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IN THE UNITED STATES DISTRICT COURT

DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION

Brenda Inabinette, ) Case No.: 3:25−cv−00800-SAL-PJG

)
)
Plaintiff, )
)
v. )
)
COMPLAINT
Lexington County Sheriff’s Office, )
Lexington School District One, and )
(Jury Trial Requested)
SHELLEY COLLINS, in her
Individual Capacity,
)
Defendants. )

COMPLAINT

The Plaintiff, Brenda D. Inabinette, by and through her undersigned counsel,

complaining of the Defendants Lexington County Sheriff’s Office, Lexington School

District One, and Shelley Collins, in her individual capacity, (“Defendants”), would

respectfully show unto this Honorable Court:

PARTIES & BACKGROUND

Plaintiff

1. That Plaintiff, Brenda D. Inabinette, (hereinafter “Plaintiff”), is and was a

citizen and resident of the County of Lexington, State of South Carolina at all times relevant

herein. Further, Plaintiff, at nearly all times relevant herein, was a teacher employed by

Defendant Lexington School District One.

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Lexington County Sheriff’s Office

2. Defendant Lexington County Sheriff’s Office is a political subdivision of

the State of South Carolina, existing under the laws of the State of South Carolina (as

defined by Section 15-78-10 of the Code of Laws of South Carolina (1985), as amended).

3. At all times relevant herein, Defendant Lexington County Sheriff’s Office

operated and controlled the Lexington County Sheriff’s Office, and acted and carried on

their business by and through their agents, servants, and/or employees who were operating

within the scope of their officially assigned and/or compensated duties.

4. That Defendant Lexington County Sheriff’s Office is being sued in its

representative capacity pursuant to the South Carolina Tort Claims Act that makes the

employing entity liable for the torts of its employees and agents (S.C. Code §15-78-70).

Plaintiffs allege that Defendant Lexington County Sheriff’s Office is liable for the acts and

omissions of its employees, agents, servants, and contractors for the negligence, gross

negligence, recklessness, and other liability forming conduct, actions, and inactions that

caused the harm to Plaintiff.

5. That the negligent and grossly negligent acts, omissions, and liability

forming conduct, actions, and inactions of Defendant Lexington County Sheriff’s Office

include their agents, principals, employees and/or servants, both directly and vicariously,

pursuant to principles of non-delegable duty, apparent authority, agency, ostensible agency

and/or respondeat superior and the acts and/or omissions of the abovenamed Defendant

was the direct and proximate cause of the injuries, damages, and losses to Plaintiff.

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Lexington School District One

6. That upon information and belief, the Defendant Lexington School District

One is a school district operated as a subdivision of Lexington County Government and is

a governmental agency with its principal place of business located in the County of

Lexington, State of South Carolina, and is responsible for the actions or inactions of its

agents, servants, contractors, volunteers, and employees.

7. That upon information and belief the majority, if not all, of the events to

this claim, took place at White Knoll Middle School.

8. That Defendant Lexington School District One is being sued in its

representative capacity pursuant to the South Carolina Tort Claims Act that makes the

employing entity liable for the torts of its employees and agents (S.C. Code §15-78-70).

Plaintiffs allege that Defendant Lexington School District One is liable for the acts and

omissions of its employees, agents, servants, and contractors for the negligence, gross

negligence, recklessness, and other liability forming conduct, actions, and inactions that

caused the harm to Plaintiff.

9. The negligent and grossly negligent acts, omissions, and liability forming

conduct, actions, and inactions of Defendant Lexington School District One include their

agents, principals, employees and/or servants, both directly and vicariously, pursuant to

principles of non-delegable duty, apparent authority, agency, ostensible agency and/or

respondeat superior and the acts and/or omissions of the abovenamed Defendant was the

direct and proximate cause of the injuries, damages, and losses to Plaintiff.

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Shelley R. Collins

10. Upon information and belief, Defendant Shelley R. Collins (hereinafter

referred to as “Shelley Collins”) is a resident and citizen of South Carolina and was an

agent, servant, and/or employee of Defendant Lexington County Sheriff’s Office at all

times relevant herein. Specifically, Shelley Collins, at all times relevant herein, was

employed by the Lexington County Sheriff’s Office as a police officer. For purposes of

this action, Officer Collins is being sued in her individual capacity under the color of state

law. Furthermore, Defendant Shelley Collins was aware of Plaintiff’s constitutional rights,

which she had violated.

