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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
DREW PARSONS,
Plaintiff,
vs. Case No: 2020- -
Hon.
CITY OF ANN ARBOR, a municipal
corporation, ANN ARBOR POLICE
DEPARTMENT, SGT. MARK J.
PULFORD JR., OFFICER JUSTIN J.
KANDT, OFFICER RYAN M. SCOTT,
OFFICER JEFFREY D. SHAFER JR., and
OFFICER ERIC D. CHINN,
Defendants.
LOUIS G. COREY (P34377)
JOHN P. MEADS (P82914)
Attorneys for Plaintiff
401 N. Main Street,
Royal Oak, Michigan 48067
(248) 548-9700
lou@coreylawfirm.com
john@coreylawfirm.com
There is no other civil action between these parties arising out of the
same transaction or occurrence as alleged in this complaint pending
in this court, nor has any such action been previously filed and dismissed
or transferred after having been assigned to a judge, nor do I know of
any other civil action, not between these parties, arising out of the
same transaction or occurrence as alleged in this complaint that is
either pending or was previously filed and dismissed, transferred, or
otherwise disposed of after having been assigned to a judge in this
court.
COMPLAINT & JURY DEMAND
NOW COMES, Plaintiff, DREW PARSONS, by and through his undersigned
counsel, THE COREY LAW FIRM, and in complaint against the defendants, alleges the
following:
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JURISDICTION AND VENUE
1. This action is brought pursuant to 42 U.S.C. §§ 1983 and the First, Fourth,
and Fourteenth Amendments to the United States Constitution.
2. This Court has jurisdiction pursuant to 28 U.S.C. §§ 1331, 1332, and 1343.
Plaintiff further invokes the supplemental jurisdiction of this Court to hear and decide
claims arising out of state law, pursuant to 28 U.S.C. § 1367.
3. Venue is proper pursuant to 28 U.S.C. § 1391(b).
PARTIES
4. Plaintiff, DREW PARSONS, at all times relevant herein, was a student
attending Bates College in the City of Lewiston, County of Androscoggin, State of Maine.
5. Defendant, CITY OF ANN ARBOR (hereinafter “City”), at all times relevant
herein, is a municipal corporation organized and existing under the laws of the State of
Michigan and is headquartered and conducts business in the County of Washtenaw,
State of Michigan.
6. Defendant, ANN ARBOR POLICE DEPARTMENT (hereinafter “AAPD”), at
all times relevant herein, is a municipal law enforcement agency organized and existing
under the laws of the State of Michigan, subject to the control of Defendant City, and is
headquartered and conducts business in the County of Washtenaw, State of Michigan.
7. Defendant, SGT. MARK J. PULFORD JR. (hereinafter “Pulford”), is upon
information and belief at all times relevant herein, a Police Staff Sergeant employed by
Defendant City and the Defendant Police Department.
8. Defendants, OFFICER ERIC D. CHINN (hereinafter “Chinn”); OFFICER
JUSTIN J. KANDT (hereinafter “Kandt”); OFFICER RYAN M. SCOTT (hereinafter
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“Scott”); and OFFICER JEFFREY D. SHAFER JR. (hereinafter “Shafer”), were upon
information and belief at all times relevant herein, Police Officers employed by Defendant
City and the Defendant Police Department.
FACTUAL ALLEGATIONS
9. During the evening of November 15, 2018, Plaintiff was assaulted, battered,
and beaten, with excessive and unnecessary force used by Defendant Police Officers
while Plaintiff was being arrested, placed in handcuffs, and taken into custody by the
Defendants.
10. Prior to this incident, Plaintiff was with friends at a local restaurant and bar,
‘Scorekeepers,’ in Ann Arbor, MI.
11. While inside Scorekeepers, an altercation occurred and Plaintiff was
misidentified as one of the individuals involved in the altercation.
12. Plaintiff was taken by two bouncers and escorted out of Scorekeepers onto
the adjacent sidewalk where Defendant Kandt was parked in his police car, in the process
of issuing an unrelated citation to another individual.
