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The defendants are Marion County Sheriff Department Deputies who falsely arrested the plaintiff John Doe for bank robbery. Doe was arrested without a warrant and without probable cause. This lawsuit seeks compensatory and punitive damages from the defendant law enforcement officers for this false arrest and imprisonment. Plaintiff is an adult and resides in Marion County, Indiana. Defendants are deputies employed by the Marion County Sheriff who are being sued in their individual capacities as deputy sheriffs. Fact: State facts simply and concisely.

On April 22, 1991, the Union Federal Savings and Loan Bank located at 8603 Allisonville Road in Indianapolis was robbed.
Plaintiff lives in the general vicinity of the bank and the next day was stopped by the Defendants while he was driving his car on Allisonville Road. In some respects Plaintiff resembles, in physical appearance, the person who was photographed while robbing the bank the previous day. The Defendants arrested Plaintiff and caused him to be jailed and charged with the bank robbery. The Defendants arrested Plaintiff without an arrest warrant. The Defendants arrested Plaintiff without probable cause. Plaintiff did not rob the bank. Plaintiff was forced to defend himself against the criminal charge. The charges against Plaintiff were dismissed by the prosecutor prior to trial but approximately eleven months after they were filed. Plaintiff has been financially and emotionally harmed by the Defendants' actions and his reputation has been damaged. The Defendants' actions were taken under color of state law. The Defendants' actions were reckless and taken in deliberate and callous indifference to Plaintiff's rights.

AS AND FOR A CAUSE OF ACTION ON BEHALF OF PLAINTIFF The plaintiff repeats, reiterates and re alleges each and every allegation contained in paragraphs marked 1 through 10 with the same force and effect as if more fully set forth herein.

Defendants' actions violated Plaintiff's rights to be free from false arrest and false imprisonment under the common law of Indiana and right to be free from unreasonable seizure under the Fourth Amendment to the United States Constitution. The Prayer for relief must be included. Tell the court what you want the court to do. Ask for cost, attorney fees, sanctions, and the records.
Plaintiff is requesting compensatory and punitive damages as well as his costs and attorney's fees. Respectfully Submitted,