ) Serve: Oliver Glenn Boyer )

Sheriff ) 510 1st St ) Hillsboro, MO 63050 )

) and )

) DEPUTY JUSTIN COSMA, Individual ) Serve: Place of Employment )

Jefferson County Sheriffs ) Department ) 510 1st St ) Hillsboro, MO 63050 ) )

and ) ) DEPUTY RICHARD CARTER, Individual ) Serve: Place of Employment )

Jefferson County Sheriffs ) Department ) 510 1st St ) Hillsboro, MO 63050 )

) Defendants. )

Case: 4:12-cv-01710-NAB Doc. #: 1 Filed: 09/21/12 Page: 1 of 8 PageID #: 1

COMPLAINT

COMES NOW Plaintiff, DB, by and through his Next Friend Tami Bennett and

by and through counsel, Richard Lozano, and for his causes of action states that:

FACTS

1. On June 25, 2010, 12 year old minor child DB was checking his mail at the end of

his driveway when he was approached by Jefferson County deputies Justin Cosma

and Richard Carter.

2. The deputies asked DB if he had been playing on the highway adjacent to his

driveway, to which DB replied no.

3. The deputies became confrontational, frightening and intimidated minor child DB.

4. Unprovoked and without cause, the deputies grabbed DB, choked him around the

neck and threw him to the ground.

5. DB was shirtless and suffered bruising, choke marks, scrapes and cuts across his

body.

6. Said deputies hog tied DB.

7. At no time was a parent or other adult present during the initial questioning or

arrest.

8. DB was transported to a medical facility for medical treatment.

9. The deputies reported the incident as assault of a law enforcement officer third

degree and resisting/interfering with arrest, detention or stop, but Jefferson

County refused to issue a juvenile case against DB.

10. DB presented no danger to the deputies or himself.

11. DB was at the time a young, small child who was simply checking the mail on his


property as instructed by his mother, was not engaged in suspicious activity and

was assaulted by the deputies without provocation.

12. The show of force initiated by the deputies caused an unreasonable injury to DB.

13. On or about June 25, 2010, the Jefferson County deputies Justin Cosma and

Richard Carter were on duty at all times relevant to this complaint and were duly

appointed sheriff deputies of Jefferson County.

14. The Jefferson County deputies Justin Cosma and Richard Carter engaged in the

conduct complained of, on said date, in the course and scope of their employment

and while on duty.

JURISDICTION AND VENUE

15. The jurisdiction of the court is invoked pursuant to the Civil Rights Act, 42 USC

1983; the Judicial Code, 28 USC 1331 and 1343 (a); The Constitution of the

United States; and this Courts supplementary jurisdiction powers.

16. This Court has jurisdiction pursuant to 28 U.S.C. 1343 and 28 U.S.C. 1331.

Plaintiffs claims for relief are cognizable under 42 U.S.C. 1983 and 1988, and

under Missouri state law. Plaintiff invokes the supplemental jurisdiction of the

Court to hear and decide their claims arising under Missouri state law.

17. Venue is appropriate in this Court pursuant to 28 U.S.C. 1391(b) because the

Defendants are located, and all incidents giving rise to this suit occurred, in this

judicial district.

PARTIES

18. Plaintiff is a resident of the State of Missouri and of the United States.

19. Oliver Glenn Boyer is the sheriff of Jefferson County and is sued in his official


capacity.

20. The Defendant Sheriff Deputies were at all times relevant hereto employed by and

acting on behalf of the Jefferson County Sheriffs Department and are sued in

their official and individual capacities.

21. Defendant Jefferson County Sheriffs Department, Jefferson County, Missouri is

in the Eastern District of Missouri. The Department acted by and through its

policymakers, agents, and employees and acted under color of law in all respects

set forth herein.

22. Defendant Justin Cosma is a sheriff deputy employed by Jefferson County who

acted under color of law. Defendant Justin Cosma is sued in his individual and

official capacity.

23. Defendant Richard Carter is a sheriff deputy employed by Jefferson County who

acted under color of law. Defendant Richard Carter is sued in his individual and

official capacity.

CAUSES OF ACTION

COUNT I

EXCESSIVE USE OF FORCE AGAINST DB BY DEFENDANTS COSMA AND

CARTER IN VIOLATION OF THE FOURTH AND FOURTEENTH AMENDMENTS

TO THE UNITED STATES CONSTITUTION; 42 U.S.C. 1983

24. Plaintiff incorporates by this reference the allegations in paragraphs 1 through 23

as though fully set forth herein.