13. Defendant Kandt saw Plaintiff being escorted from Scorekeepers, exited
his vehicle, and approached the bouncers who then let go of Plaintiff.
14. Defendant Kandt grabbed Plaintiff by the arm and pulled him over to the
front the police car, instructing Plaintiff to “step over here, bro” and to put his hands behind
his back.
15. Plaintiff, while attempting to be compliant with Defendant Kandt and without
putting up any resistance, asked Defendant Kandt “Wait, really?”
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16. Without any hesitation, Defendant Kandt grabbed Plaintiff and forced him
face-first onto the hood of the police car, trapping one of Plaintiff’s arms between his chest
and the hood of the police car.
17. Defendant Kandt then began screaming at Plaintiff to place his hands
behind his back.
18. Still attempting to comply with Defendant Kandt’s orders, Plaintiff lifted his
torso from the hood of the police car to free his trapped arm.
19. Before Plaintiff could bring his freed arm behind his back, Defendant Kandt,
again, without hesitation, grabbed Plaintiff, picked him up, and body-slammed him face-
first down onto the pavement.
20. The force of impact briefly rendered Plaintiff unconscious and inflicted
lacerations to his face.
21. Despite having Plaintiff face-down on the pavement in a pool of his own
blood, Defendant Kandt climbed onto Plaintiff’s back and called for back-up, stating that
he had “one resisting.”
22. Within seconds, a second police officer, believed to be Defendant Scott,
arrived on scene, at which time he also climbed on top of Plaintiff and began assisting
Defendant Kandt in executing the ‘arrest’ of Plaintiff.
23. After placing handcuffs on Plaintiff, Defendants Kandt and Scott lifted
Plaintiff off of the ground and led him to the back of the police car.
24. At this point, additional officers had arrived on scene in response to
Defendant Kandt’s call for back-up, believed to be Defendants Pulford, Shafer, and
Chinn.
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25. Defendants made Plaintiff, who was clearly disoriented and bleeding
profusely from his face, stand against the side of Defendant Kandt’s patrol car while
Defendant Kandt finished processing the individual referenced in ¶12, who had been left
in the back of the patrol car throughout the entire ‘arrest’ of Plaintiff.
26. Outside of the car, Defendants finally asked Plaintiff to show some
identification. Plaintiff, still in handcuffs, politely explained to the officers that he had two
ID’s (his Maine ID and his Danish ID) and that these were both in his back pocket.
27. After being placed in the back of the police car, an ambulance arrived on
the scene, at which time Defendants told EMS that Plaintiff had been assaulted by a blunt
object to his head, lost consciousness, and fell to the ground.
28. Plaintiff was transferred from the back of Defendant Kandt’s police car to
the ambulance and taken to the University of Michigan Emergency Department.
29. It was not until around 5:00 AM the next morning (November 16, 2018)
when Plaintiff regained sufficient consciousness that he was informed of what had
happened the prior evening.
GENERAL ALLEGATIONS
30. While being arrested and while in police custody, Defendants used and/or
authorized or ratified the use of excessive and unnecessary force on Plaintiff without
cause, warning and/or reason under the circumstances, and/or were otherwise
deliberately indifferent to and violated Plaintiff’s Constitutional rights.
31. At no time while Plaintiff was in custody and/or being arrested was he
physically abusive to Defendants, nor did Plaintiff otherwise provoke Defendants to use
excessive force upon him.
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32. Defendants, individually and collectively, promulgated and/or carried out the
acts and omissions described herein, under color of Defendant City’s and/or AAPD’s
official policies, practice, orders, directives, or customs, which tolerated, authorized,
and/or permitted insufficient supervision, training, placement, and discipline of Defendant
City and AAPD police officers and have caused and/or allowed individuals, including
Plaintiff, to be arrested without justifiable cause and subjected to excessive and
unnecessary force by said officer(s).
