MOTION TO DISMISS

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF XXX

XXX  DIVISION

 

 

XXX,                            §

Plaintiff,                                                    §

1. §      Case XXX

HARRIS COUNTY, XXX;      §

1. al. §

Defendants.                                             §

 

 

PLAINTIFF’S OPPOSITION TO DEFENDANT REYES’ MOTION TO DISMISS

NOW COMES XXX, Plaintiff, and files this Opposition to Defendant XXX Motion to Dismiss, and for cause would show this Honorable Court as follows:

 

1. STATEMENT OF FACTS IN SUPPORT OF OPPOSITION TO DEFENDANT REYES’ MOTION TO DISMISS
2. The Plaintiff is the owner of two rental properties located in Harris County. These properties consist of furnished rooms that are rented individually in a shared living arrangement similar to Airbnb.
3. The Plaintiff has furnished both houses, including all bedrooms and common areas such as the living room, kitchen, and laundry facilities. Additionally, the Plaintiff provides various utilities and services to the tenants, including water, electricity, internet, gas, lawn services, and regular maid services.
4. The lease agreements between the Plaintiff and the tenants contain provisions allowing the Plaintiff and their agents to enter the common areas as needed for inspection, maintenance, or improvements to the property. The tenants are informed that such entries may occur without prior notice.
5. Furthermore, the lease agreements also include a provision stating that the Plaintiff may install monitoring devices only in the property’s entrances and common areas. These devices are intended to ensure tenant safety, protect the Plaintiff’s property in common areas, and enforce compliance with house rules, such as kitchen cleanliness. The tenants are explicitly informed that no cameras or monitoring devices are installed in private areas like bedrooms or bathrooms.
6. On or around December XXX, the Defendant,  .XXXX, became a tenant at one of the Plaintiff’s rental properties. XXX  rented the Master Bedroom and shared the rest of the house, including the common areas, with other unrelated tenants.
7. Shortly after XXX moved in, multiple complaints were filed by other tenants regarding loud noise emanating from her room, which disrupted their peaceful enjoyment of the property.
8. In an attempt to address the noise issue, the Plaintiff sent text messages to XXX, requesting her cooperation in maintaining a peaceful environment. The Plaintiff also sent her a text message on February XXX, reminding her to clean up food left in the kitchen that appeared to be hers.
9. XXX responded to the Plaintiff’s text messages with insults and asserted that she should not be bothered about complaints or lease violations since she supposedly paid the highest rent. Her response demonstrated a rude and unreasonable attitude towards the Plaintiff and a failure to abide by the lease terms regarding noise and cleanliness.
10. On February XXX, the Plaintiff and their children visited the property to move the trash bins to the curbside for garbage pickup. At that time, XXX vehicle was already parked on the street. The Plaintiff ensured that the trash bins were positioned in a manner that did not obstruct the driveway or XXX vehicle. However, upon seeing the bins ,XXX  became furious and initiated a confrontational phone call with the Plaintiff, accusing them of damaging her vehicle.
11. XXX anger escalated, and she physically assaulted the Plaintiff by pushing and shoving them. In response, the Plaintiff called 911 to report the assault.
12. Law enforcement officers, including Defendant Michael Aaron Flores, responded to the call and saw video of the altercation and the assault. XXX did not deny assaulting Plaintiff. The Plaintiff showed the officers videos of the incidents and provided a detailed explanation of what had transpired. Following the assault, the Plaintiff decided to terminate XXX lease and issued her a three-day notice to vacate on February XXX. When an attempt was made to hand-deliver a second notice on February XXX refused to accept it and assaulted the Plaintiff again by pushing and shoving them.
13. The Plaintiff reported this second assault to 911, resulting in the arrival of Defendant Courtney Reyes and other officers. The Plaintiff shared the videos of the altercation with the officers and provided a full account of the events. The second assault occurred on XXX, the same day the Plaintiff was arrested for filing a false report of assault.
14. Defendant Reyes confronted XXX and claimed to have witnessed XXX yelling at the Plaintiff. XXX sobbing, vehemently denied this accusation.
15. XXX further stated that she saw XXX hands moving towards the Plaintiff’s face, emphasizing their close proximity during the incident. Despite Plaintiff repeatedly asserting that XXX had touched him, XXX continued to deny any physical contact.
16. Defendant Reyes became particularly enraged when she learned that XXX internet was allegedly not working. Instead of considering the undeniable video evidence of the assault, Defendant Reyes immediately focused on confronting the Plaintiff regarding the internet issue.
17. Disregarding the lack of hidden cameras in XXX room, Defendant Reyes proceeded to search other rooms without probable cause or a search warrant. Finding nothing, she then inquired about the address of the Plaintiff’s second rental house, likely with the intention of searching it. However, it seems that her superiors intervened and prevented her from proceeding.
18. Despite clear evidence of XXX aggressive behavior, the officers did not take any action against her. Instead, they handed her the notice to vacate and left the premises.
19. However, XXX refused to comply with the notice to vacate, prompting the Plaintiff to file an eviction petition with the Harris County Justice of the Peace on February XXX.
20. On March XXX, the Plaintiff was present at one of their properties to address maintenance concerns when another altercation occurred with XXX. The dispute involved the temperature in XXX room and internet access.
21. During the confrontation, XXX became extremely angry and aggressively approached the Plaintiff from over 6 ft away, shouting threats, cursing, and recklessly spitting in their face. The Plaintiff walked away from the altercation and contacted 911 to report the incident.
22. Responding officers, including Defendant Courtney Reyes, arrived at the scene. They questioned both parties and listened to XXX allegations of harassment and intimidation. XXX falsely accused the Plaintiff of spying on her with hidden cameras, implying that the Plaintiff must have had access to private information about her activities.
23. The officers detained the Plaintiff while they searched for hidden cameras, checking XXX  room and approaching other tenants. No evidence of hidden cameras was found.
24. Despite clear evidence of XXX aggressive behavior and the lack of hidden cameras, the officers unjustly arrested the Plaintiff, accusing them of making false reports and being a “troublemaker.”
25. The Plaintiff was taken into custody, and their personal belongings, including their wallet, cellphones, car keys, and cash, were confiscated. They were then transported to the Harris County Courthouse jail, where they endured approximately 16 hours of detention.
26. Upon release, the Plaintiff faced difficulties and hardships, including challenges in contacting their family and the physical and emotional distress caused by the unjust arrest and detention.
27. The Plaintiff attempted to obtain information regarding their arrest by filing official requests with the Harris County Constable Precinct 5 office. However, all requests were denied, even after the case was dismissed, under the pretext of protecting the Plaintiff, further obstructing justice and violating their due process rights.
28. The Plaintiff appealed to the Office of the Attorney General of Texas for an exception to access case information. Regrettably, the appeal was rejected, reinforcing the obstruction of justice and denial of due process.
29. The Plaintiff asserts that the actions of the Defendants, including Defendants Ted Heap, Harris County, and various law enforcement officers, constituted violations of their civil rights, including false arrest, malicious prosecution, obstruction of justice, and denial of due process.
30. In light of these facts, the Plaintiff seeks justice and the enforcement of their rights in this matter.