JURISDICTION AND VENUE

11. This court has a federal question and supplemental jurisdiction pursuant to

28 U.S.C. § 1331 and 28 U.S.C. § 1367 because: (i) the federal law claims arising under

the constitution and statutes of the United States; and (ii) the state law claims are so closely

related to the federal law claims as to form the same case or controversy under Article III

of the United States Constitution.

12. Venue in this action properly lies in this district pursuant to 28 U.S.C. §1391

because the Defendants are considered to reside in this judicial district and the separate and

distinct acts and occurrences giving rise to the claims occurred in this judicial district.

FACTUAL ALLEGATIONS APPLICABLE TO ALL CLAIMS

13. That Plaintiff incorporates herein by reference all the allegations contained in

the above paragraphs and throughout this entire Complaint as though the same were fully set

forth herein at length.

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14. That upon information and belief, and at all times relevant herein,

Defendant Officer Shelley Collins was an employee and servant of Defendant Lexington

County Sheriff’s Office as a police officer and public official making her under the direct

control and supervision of Defendant Lexington County Sheriff’s Office.

15. At all times relevant herein, Defendant Shelley Collins used the resources,

power, and authority of her office to obtain a warrant for Plaintiff’s arrest maliciously and

without sufficient probable cause in violation of the constitutional rights of Plaintiff.

16. That upon information and belief, and at all times relevant herein,

Defendant Shelley Collins was on duty, in uniform, wearing a badge, and/or acting under

the color of law in the course and scope of her employment.

17. That upon information and belief, and at all times relevant herein,

Defendant Lexington County Sheriff’s Office had the ability to control or should have

known they had the ability to control Defendant Officer Shelley Collins, making them also

liable for her acts and conduct.

18. That upon information and belief, and at all times herein, Defendant

Lexington County Sheriff’s Office knew or should have known of the necessity and

opportunity to exercise control of Defendant Shelley Collins.

19. That upon information and belief, and at all times relevant herein,

Defendant Lexington School District One employees Donald Hardie, Margaret Schilit, and

Daniel Bailey were employees and servants of Defendant Lexington School District One

as school administrators making them under direct control and supervision of Defendant

Lexington School District One.

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20. That upon information and belief, and at all times herein, Defendant

Lexington School District One knew or should have known of the necessity and

opportunity to exercise control over their employees, including but not limited to

administrators Donald Hardie, Margaret Schilit, and Daniel Bailey.

21. On or about August 25, 2022, Plaintiff was acting in the course and scope

of her employment as a schoolteacher at White Knoll Middle School in Lexington County,

South Carolina. On this day, Plaintiff was falsely accused by a middle school student of

assaulting him. The alleged incident was not witnessed by any teachers, administrators, or

school resource officers.

22. Following the incident, White Knoll Middle School administrator Daniel

Bailey allegedly retrieved a statement from the middle school student who allegedly

accused Plaintiff of assault. The statement was typed by administrator Daniel Bailey and

was highly editorialized using exaggerated adjectives and language that would later be

directly published by the news media in their reporting of the incident. Further, the

statement was written by administrator Daniel Bailey as if he witnessed the details he

typed.

23. Following the alleged incident, Principal Don Hardie asked Plaintiff to

provide a written statement concerning the alleged incident. Furthermore, Principal Don

Hardie informed Plaintiff that said statement would not be used in any criminal prosecution

of Plaintiff. Accordingly, Plaintiff provided a written statement contradicting the false

allegations she was accused of committing. Nevertheless, Principal Don Hardie

subsequently forwarded Plaintiff’s statement to Shelley Collins.

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24. At some point after retrieving the written statement from Principal Don

Hardie, Defendant Shelley Collins used the written statement provided by Plaintiff and the

written statement typed by administrator Daniel Bailey to obtain a warrant for Plaintiff's

arrest. At no point did Shelley Collins conduct an independent investigation by seeking to

speak with Plaintiff about the alleged incident or other relevant witnesses. Shelley Collins

simply took the information she received and swore to them as fact in the application and

affidavit for an arrest warrant.