33. The acts and/or omissions of Defendants were intentional and amounted to
gross negligence, with wanton and reckless disregard and deliberate indifference to
Plaintiff’s rights and the rights of the citizens with whom the members of the Ann Arbor
Police come into contact. Therefore, Plaintiff has pled in avoidance of governmental
immunity, and the Defendants City and AAPD are liable for the actions and omissions of
their officers under the Doctrine of Vicarious Liability/Respondeat Superior, as well
as for their own grossly negligent acts and/or omissions in relation to the events described
herein.
COUNT I – 42 U.S.C. § 1983 CLAIM
AGAINST DEFENDANTS PULFORD, KANDT, SCOTT, SHAFER, & CHINN
Plaintiff realleges and incorporates by reference every allegation stated above, as
though fully stated below, and further alleges:
34. At all times relevant, Plaintiff had the right to be protected from the use of
excessive force and unreasonable search and seizure, as guaranteed by the Fourth
Amendment to the United States Constitution and incorporated against the States by the
Fourteenth Amendment.
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35. The acts and/or omissions of Defendants described herein were for the very
purpose of causing harm, with callous and/or reckless disregard or deliberate indifference
for Plaintiff’s rights, health, and safety, and substantial risk of serious harm.
36. In committing these acts and/or omissions, Defendants deprived Plaintiff of
the following clearly established and well-settled rights, privileges and immunities
guaranteed under the Fourth and Fourteenth Amendments to the Constitution of the
United States:
a. Freedom from the use of excessive and unreasonable force in
violation of Plaintiffs Fourth Amendment rights;
b. Equal protection of the law and rights, privileges and immunities of
citizens of the United States and the State of Michigan, including
such rights as free speech, assembly, association and movement,
and due process; and
c. Otherwise violating the rights of Plaintiff.
37. Defendants subjected Plaintiff to these deprivations of rights for the very
purpose of causing harm, or by acting with callous and/or reckless disregard and with
deliberate indifference as to whether Plaintiff’s rights would be violated by their conduct.
38. As a direct and proximate result of the aforementioned acts and/or
omissions of the Defendants, Plaintiff has suffered medical expenses, legal expenses and
other out-of-pocket costs, and pain and suffering from physical and mental injuries,
including but not limited to:
a. Multiple contusions, bruises, abrasions, lacerations, and other
injuries to the neck, back, arms, eyes, head, and body;
b. Emotional and psychological injuries including but not limited to fear,
anxiety, trauma, humiliation, mortification, shock, stress, loss of
social pleasure and enjoyment, and other severe emotional
disturbances; and
c. Other injuries to be determined during the course of discovery.
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WHEREFORE, Plaintiff requests judgment against Defendants, jointly and
severally, in whatever amount in excess of Seventy-Five Thousand Dollars ($75,000.00)
Plaintiff is found to be entitled, as well as a demand for punitive and/or exemplary
damages to the extent they are not duplicative, together with interest, costs, and attorney
fees so wrongfully incurred as a result of this incident.
COUNT II – 42 U.S.C. § 1983 CLAIM
AGAINST DEFENDANTS CITY & AAPD
Plaintiff realleges and incorporates by reference every allegation stated above, as
though fully stated below, and further alleges:
39. Defendants City and AAPD have, with deliberate indifference to Plaintiff’s
rights and the rights of persons with whom members of the Ann Arbor Police Department
come into contact, caused Plaintiff to be deprived of his Constitutional rights under the
Fourth and Fourteenth Amendments to the United States Constitution by maintaining
policies, practices and customs that were a direct and/or proximate cause of the
deprivation of Plaintiff’s Constitutional rights.
40. Defendants City and AAPD have, as a matter of custom, policy and/or
practice, failed to adequately screen, train, supervise, discipline, transfer, counsel or
otherwise direct or control police officers concerning the rights of citizens with whom the
police come into contact, including Plaintiff, as described herein, thereby promoting,
permitting, or otherwise causing or contributing to the deprivation of Plaintiff’s
Constitutional rights.