25. The physical force used by Deputy Justin Cosma against Plaintiff was

unreasonable and excessive.


26. The acts of Defendants Justin Cosma and Richard Carter of detaining, choking,

shoving down and causing choke marks, bruising, scraps and cuts across the

body of DB were committed without just cause or provocation.

27. DB was a young child and unable to protect himself.

28. Defendants caused the violations of Plaintiffs constitutional rights by their acts,

direct and indirect, and by their omissions. Defendants are jointly and severally

liable for Plaintiffs damages.

29. As a direct and proximate result of the acts and omissions of Defendants, Plaintiff

suffered injury and damages.

30. The acts, conduct, omissions, and failures to act by Defendants showed reckless

and/or callous disregard to Plaintiffs constitutional rights. Their conduct warrants

an award of punitive damages to punish them and to deter them and others from

acting in a like manner in the future.

31. If Plaintiff prevails, he is entitled to an award of attorneys fees pursuant to 42

U.S.C. 1983 and 42 U.S.C. 1988.

WHEREFORE, Plaintiff prays judgment against Defendants, jointly and severally,

for compensatory damages, for punitive damages and for attorneys fees and the costs of

litigation, and for other relief as is appropriate under the law.

COUNT II

PLAINTIFFS CAUSE OF ACTION AGAINST THE JEFFERSON COUNTY

SHERIFF DEPARTMENT AND BOYER IN VIOLATION OF THE FOURTH AND

FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION 42

U.S.C. 1983




33. Failure to Train Holding Cell Tactics. Further, the Jefferson County Sheriffs

Department, Jefferson County, Missouri has failed to effectively train, supervise,

discipline, and control the people it employs as police officers regarding

appropriate questioning and detention of minor children.

34. Unconstitutional Custom and Practice Use of Force. Further, it was the policy

and custom of the Jefferson County Sheriffs Department to inadequately and

improperly investigate citizen complaints of inappropriate and excessive police

use of force against citizens, and acts of excessive use of force were tolerated by

Jefferson County.

35. Failure to Train Use of Force. Further, the Jefferson County Sheriffs


discipline, and control the people it employs as police officers regarding the

appropriate use of force against citizens.

36. Failure to Train Citizen Detention. Further, the Jefferson County Sheriffs


discipline, and control the people it employs as police officers regarding the

appropriate detention, holding, or confinement of citizens.

37. Failure to Discipline Defendants Cosma and Carter were not disciplined for

their use of excessive force against DB.

38. Therefore, the Jefferson County Sheriffs Department and Sheriff Oliver Glenn

Boyers policies and customs and failures to effectively train supervise, discipline,


and control the people it employs as police officers led to the deprivation of DBs

constitutional rights.

39. If Plaintiff prevails, he is entitled to an award of attorneys fees pursuant to 42

U.S.C. 1983 and 42 U.S.C. 1988.

WHEREFORE, Plaintiff prays judgment against Defendant Jefferson County,

Missouri and Sheriff Oliver Glenn Boyer for compensatory damages and for attorneys

fees and the costs of litigation, and for other relief as is appropriate under the law.

COUNT III

ASSAULT AND BATTERY OF DB

BY DEFENDANTS JUSTIN COSMA AND RICHARD CARTER UNDER STATE

LAW



41. The act of Defendants Cosma and Carter as afore described, was committed

without just cause or provocation, and with the intent to cause DB offensive

contact, bodily harm, apprehension of offensive contact, and apprehension of

bodily harm, constitute an intentional assault and battery against DB.

42. As a direct and proximate result of the acts of Defendants Cosma and Carter, as

afore described, DB suffered damages.

43. The acts, conduct, omissions, and failures to act by Defendants showed reckless

and/or callous disregard to DB. His conduct warrants an award of punitive

damages to punish him and to deter him and others from acting in a like manner

in the future.


WHEREFORE, Plaintiff prays judgment against Defendant Justin Cosma and

Richard Carter jointly and severally for compensatory damages, for punitive damages and

the costs of litigation, and for other relief as is appropriate under the law.