 

1. ARGUMENT

Plaintiff Has Brought Valid Claims Against Defendant Reyes

Malicious Prosecution

30. The Plaintiff’s allegations encompass a broader range of constitutional violations that go beyond malicious prosecution alone. Therefore, the cited cases, Castellano v. Fragozo and Deville v. Marcantel, are distinguishable from the present case.
31. The Plaintiff’s claim does not solely rely on a malicious prosecution theory but includes additional constitutional violations, such as false arrest, obstruction of justice, and denial of due process. These allegations, when considered together, form the basis of the Plaintiff’s claim.
32. The case of Morgan v. Chapman, which is also cited, is not directly applicable to the present matter. Morgan v. Chapman dealt specifically with a claim for malicious prosecution under Section 1983 and did not involve the additional constitutional violations raised by the Plaintiff in this case.
33. The Plaintiff’s claim is grounded in a violation of their constitutional rights, rather than relying solely on the notion of malicious prosecution. The actions of the Defendants, including false arrest and obstruction of justice, contribute to a broader pattern of misconduct that warrants redress under Section 1983.
34. It is well-established that Section 1983 provides a remedy for violations of constitutional rights, and courts have recognized various constitutional claims that encompass elements of malicious prosecution alongside other violations. The Plaintiff’s claim falls within this established framework, as it involves a combination of constitutional violations that collectively form the basis of their cause of action.
35. Therefore, while the Fifth Circuit may not recognize a standalone claim for malicious prosecution under Section 1983, the Plaintiff’s case involves additional constitutional violations that should not be dismissed solely on the basis of the malicious prosecution claim. The Plaintiff’s federal claim encompasses a broader range of constitutional violations that merit consideration and redress under Section 1983.