41. As a direct and proximate result of Defendants’ acts and/or omissions,
Plaintiff has suffered medical expenses, legal expenses and other out-of-pocket costs,
and pain and suffering from physical and mental injuries, including but not limited to:
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a. Multiple contusions, bruises, abrasions, lacerations, and other
injuries to the neck, back, arms, eyes, head, and body;
b. Emotional and psychological injuries including but not limited to fear,
anxiety, trauma, humiliation, mortification, shock, stress, loss of
social pleasure and enjoyment, and other severe emotional
disturbances; and
c. Other injuries to be determined during the course of discovery.
WHEREFORE, Plaintiff requests judgment against Defendants, jointly and
severally, in whatever amount in excess of Seventy-Five Thousand Dollars ($75,000.00)
Plaintiff is found to be entitled, as well as a demand for punitive and/or exemplary
damages to the extent they are not duplicative, together with interest, costs, and attorney
fees so wrongfully incurred as a result of this incident.
SUPPLEMENTAL JURISDICTION (28 U.S.C. § 1367) – STATE LAW CLAIMS
COUNT III – ASSAULT & BATTERY
AGAINST DEFENDANTS KANDT & SCOTT
Plaintiff realleges and incorporates by reference every allegation stated above, as
though fully stated below, and further alleges:
42. The conduct of Defendants described herein, both individually, and as
employees of the Defendants City and AAPD acting in the course and scope of their
employment as police officers, constituted assault and battery.
43. Defendants placed Plaintiff in a great fear of harmful physical contact, and
acted intending to cause willful, harmful or offensive touching, which Defendants
accomplished through threatening, striking, and using excessive force on Plaintiff against
his will and without his consent.
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44. At no time was it necessary to use force against Plaintiff, and the excessive
force used by the Defendants was entirely unreasonable, and was not justified by any
action of Plaintiff.
45. Defendants’ conduct described herein was not privileged, was not carried
out for any proper purpose, and was not within the scope of Defendants’ authority as law
enforcement.
46. As a direct and proximate result of Defendants’ assault and battery, Plaintiff
has suffered medical expenses, legal expenses and other out-of-pocket costs, and pain
and suffering from physical and mental injuries, including but not limited to:
a. Multiple contusions, bruises, abrasions, lacerations, and other
injuries to the neck, back, arms, eyes, head, and body;
b. Emotional and psychological injuries including but not limited to fear,
anxiety, trauma, humiliation, mortification, shock, stress, loss of
social pleasure and enjoyment, and other severe emotional
disturbances; and
c. Other injuries to be determined during the course of discovery.
WHEREFORE, Plaintiff requests judgment against Defendants, jointly and
severally, in whatever amount in excess of Seventy-Five Thousand Dollars ($75,000.00)
Plaintiff is found to be entitled, as well as a demand for punitive and/or exemplary
damages to the extent they are not duplicative, together with interest, costs, and attorney
fees so wrongfully incurred as a result of this incident.
COUNT IV – GROSS NEGLIGENCE
AGAINST DEFENDANTS PULFORD, KANDT, SCOTT, SHAFER, & CHINN
Plaintiff realleges and incorporates by reference every allegation stated above, as
though fully stated below, and further alleges:
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47. At all times relevant, Defendants owed Plaintiff the following duties and
obligations, among others:
a. The duty to use verbal means such as advice, warning, or persuasion
before resorting to force;
b. The duty to refrain from using force where such force was not
reasonable and/or necessary;
c. The duty to exhaust all reasonable alternatives before using force,
including but not limited to requesting assistance and/or backup
before utilizing force as a means of coercion;
d. The duty to use only such force as was necessary and reasonable
under the circumstances;
e. The duty to exercise restraint in difficult situations and to analyze the
situation and react in a professional manner; and
f. Other duties to be identified.