Respectfully submitted, By: /s/ Richard R. Lozano #44492MO 231 S. Bemiston, Ste. 800 Clayton, Missouri 63040 (314) 650-5217 (866) 401-7772 fax [email protected]


JS 44 (Rev. 09/11) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as providedby local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiatingthe civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff)(For Diversity Cases Only) and One Box for Defendant)

1 U.S. Government 3 Federal Question PTF DEF PTF DEFPlaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6 Foreign Country

IV. NATURE OF SUIT (Place an X in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act 120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionment 130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust 140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking 150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 460 Deportation 151 Medicare Act 330 Federal Employers Product Liability 830 Patent 470 Racketeer Influenced and 152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizations

Student Loans 340 Marine Injury Product 480 Consumer Credit (Excl. Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV

153 Recovery of Overpayment Liability PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commodities/ of Veterans Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange

160 Stockholders Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 890 Other Statutory Actions 190 Other Contract Product Liability 380 Other Personal 740 Railway Labor Act 864 SSID Title XVI 891 Agricultural Acts 195 Contract Product Liability 360 Other Personal Property Damage 751 Family and Medical 865 RSI (405(g)) 893 Environmental Matters 196 Franchise Injury 385 Property Damage Leave Act 895 Freedom of Information

362 Personal Injury - Product Liability 790 Other Labor Litigation Act Med. Malpractice 791 Empl. Ret. Inc. 896 Arbitration

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS Security Act FEDERAL TAX SUITS 899 Administrative Procedure 210 Land Condemnation 440 Other Civil Rights 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act/Review or Appeal of 220 Foreclosure 441 Voting Sentence or Defendant) Agency Decision 230 Rent Lease & Ejectment 442 Employment Habeas Corpus: 871 IRSThird Party 950 Constitutionality of 240 Torts to Land 443 Housing/ 530 General 26 USC 7609 State Statutes 245 Tort Product Liability Accommodations 535 Death Penalty IMMIGRATION 290 All Other Real Property 445 Amer. w/Disabilities - 540 Mandamus & Other 462 Naturalization Application

Employment 550 Civil Rights 463 Habeas Corpus - 446 Amer. w/Disabilities - 555 Prison Condition Alien Detainee

Other 560 Civil Detainee - (Prisoner Petition) 448 Education Conditions of 465 Other Immigration

Confinement Actions

V. ORIGINTransferred fromanother district(specify)

(Place an X in One Box Only) 1 Original

Proceeding 2 Removed from

State Court 3 Remanded from

Appellate Court 4 Reinstated or

Reopened 5 6 Multidistrict

Litigation

VI. CAUSE OF ACTION

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): Brief description of cause:

VII. REQUESTED IN COMPLAINT:

CHECK IF THIS IS A CLASS ACTIONUNDER F.R.C.P. 23

DEMAND $ CHECK YES only if demanded in complaint:

JURY DEMAND: Yes No

VIII. RELATED CASE(S) IF ANY

(See instructions):JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case: 4:12-cv-01710-NAB Doc. #: 3 Filed: 09/27/12 Page: 1 of 2 PageID #: 10Case: 4:12-cv-01710-NAB Doc. #: 1-1 Filed: 09/21/12 Page: 1 of 2 PageID #: 14

JS 44 Reverse (Rev. 09/11)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as requiredby law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for theuse of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civilcomplaint filed. The attorney filing a case should complete the form as follows:

I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and de fendant. If the plaintiff or defendant is a governm ent agency, use onlythe full name or standard abbreviations. If the plaintiff or de fendant is an official within a government agency, identify first the agency and then the official, givingboth name and title.

(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at thetime of filing. In U.S. plaintiff cases, enter the name of th e county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnationcases, the county of residence of the defendant is the location of the tract of land involved.)

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, notingin this section (see attachment).

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C .P., which requires that jurisdictions be shown in pleadings. Place an X in oneof the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.

United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an X in this box.

Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdicti on arises under the Constitution of the UniteG States, an amendment to theConstitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box1 or 2 should be marked.

Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship ofthe different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if divers ity of citizenship was indicated above. Mark this sectionfor each principal party.

IV. Nature of Suit. Place an X in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, issufficient to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature ofsuit, select the most definitive.

V. Origin. Place an X in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.

Removed from State Court. (2) Proceedings initiated in state cour ts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petitionfor removal is granted, check this box.

Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing date.

Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.

Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrictlitigation transfers.

Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When thisbox is checked, do not check (5) above.

Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judges decision.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause . Do not cite jurisdictional statutesunless diversity. Example: U.S. Civil Statute: 47 USC 553

Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an X in this box if you are filing a class action under Rule 23, F.R.Cv.P.

Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.

Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket numbersand the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.


UNITED STATES DISTRICT COURTEASTERN DISTRICT OF MISSOURI

) , )

)Plaintiff, )

)v. ) Case No.