 

False Arrest

36. The argument put forth by Defendant Reyes asserts that there was arguable probable cause for the Plaintiff’s arrest for making a false assault report. However, upon a thorough examination of the facts and legal principles, it becomes evident that the existence of probable cause is far from certain. In light of the complexities surrounding the events leading to the Plaintiff’s arrest, the Plaintiff’s claim of false arrest should be upheld.
37. Defendant Reyes relies on Section 37.08 of the XXX Penal Code, which defines the offense of making a false statement during a criminal investigation. While this provision establishes a potential offense, it does not automatically confer probable cause for the Plaintiff’s arrest. To determine the presence of arguable probable cause, it is crucial to evaluate the specific facts and circumstances surrounding the alleged false assault report.
38. Probable cause requires more than mere suspicion or speculation. It necessitates facts and circumstances that would lead a prudent person, or one of reasonable caution, to believe that the suspect has committed an offense. In this case, the facts presented raise doubts about the existence of probable cause for the Plaintiff’s arrest.
39. The Plaintiff’s claim outlines a series of allegations and evidence that cast doubt on the veracity of the assault report. According to the Plaintiff, they provided texts reflecting landlord-tenant issues and cellphone videos allegedly showing assaults by XXX. However, living room evidence failed to corroborate the alleged assault. These discrepancies, when considered collectively, create doubt about the existence of probable cause. Defendant Reyes stated that she did not see the video of the assault, yet she and other officers watched the video clearly.
40. Additionally, it is worth noting that the Plaintiff had previously reported an assault by XXX but did not press charges or express significant pain resulting from the altercation. While this information may be relevant, it does not automatically establish probable cause for the false assault report charge. Each incident must be evaluated independently, considering the specific circumstances and evidence related to the alleged assault.
41. The dismissal of the criminal charge against the Plaintiff for assault does not invalidate the claim of false arrest. The outcome of a subsequent prosecution does not determine the existence of probable cause at the time of the arrest. The focus should be on the facts and circumstances known to the arresting officer at the time of the arrest, not the ultimate resolution of the criminal charge.
42. Moreover, it is important to recognize that arguable probable cause, while it may provide some justification for an arrest, does not absolve the arresting officer of liability for false arrest.
43. In this case, the Plaintiff has presented sufficient allegations and evidence to support the claim of false arrest. The existence of arguable probable cause does not conclusively establish the legality of the arrest, especially considering the doubts raised by the Plaintiff’s account and the lack of corroborating evidence.
44. Defendant Reyes suggests that arguable probable cause justifies the arrest. However, it is essential to remember that arguable probable cause is not an infallible defense against false arrest claims. It requires a careful examination of the specific circumstances and evidence available at the time of the arrest. Reyes saw clear video evidence presented by Plaintiff but maliciously choose to ignore them.
45. Furthermore, the argument fails to acknowledge the Supreme Court’s definition of probable cause as “the facts and circumstances within the officer’s knowledge that are sufficient to warrant a prudent person, or one of reasonable caution, in believing, in the circumstances shown, that the suspect has committed, is committing, or is about to commit an offense” XXX. This definition underscores the need for a reasonable belief based on the information available to the arresting officer.
46. The Plaintiff’s claim highlights the investigative steps taken by the arresting officer, Deputy Reyes, and raises questions about the sufficiency of the evidence to establish probable cause. The Plaintiff alleges that Reyes requested cellphone evidence of the alleged assault, but the Plaintiff could not provide any. Additionally, the doorbell camera evidence failed to show the alleged assault, and when asked by Deputy Reyes if she assaulted the Plaintiff, XXX denied doing so.
47. These circumstances indicate that Deputy Reyes had reason to doubt the veracity of the Plaintiff’s assault report. However, it is important to note that the absence of supporting evidence does not automatically establish the presence of false reporting. Further investigation and careful evaluation of all available evidence should have been conducted before determining probable cause for the arrest.
48. The argument made by Defendant Reyes relies heavily on the concept of arguable probable cause. While arguable probable cause may provide some justification for an arrest, it does not absolve the arresting officer of liability for false arrest. The Plaintiff has alleged facts and circumstances that raise doubts about the reasonableness of the probable cause relied upon by Deputy Reyes.
49. Moreover, the argument overlooks the fundamental principle that a warrantless arrest without probable cause violates an individual’s rights under the Fourth Amendment XXX. The Supreme Court has unequivocally stated that probable cause is a constitutional requirement for an arrest to be lawful.
50. It is worth reiterating that the ultimate dismissal of the criminal charge against the Plaintiff is not dispositive of the issue of probable cause for the arrest and the liability of Deputy Reyes. The focus must remain on the facts and circumstances known to the arresting officer at the time of the arrest, not the ultimate outcome of subsequent proceedings.
51. In conclusion, the Plaintiff has presented sufficient allegations and evidence to support the claim of false arrest. The existence of arguable probable cause does not conclusively establish the legality of the arrest, especially considering the doubts raised by the Plaintiff’s account and the lack of corroborating evidence. The circumstances surrounding the Plaintiff’s arrest require a thorough evaluation, and it is evident that the Plaintiff’s claim of false arrest should be upheld.