48. Through their conduct, Defendants breached the duties owed to Plaintiff in
the following manners, among others:
a. Failing to use verbal means such as advising, warning, or persuasion
before resorting to use of force;
b. Applying force in an amount greatly in excess to that force which the
situation reasonably demanded, if any;
c. Continuing to use excessive force against Plaintiff over a period of
time;
d. Failing to exhaust all reasonable alternatives before using force;
e. Failing to exercise restraint and failing to act in a professional
manner;
f. Failing to prevent and/or ratifying the improper arrest of Plaintiff
through use of excessive force;
g. Humiliating and/or mortifying Plaintiff through their application of
excessive force and continued use of such excessive force over a
period of time;
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h. Allowing Plaintiff to be further humiliated through their threatening,
abusive, and demeaning actions towards Plaintiff after using such
excessive force against Plaintiff;
i. Engaging in conduct so reckless as to demonstrate a substantial lack
of concern for whether an injury resulted;
j. Showing reckless disregard for Plaintiff’s dignity, health, and safety,
as well as his Constitutional and statutory rights, by forcing Plaintiff
into the ground with excessive force, handcuffing Plaintiff, placing
Plaintiff in the backseat of Defendant Kandt’s patrol car while
handcuffed, and failing to take any affirmative action to protect
Plaintiff from a substantial risk of serious harm; and
k. Other acts and/or omissions constituting gross negligence.
49. The conduct of Defendants, as described herein, amounts to gross
negligence as that term is used and defined under MCL 691.1407(2)(c) & (8)(a).
50. As a direct and proximate result of the gross negligence of the Defendants,
Plaintiff has suffered medical expenses, legal expenses and other out-of-pocket costs,
and pain and suffering from physical and mental injuries, including but not limited to:
a. Multiple contusions, bruises, abrasions, lacerations, and other
injuries to the neck, back, arms, eyes, head, and body;
b. Emotional and psychological injuries including but not limited to fear,
anxiety, trauma, humiliation, mortification, shock, stress, loss of
social pleasure and enjoyment, and other severe emotional
disturbances; and
c. Other injuries to be determined during the course of discovery.
WHEREFORE, Plaintiff requests judgment against Defendants, jointly and
severally, in whatever amount in excess of Seventy-Five Thousand Dollars ($75,000.00)
Plaintiff is found to be entitled, as well as a demand for punitive and/or exemplary
damages to the extent they are not duplicative, together with interest, costs, and attorney
fees so wrongfully incurred as a result of this incident.
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COUNT V – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AGAINST DEFENDANTS PULFORD, KANDT, SCOTT, SHAFER, & CHINN
Plaintiff realleges and incorporates by reference every allegation stated above, as
though fully stated below, and further alleges:
51. The conduct of Defendants, as described herein, was extreme and
outrageous, beyond all possible bounds of decency, and of such character as to be
intolerable in a civilized society.
52. Defendants’ conduct was not privileged, was not carried out for any proper
purpose, and was not within the scope of Defendants’ authority as law enforcement.
53. Through their conduct described herein, Defendants intentionally and/or
recklessly caused Plaintiff to suffer severe mental and emotional distress.
54. As a direct and proximate result of the Defendants’ intentional infliction of
emotional distress, Plaintiff has suffered medical expenses, legal expenses and other out-
of-pocket costs, and pain and suffering from physical and mental injuries, including but
not limited to:
a. Multiple contusions, bruises, abrasions, lacerations, and other
injuries to the neck, back, arms, eyes, head, and body;
b. Emotional and psychological injuries including but not limited to fear,
anxiety, trauma, humiliation, mortification, shock, stress, loss of
social pleasure and enjoyment, and other severe emotional
disturbances; and
c. Other injuries to be determined during the course of discovery.
WHEREFORE, Plaintiff requests judgment against Defendants, jointly and
severally, in whatever amount in excess of Seventy-Five Thousand Dollars ($75,000.00)
Plaintiff is found to be entitled, as well as a demand for punitive and/or exemplary
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damages to the extent they are not duplicative, together with interest, costs, and attorney
fees so wrongfully incurred as a result of this incident.
COUNT VI – NEGLIGENT SUPERVISION AND TRAINING
AGAINST DEFENDANTS CITY & AAPD
Plaintiff realleges and incorporates by reference every allegation stated above, as
though fully stated below, and further alleges:
55. At all times relevant, Defendants City and AAPD owed Plaintiff, and the
public in general, a duty to exercise proper care in adequately hiring, screening, training,
supervising, disciplining, transferring, or otherwise directing or controlling their police
officers, including Defendant Police Officers, in regard to the rights of citizens, including
Plaintiff, to be free from the use of excessive force and/or false arrest and imprisonment.