25. On or about August 29, 2022, a warrant for Plaintiff’s arrest was issued.

Plaintiff subsequently turned herself to the Lexington County Sheriff’s Office where she

was arrested, criminally charged with Assault and Battery 3rd Degree, fingerprinted, and

required to change into Lexington County Sheriff’s Office clothing. All without ever being

questioned by any member of law enforcement about the incident.

26. Following Plaintiff’s arrest, news media widely covered the incident, and

her good reputation was ruined. Further, Plaintiff would later have to retain several lawyers

to defend her against the criminal charges she was accused of and to assist her in the

employment dispute with Lexington School District One stemming from this incident.

27. On or about June 28, 2023, Plaintiff was acquitted by a jury of her peers and

found not guilty of Assault and Battery 3rd degree stemming from the false allegations

made against Plaintiff. At the trial of her case, Plaintiff was shocked and dismayed as she

learned details of her wrongful arrest and malicious prosecution stemming from the

unconstitutional actions of Shelly Collins along with the grossly negligent and reckless

actions of Defendants Lexington County Sheriff’s Office and Lexington School District

One.

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28. Despite Defendants Lexington County Sheriff’s Office and Lexington

School District One being aware that the arrest of Plaintiff based on false pretenses and

editorialized information was unlawful and unconstitutional and in violation of established

precedent, they continued to prosecute Plaintiff maliciously for the alleged criminal

offenses she was accused of.

29. Defendants initiated the criminal proceedings against Plaintiff and

maliciously prosecuted criminal proceedings against Plaintiff from the date of these

accusations on or about August 25, 2022, until on or about June 28, 2023, when Plaintiff

was found not guilty.

30. Plaintiff did not have the requisite knowledge to know that Defendants’

actions and inactions were done without the proper authority by law until after she was

acquitted by a jury on June 28, 2023.

31. That Plaintiff is informed and believes that Defendant Shelley Collins used

the resources and abused the power and authority of her office to obtain an arrest warrant

maliciously without sufficient probable cause and arrest Plaintiff in violation of her

constitutional rights.

32. Defendant Lexington County Sheriff’s Office and was also under a duty to

prevent Shelley Collins from harming Plaintiff, and/or conducting herself in a manner that

created an unreasonable risk of harm to citizens, including Plaintiff.

33. Notwithstanding information that was known or should have been known

by Defendant Lexington County Sheriff’s Office, continued to employ and retained

Defendant Officer Shelley Collins, and failed to properly train, monitor, and supervise

Defendant Shelley Collins.

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34. Furthermore, Defendant Lexington School District One through the actions

and inactions of their employees were further grossly negligent in their role in investigating

this matter and seeking the prosecution of Plaintiff. Lexington School District One was

further grossly negligent in failing to properly train, monitor, and supervise their agents,

employees, and servants who sought the prosecution of Plaintiff.

35. That as a direct and proximate result of Defendant's actions and/or inactions,

including Defendant Shelley Collins's actions in the malicious prosecution of Plaintiff,

Plaintiff suffered harm that included but was not limited to: violation of her constitutional

right under the Fourth Amendment to the United States Constitution to remain free from

unreasonable seizures through malicious prosecution, great and permanent mental harm

and injury, economic loss, emotional distress, anguish, distress, psychological trauma,

apprehension, anxiety, depression, embarrassment, fear, shame, humiliation, loss of wages,

loss of earning capacity, and a loss of enjoyment of life, which has and will in the future

cause her to spend money for mental health treatment services.

FOR A FIRST CAUSE OF ACTION AS TO DEFENDANTS LEXINGTON

COUNTY SHERIFF’S OFFICE AND LEXINGTON SCHOOL DISTRICT ONE
Gross Negligence

36. That Plaintiff incorporates herein by reference all the allegations contained in

the above paragraphs and throughout this entire Complaint as though the same were fully set

forth herein at length.

37. That Defendants were acting under the color or pretense of State law,

customs, practices, usage, or policy at all times mentioned herein by employing agents,

supervisors, or other such personnel and/or employees and had certain duties imposed upon

it with regard to Plaintiff.