 

Due Process

52. The argument put forth by Defendant Reyes asserts that the Plaintiff mistakenly asserts a claim under the Fourteenth Amendment and argues that the Fourth Amendment, which covers false arrests, should be the guide for analyzing the claims. However, upon careful examination of the facts and relevant legal principles, it becomes evident that the Plaintiff’s claim under the Fourteenth Amendment is valid and should not be dismissed as a matter of law.
53. Defendant Reyes relies on the principle that when a particular Amendment explicitly addresses a specific type of government behavior, that Amendment should guide the analysis of the claims rather than a more generalized notion of substantive due process. While this principle is generally applicable, it does not automatically preclude the Plaintiff from seeking relief under the Fourteenth Amendment.
54. It is important to note that the Fourteenth Amendment provides explicit textual protection against certain government actions, including the deprivation of life, liberty, or property without due process of law. The Plaintiff’s claim under the Fourteenth Amendment arises from the alleged excessive force used by Deputy Reyes during the arrest, which potentially violates the Plaintiff’s rights to due process and protection from state actions that infringe upon their liberty interests.
55. Although the Fourth Amendment generally covers false arrests, it does not necessarily exclude the application of the Fourteenth Amendment in cases involving excessive force or other constitutional violations. The Supreme Court has recognized that the Fourth Amendment and the Fourteenth Amendment can provide distinct and complementary protections in different circumstances.
56. In cases involving excessive force during an arrest, the Fourth Amendment protects individuals from unreasonable seizures, which can include the use of excessive force by law enforcement officers. However, the Fourteenth Amendment can also come into play when the alleged conduct rises to the level of a violation of substantive due process, particularly when it involves egregious or shocking behavior that shocks the conscience.
57. The Supreme Court has acknowledged that excessive force claims can be analyzed under both the Fourth Amendment and the Fourteenth Amendment. In Graham v. Connor, the Court held that “all claims that law enforcement officers have used excessive force…in the course of an arrest, investigatory stop, or other ‘seizure’ of a free citizen should be analyzed under the Fourth Amendment and its ‘reasonableness’ standard.” However, the Court also recognized that in certain circumstances, such as when the force used is particularly egregious or shocks the conscience, the claim may be analyzed under the Fourteenth Amendment’s substantive due process framework.
58. In the present case, the Plaintiff’s claim of excessive force alleges that Deputy Reyes used unreasonable and excessive force during the arrest. If the alleged conduct goes beyond a mere Fourth Amendment violation and rises to the level of shocking or conscience-shocking behavior, it may trigger the protections of the Fourteenth Amendment.
59. Defendant Reyes’s assertion that the Plaintiff’s claim under the Fourteenth Amendment should be dismissed solely because the Fourth Amendment covers false arrests oversimplifies the issue. The nature and circumstances of the alleged excessive force must be considered to determine whether the claim falls within the purview of the Fourteenth Amendment’s substantive due process protections.
60. In conclusion, the Plaintiff’s claim under the Fourteenth Amendment should not be dismissed as a matter of law. While the Fourth Amendment generally governs false arrests, it does not preclude the application of the Fourteenth Amendment in cases involving alleged excessive force that rises to the level of a violation of substantive due process. The specific facts and circumstances of the case must be carefully evaluated to determine the appropriate constitutional basis for the claim.