), )

) Defendant, )

)

ORIGINAL FILING FORM

THIS FORM MUST BE COMPLETED AND VERIFIED BY THE FILING PARTYWHEN INITIATING A NEW CASE.

THIS SAME CAUSE, OR A SUBSTANTIALLY EQUIVALENT COMPLAINT, WAS

PREVIOUSLY FILED IN THIS COURT AS CASE NUMBER

AND ASSIGNED TO THE HONORABLE JUDGE .

THIS CAUSE IS RELATED, BUT IS NOT SUBSTANTIALLY EQUIVALENT TO ANY

PREVIOUSLY FILED COMPLAINT. THE RELATED CASE NUMBER IS AND

THAT CASE WAS ASSIGNED TO THE HONORABLE . THIS CASE MAY,

THEREFORE, BE OPENED AS AN ORIGINAL PROCEEDING.

NEITHER THIS SAME CAUSE, NOR A SUBSTANTIALLY EQUIVALENT

COMPLAINT, HAS BEEN PREVIOUSLY FILED IN THIS COURT, AND THEREFORE

MAY BE OPENED AS AN ORIGINAL PROCEEDING.

The undersigned affirms that the information provided above is true and correct.

Date: Signature of Filing Party


AO 440 (Rev. 12/09) Summons in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

)))))))

Plaintiff

v. Civil Action No.

Defendant

SUMMONS IN A CIVIL ACTION

To: (Defendants name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if youare the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

CLERK OF COURT

Date:Signature of Clerk or Deputy Clerk

Case: 4:12-cv-01710-NAB Doc. #: 1-3 Filed: 09/21/12 Page: 1 of 2 PageID #: 17

AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

I personally served the summons on the individual at (place)on (date) ; or

I left the summons at the individuals residence or usual place of abode with (name), a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individuals last known address; or

I served the summons on (name of individual) , who is designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

I returned the summons unexecuted because ; or Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc:




__________ District of __________

)))))))

Plaintiff

v. Civil Action No.

Defendant






CLERK OF COURT




Civil Action No.








on (date) ; or


.





Servers address





__________ District of __________

)))))))

Plaintiff

v. Civil Action No.

Defendant






CLERK OF COURT




Civil Action No.








on (date) ; or


.





Servers address





__________ District of __________

)))))))

Plaintiff

v. Civil Action No.

Defendant






CLERK OF COURT




Civil Action No.








on (date) ; or


.





Servers address



Brief Description: Excessive use of police forceButton6: Demand: 250000Text1: DB, minor child, by and through Tami BennettText2: Jefferson County Sheriff's Dept, et al.Place Served:

Method:

Text3: 4:12-CV-01710Text4: Text5: Organization:

Text6: Text7: Text8: 09/27/2012Text9: /s/ Richard R. LozanoPlaintiff address: Richard R. Lozano231 S. Bemiston, Ste. 800Clayton, Missouri 63015(314) 650-5217

Button: SaveAs: Print1: Reset:

County_of_Residence_of_Fi: Jefferson CountyDate: 09/27/2012Unexecuted Reason:

Plaintiff: DB, minor child, by and through Tami Bennett

Attorneys: DOCKET_NUMBER: CHECK_IF_THIS_IS_A_CLASS: Other:

JUDGE: Place Served2:

FirmName: Richard R. Lozano, 231 S. Bemiston Ste. 800Clayton, Missouri 63105 (314) 650-5217Defendant: Jefferson County Sheriff's Department, et al.

Check Box6: YesCheck Box5: Check Box4: Left With2:

Server Address:

Date_Today2:

7: Service Fee:

Total Fee: 0

Additional information:

Basis of Jurisdiction: 3.Federal_Question

Served On:

9: 8: Date_Served:

Travel Fee:

Date_Received:

17: 18: 15: 16: 13: 14: Defendant2:

11: 12: V: Origin: 1

CM/ECF Requirements: Date_Served1:

CauseofAction: 42 USC 1983Defendant address: Jefferson County Sheriff's Department510 1st St Hillsboro, MO 63050

Date_Served2:

Civil action number: 4:12-CV-01710

Server Signature:

b_County_of_Residence_of: Jefferson CountyNature of Suit: 440

Sig: /s/ Richard R. LozanoDate_Today:

CHECK_YES_only_if_demand1: Yes

Organization2:

10: Left With:

Dist: Info: Eastern District of Missouri

Server Name:

Deputy Clerk Signature:

justin cosma

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