‘STATE OF LOUISIANA* PARISH OF RAPSDES * 9% JUDICIAL DISTRICT COURT ANTHONY T. BROWN FLED: BIANCAS. BROWN, vmnsisxo:_ OOS AN CITY OF ALEXANDRA, By: MAYORIACOUES ROY, CITY ‘DEPUTY CLERK OF COURT COUNCIL, CHIEF OF POLICE. OREN M LaMPERT, CAPTAIN MICHAEL RENNIER, INDIVIDUALLY, AND IN HIS DOFFICHASCAPACTTY, GRAND THEATRE AKANOUTHERN THEATRES, LLG, ALEXANDRIM THEATRES, LLC, MICHAEL STEVENSON, AND THEI. INSURANCE COMPANTES, ¥Y2. PETITION Fon DAMAGES [Now INTO COURT, throeghw espe coun comes the Pantie, ANTHONY T, BROWN, 1 BIANCA S, BROWN, bein ofthe fall ae of majority omiliary ofthe Parish of Rape, Sate oun, respect represents tht: “That made Defendants brcn ar the CITY OF ALEXANDRIA, «government city operating person tothe laws of th State of Liana caro and use, deprived sii of gh secured bythe Lasisians Constitution, Artic 1§ 20 and Une ‘States Contato, tn vation of €2 USC. 9 3983, [MANOR JACQUES ROY AND THE ALEXANDRIA CITY COUNCIL are the smvering (eas ofthe Sate of Lauans ALEXANDRIA CITY POLICE DEPARTMENT, AND CHIEF OF POLICE, ‘LOREN MARC LAMPERT, isthe governing authority, deson maker for ALEXANDRIA POLICE DEPARTMENT. Defendant, CAPTAIN MICHAFL RENNIER, cng indivi a i a ‘apace wer the authority he CITY OF ALEXANDRIA, a the ALEXANDRIA POLICE DEPARTMENT (GRAND THEATRE AKA SOUTHERN THEATRES, LLC, ALEXANDRIA “THEATRES, LLC, foreign Li te Liat Corporation ding busines inthe Stat of SANE COP ETORED{ovina with thir reitered agent for Service of Process the CT Cerporation System, 23867 Plan Tomer Drive, Baton Rouge, Louisiana W816. Defendant’ INSURANCE ‘COMPANIES XV, doing busines inthe Stat of Louisiana, etendant, MICHAEL STEVENSON, an employeuformer employe of GRAND ‘THEATRE acting nthe spe of hi employment with GRAND THEATRE. ‘reasonable ander the premises, pnlive damage allowed by am atoreys fees al cost of hse proces, legal intr thereon from the dat of judi demand wnt pa, nt ails leo which Petitioners are etd at ay ori equity. (On May 21,2016, a8 thee date night, Platte ANTHONY T. BROWN, and is ‘ie, Pasi BIANCA S. BROWN, attended the GRAND THEATRE in Alecandia fr regular night onthe Tome, Whi he canceion sand MICHAEL STEVENSON, an {employee tthe GRAND THEATRE sad hls o Mrs, Brown, Subsequeaty, Me rowan Introduced hinvefo Stevenson, They engaged incor conversation it the mai oy fe there, then sok hands, Paints then wet in to view thee move “Captain Americ". The movie lasted fortwo hours.Pliis mere coming oof ove when they were asoted by Defendant MICHAEL STEVENSON who was standing the doorway, Defendant Sevenonattempled to commence & conversation wih Mr: Bes: making I Insporoorat, wit responding turned a lant then cornered and jmp infront of them, making the statement, an grown as ma and Tl tal whoever the el wa {alk 1 hen pashed Mr. Brown in the chest sd commenced tacking Nm, causing gh rte Betweun the woof them. Mrs. Bro sreamed for he assistce of Defendant Officer MICHAEL, RENNIER wi 1 employed by the [ALEXANDRIA POLICE DEPARTMENT providing scarey tothe GRAND THEATRE. Defendant MICHAEL. RENNIER ran at fll peed toward Phin and Defendant, who ‘weve ihe, Defendant RENTER arbitrary slammed Plant ANTHONY, BROWN tothe fora om his back using profany. Ie the mt of the officer's cessive ations tard Pani ANTHONY BROWN, he struck Mii Brom, knocking het the ‘oor whereby she hit her hea, casing vere traumatic injures te her hed neck, back, ankle and fractured her oe. Ths caused extreme physi pain and emetonl distress ant sngsish, She was subsequently taken o Christus St Frances CaBrini Hospital by Acadian. Plant ANTHONY 7. BROWN further alleges that