 

Retaliatory Arrest

61. Defendant Reyes contends that in order to assert a retaliatory arrest claim, the plaintiff must plead and prove the absence of probable cause for the arrest. It relies on legal precedents such as Nieves v. Bartlett, Keenan v. Tejeda, and Curtis v. Sowell to support this proposition. However, a careful analysis of the facts and the applicable legal principles reveals that the plaintiff’s retaliatory arrest claim can still proceed even if probable cause existed for the arrest.
62. While it is true that establishing the absence of probable cause is an essential element in malicious prosecution claims and may be relevant in certain retaliatory arrest cases, it is not an absolute requirement for every retaliatory arrest claim based on the First Amendment. The First Amendment protects individuals from retaliatory actions by government officials, including arrests made in retaliation for the exercise of protected speech or other protected activities.
63. In the landmark case of XXXX  the Supreme Court emphasized that retaliatory arrest claims are distinct from malicious prosecution claims. The Court recognized that malicious prosecution claims require the absence of probable cause as an essential element because they focus on the initiation and continuation of criminal proceedings. However, retaliatory arrest claims are concerned with the motive behind the arrest rather than the subsequent prosecution.
64. In Nieves v. Bartlett, the Supreme Court reiterated the principle that the absence of probable cause is an important factor in analyzing retaliatory arrest claims. However, the Court did not establish an absolute rule requiring the complete absence of probable cause to pursue such a claim. Instead, it emphasized that a plaintiff can still prevail on a retaliatory arrest claim if they can demonstrate that the arrest was solely motivated by the retaliatory intent of the arresting officer, even if there was probable cause for the arrest.
65. In the present case, the plaintiff alleges that Deputy Reyes arrested him in retaliation for his exercise of protected speech and other protected activities. To establish a retaliatory arrest claim, the plaintiff must show that the arrest was motivated solely by the desire to retaliate against the plaintiff’s protected expression or conduct. While the absence of probable cause can be a relevant factor in establishing retaliatory intent, it is not the sole determinant.
66. The Fifth Circuit’s decision in Keenan v. Tejeda, which links retaliatory criminal prosecutions to the common-law elements of malicious prosecution, does not automatically require the absence of probable cause for a retaliatory arrest claim. The court’s reasoning in that case does not explicitly address the distinct nature of retaliatory arrest claims and the requirement of proving retaliatory intent.
67. Furthermore, the Curtis v. Sowell case, cited in the motion, involved a dismissal of the plaintiff’s claim based on the plaintiff’s failure to establish the absence of probable cause. However, it does not preclude the possibility that a retaliatory arrest claim could still succeed without proving the absence of probable cause if the plaintiff can establish retaliatory intent through other means.
68. In conclusion, while the absence of probable cause is a relevant factor in retaliatory arrest claims, it is not an absolute requirement for such claims based on the First Amendment. The plaintiff can prevail on a retaliatory arrest claim by demonstrating that the arrest was solely motivated by retaliatory intent, even if probable cause for the arrest existed. The distinct nature of retaliatory arrest claims and their focus on the retaliatory intent behind the arrest should be recognized and considered in evaluating the plaintiff’s claim in this case.

 