56. Defendant City and AAPD, by and through by and through their staff
sergeants, police officers, and other employees, agents and/or assigns, including
Defendant Police Officers, have, as a matter of custom and/or policy and practice and
with deliberate indifference to Plaintiff’s rights and the rights of the citizens with whom the
members of the Ann Arbor Police come into contact, caused and/or allowed individuals,
including Plaintiff, to be arrested without justifiable cause and subjected to excessive and
unnecessary force by said officer(s).
57. Defendant City and AAPD, by and through by and through their staff
sergeants, police officers, and other employees, agents and/or assigns, breached the
duties owned to Plaintiff in the following manners, among others:
a. Failing to adequately train, screen, supervise, discipline, transfer,
counsel, or otherwise direct or control their Police Officers in regard
to the rights of citizens, including Plaintiff, to be free from the use of
excessive force and/or false arrest and imprisonment.
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b. Causing and/or allowing individuals, including Plaintiff, as a matter of
custom, policy and/or practice, to be arrested without justifiable
cause and subjected to excessive and unnecessary force by said
officer(s), with deliberate indifference to Plaintiff’s rights and the
rights of the citizens with whom the members of the Ann Arbor Police
come into contact
58. The acts and/or omissions of Defendants described herein amount to gross
negligence as that term is used and defined under MCL 691.1407(2)(c) & (8)(a), and said
gross negligence is an exception to governmental immunity.
59. As a direct and proximate result of Defendants’ acts and/or omissions,
Plaintiff has suffered medical expenses, legal expenses and other out-of-pocket costs,
and pain and suffering from physical and mental injuries, including but not limited to:
a. Multiple contusions, bruises, abrasions, lacerations, and other
injuries to the neck, back, arms, eyes, head, and body;
b. Emotional and psychological injuries including but not limited to fear,
anxiety, trauma, humiliation, mortification, shock, stress, loss of
social pleasure and enjoyment, and other severe emotional
disturbances; and
c. Other injuries to be determined during the course of discovery.
WHEREFORE, Plaintiff requests judgment against Defendants, jointly and
severally, in whatever amount in excess of Seventy-Five Thousand Dollars ($75,000.00)
Plaintiff is found to be entitled as adequate compensation for all the injuries and damages
he has sustained, as well as a demand for punitive and/or exemplary damages to the
extent they are not duplicative, together with interest, costs, and attorney fees so
wrongfully incurred as a result of this incident.
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Respectfully Submitted,
THE COREY LAW FIRM
/ s / Louis G. Corey
LOUIS G. COREY (P34377)
Attorney for Plaintiff
401 N. Main Street
Royal Oak, MI 48067
(248) 548-9700
Dated: February 25, 2020
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
DREW PARSONS,
Plaintiff,
vs. Case No: 2020- -
Hon.
CITY OF ANN ARBOR, a municipal
corporation, ANN ARBOR POLICE
DEPARTMENT, SGT. MARK J.
PULFORD JR., OFFICER JUSTIN J.
KANDT, OFFICER RYAN M. SCOTT,
OFFICER JEFFREY D. SHAFER JR., and
OFFICER ERIC D. CHINN,
Defendants.
LOUIS G. COREY (P34377)
JOHN P. MEADS (P82914)
Attorneys for Plaintiff
401 N. Main Street,
Royal Oak, Michigan 48067
(248) 548-9700
lou@coreylawfirm.com
john@coreylawfirm.com
DEMAND FOR JURY TRIAL
NOW COMES Plaintiff, Drew Parsons, by and through his attorneys, THE COREY
LAW FIRM, and hereby demands a trial by jury of the above matter.
Respectfully Submitted,
THE COREY LAW FIRM
/ s / Louis G. Corey
LOUIS G. COREY (P34377)
Attorney for Plaintiff
401 N. Main Street
Royal Oak, MI 48067
(248) 548-9700
Dated: February 25, 2020
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