inspite of the severity of his Injures no medical services were pruned by the ALEXANDRIA POLICE. DEPARTMENT in ight ofthe fact he on thre cesions avid the APD. officers that he Defendant GRAND THEATRE AKA SOUTHERN THEATRES/ALEXANDRIA THEATRES and cir Insurance company XYZ are Hable i solo to Pais f ‘employing and. retaining employees with Inarasment, negligence and ether miscondsct and filing to roect thee patrons from misconduct. Defendant MICHAEL STEVENSON, and his insurance company sable aide for damages caused 1 the Paint fo is vila havior Defendant CITY OF ALEXANDRIA, MAYOR, JACQUES ROY and the [ALEXANDRIA CITY COUNCIL and thelr insurance company XYZ are ible in slide for damages cased to the Plaintiff selecting retaining, and msgning employees wth demonstrable propensities fr excessive fore, vilece, neligence and other misconductand acting with eiberateindiferece to Plats medical needs, Further, Defendant, sting clr of state law, deprived Pants of hts, privilege, and immunities secured by Louisians Constitution andthe US. Coatution Atal mes pertinent, ert, Plait: enjoyed leary established sights ranted by the Louisiana Constitution Article 1 § 20and pareuant to the S* and the 14° Amendment tothe U.S. Contitton, Further, 3 eaymea ofthe $ amendoent tobe ‘oe fom excensive fre. The setionadelierte nation ofthe defendant ‘Upon information and bebe Paice allegs dat Injrie were cased by the cence andor fault under LaC.C. Art 2515 of the defendants and th “emploeclagent tbe Mei as fllons: 1. Slamming Pani tthe for; 4 Retwing andlor filing to render immediatly andlor adequate medial 44 Keweking Plant othe oor; ‘. Rrmployed employes tha caused violence and hartamen pon Palais; 6 allure prtet Pails against barf employers; and Such other actinsinactions as will be more fully shown a he tal af Defendants are adlinaly abe for attorney’ es pursuant to 42 S.C. § 1988 for which Paints specteally se erin. a Defendants ar ale for al such other rl to which Panis ae ented at aw ‘rin equity anal fr which Pani specially sues herein.Defendants are lable fo the os of consortia, evi and sity te both Phi for the physic manifestations of injuries they suffered ares ofthe sore ed actons. Pints are ati to and desires trial by Jury of WHEREFORE, Plabif ANTHONY T. BROWN and BIANCA 8. BROWN, pray {or ial by Jury and after due proceedings ae had that there be jgment herein a favor and aguas ll deinen, forall sums as ae resonable unive damages med bylaw, attorneys feel cost of rin from the dat of ici demand unl psd, ‘whch they ar enti by law orn egy Carol D: Powel Lexing Asecinen PLC 2488 Tower Drive, St. 6 Monroe Leaisana 71201 “Telephone 815) 240700 Facsimile: (318) 240702, hl lgaldoweayahoo.com ‘Bar Rll No 21088 = yo Acme nh Cy Conn st9189" Stree, sssSTATE OF LOU IANA* PARISH OF RAPIDES * 9 JUDICIAL DISTRICT COURT ANTHONY T. BROWN runs: BIANCA'S. BROWN VERSUS No. CITY OF ALEXANDRA, By. MAYOR JACOUES ROY. crTy DEPUTY CLERK OF COURT COUNCIL, CHIEF OF POLICE, ‘CAPTAIN MICHAEL RENNIE, INDIVIDUALLY, AND IN 1 OFFICIAL CAPACITY, GRAND ‘THEATRE AKA/SOUTHERN THEATRES, ULC, ALEXANDRIA THEATRES, LLC aXD MICHAEL STEVENSON, THEIR INSURANCE. COMPANY, XYZ. ‘MERINCATION BEFORE ME, the undersigned Notary Pel c, peronally came and appeared ANTHONY T. BROWN and BIANCA S. BROWN who, after beng duly sworn, dd depose ‘sd state that dey have read the foregoing Petition for Damages and al the allt ‘contained therein are re and corres to the bes SWORN TO AND SUBSCRIBED before me, hi_{24 day of. 2017, at Monroe, Louisiana, Oech iran ‘CAROL D. POWELL LEXING FOR LIFE DARROLLNO. 2108 isang a1 aw @