State Law Tort Claim

69. Defendant Reyes asserts that the plaintiff’s claim for intentional infliction of emotional distress fails because the plaintiff has not adequately pleaded that Deputy Reyes’s conduct was “extreme and outrageous” or that the plaintiff suffered severe emotional distress. It relies on legal principles established in XXX  and other Texas cases to support its position. However, a careful analysis of the facts and applicable law reveals that the plaintiff has met the necessary requirements for an intentional infliction of emotional distress claim.
70. To succeed on a claim for intentional infliction of emotional distress in Texas, a plaintiff must establish four elements: (1) the defendant acted intentionally or recklessly, (2) the defendant’s conduct was extreme and outrageous, (3) the defendant’s actions caused the plaintiff emotional distress, and (4) the resulting emotional distress was severe. While it is true that extreme and outrageous conduct is required, it is important to note that Texas law recognizes a broad range of conduct that may qualify as extreme and outrageous.
71. The argument cites XXX, which describes extreme and outrageous conduct as behavior that goes beyond all possible bounds of decency and is regarded as atrocious and utterly intolerable in a civilized community.
72. However, this definition does not limit extreme and outrageous conduct to only the most extreme instances. Texas courts have recognized that liability may arise from a wide range of conduct, including intentional acts, threats, harassment, and abusive conduct that exceed the bounds of normal human behavior.
73. In this case, the plaintiff alleges that Deputy Reyes intentionally arrested him without probable cause, retaliating against him for exercising his First Amendment rights. Such conduct, if proven, could reasonably be considered extreme and outrageous.
74. Arresting an individual without a legitimate basis and with the intent to retaliate against protected speech and activities is conduct that exceeds the bounds of decency and is utterly intolerable in a civilized community.
75. Moreover, the argument references the doctrine of official immunity, claiming that Texas law of official immunity aligns with federal qualified immunity law. While official immunity shields government officials from personal liability in certain circumstances, it does not provide blanket protection for actions that involve intentional infliction of emotional distress.
76. The doctrine of official immunity does not shield a public official from liability for acts that are outside the scope of their official duties or that involve intentional misconduct or gross negligence.
77. In this case, the plaintiff alleges that Deputy Reyes acted intentionally or recklessly in arresting him without probable cause as a means of retaliation. If the plaintiff can establish these allegations, Deputy Reyes’s conduct would fall outside the scope of official immunity because it involves intentional or reckless actions that caused harm to the plaintiff.
78. In conclusion, the plaintiff has adequately pleaded the elements required for an intentional infliction of emotional distress claim. The alleged conduct of Deputy Reyes, if proven, could be considered extreme and outrageous, exceeding the bounds of decency in a civilized community.
79. Additionally, the doctrine of official immunity does not shield Deputy Reyes from liability for intentional misconduct or actions outside the scope of official duties. Therefore, the plaintiff’s claim for intentional infliction of emotional distress should be allowed to proceed.

 

Punitive Damages Claim

80. Punitive damages are awarded in civil cases to punish a defendant for their intentional or reckless conduct and to deter similar behavior in the future. In order to justify an award of punitive damages, the plaintiff must demonstrate by clear and convincing evidence that the defendant’s actions were characterized by malice, willful misconduct, gross negligence, or a conscious disregard for the rights and safety of others.
81. Reyes relies on Heaney v. Roberts to support its position. However, it is important to note that each case must be evaluated based on its own unique set of facts and circumstances. The mere denial of ill will or malice by the defendant does not automatically preclude a claim for punitive damages. It is well-established that punitive damages can be awarded based on the defendant’s reckless conduct, even in the absence of specific ill will or malice.
82. In this case, the plaintiff alleges that Deputy Reyes, along with other deputies, arrested him without probable cause as a form of retaliation for exercising his First Amendment rights. The plaintiff further asserts that the deputies detained him, conducted a prolonged investigation, and ultimately arrested him despite the absence of evidence supporting the charges. These allegations, if proven, could constitute reckless conduct or a conscious disregard for the plaintiff’s rights and safety.
83. Furthermore, the argument fails to consider the potential availability of punitive damages under state law. While Heaney v. Roberts may provide guidance in the federal context, it does not dictate the outcome in this case if state law allows for the award of punitive damages under similar circumstances. State laws regarding punitive damages may differ from federal standards, and it is crucial to consider the specific jurisdiction’s legal framework.
84. In conclusion, the plaintiff has presented sufficient allegations to warrant a claim for punitive damages. The denial of ill will or malice by the defendant does not automatically preclude the possibility of punitive damages, as the focus is on the defendant’s conduct and the level of recklessness or conscious disregard for the plaintiff’s rights. Additionally, the argument fails to account for the potential application of state law, which may provide a basis for punitive damages. Therefore, the plaintiff’s claim for punitive damages should not be summarily dismissed and should be considered based on the evidence and applicable legal standards.

 

1. PRAYER FOR RELIEF

REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests this Honorable Court to DISMISS Defendant XXX Motion to Dismiss.

 

Dated this _____ day of July, XXX.

 

Respectfully Submitted,

 

 

XXX

Plaintiff in pro per

 

 

 

 

 

 

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