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38. That Defendants acting through its agents and servants were grossly

negligent, careless, and reckless, at the time and place aforementioned in the following

particulars:

a) In arresting Plaintiff without probable cause;

b) In falsely arresting Plaintiff;

c) In arresting Plaintiff without sufficient grounds to make an arrest;

d) In ordering an arrest when there was no charge to arrest for;

e) In failing to properly train, supervise, and monitor its staff;

f) In violating established precedent and in arresting Plaintiff without probable

cause;

g) In failing to take that degree of skill and care which a reasonable and/or
prudent person would have done under the same or similar circumstances;

h) In arresting Plaintiff due to bias;

i) In failing to properly hire, train, and/or supervise its employees;

j) In failing to have adequate policies and procedures in place to protect citizens

from being arrested by officers without probable cause;

k) In failing to enforce their own internal rules, policies, procedures, and

standards;

l) In refusing the dismiss the allegations received and/or the criminal charges
after reviewing the evidence including statements;

m) In arresting Plaintiff without justification;

n) In the officer’s failure to conform her conduct to her training;

o) In exercising his discretion in a grossly negligent manner (see Duncan vs.

Hampton County School District # 2 335 S.C. 535, 517 S.E.2d 449 (S.C. App.
1999 “if discretion is exercised in a grossly negligent manner then the
government entity involved is liable for its torts as if it were a private
individual)

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p) In failing to exercise reasonable or slight care to protect Plaintiff from harm

at the hands of its personnel, agents, officers, and/or employees;

q) In failing to exercise reasonable or slight care to properly train and/or

supervise its personnel, agents, officers, and/or employees;

r) In failing to exercise reasonable or slight care to draft and/or institute

proper policy and procedure with regard to the hiring and evaluation of its
agents;

s) In failing to exercise reasonable or slight care to draft and/or institute proper

policy and procedure necessary to ensure that citizens were safe and
protected from racial profiling, harassment, ridicule, abuse, unlawful
searches and seizures, wrongful arrests, and threatening behavior by their
agents;

t) In failing to exercise reasonable or slight care to draft and/or institute proper

policy and procedure that would lead to the discovery of inappropriate,
threatening actions by its employees and prevent the same from occurring;

u) In failing to exercise reasonable or slight care to make periodic and proper

investigations and take remedial action as might be necessary to prevent
inappropriate, unlawful, and/or unconstitutional actions;

v) In failing to exercise reasonable or slight care to take the appropriate time

to follow-up, review, and/or check compliance with policy, state law, and/or
existing orders;

w) In failing to exercise reasonable or slight care to properly supervise their

agents, servants, and employees in this incident including, but not limited
to Shelley Collins;

x) In failing to exercise reasonable or slight care to provide Plaintiff with

proper protection from abuse (both physical and mental) at the hands of
their agents when it had notice of their agent’s propensities towards
inappropriate, unlawful, and/or unconstitutional actions;

y) In conducting themselves in an egregious and arbitrary manner;

z) In breaching their fiduciary duty of trust with regard to Plaintiff;

aa) In failing to follow and adhere to the local state and national standards,
policies, and procedures including the policies and procedures of the
Lexington County Sheriff’s Office and Lexington School District One;

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bb) In failing to follow and adhere to the policies and procedures of Lexington
County Sheriff’s Office and Lexington School District One;

cc) In engaging in a pattern and practice of allowing and/or condoning

inappropriate, unlawful, and unconstitutional conduct on behalf of the City
of Lexington County Sheriff’s Office Officer;

dd) In failing to sufficiently monitor and supervise employees at Lexington

County Sheriff's Office and Lexington School District One;

ee) In failing to have the appropriate policies and procedures in place to provide
adequate supervision;

ff) In negligently permitting agents to racially profile, harass, violate the

constitutional rights, and wrongfully arrest citizens, including Plaintiff;

gg) In failing to adopt, implement, enforce, and/or follow policies and/or

procedures for reasonable interaction with citizens;

hh) In failing to exercise even slight care to protect Plaintiff from harm; and

ii) In any other manner that Plaintiff may become aware of through discovery
and/or trial.

39. All of which were the direct and proximate cause of the damages suffered by

Plaintiff herein, said acts being in violation of the statutes and laws of the State of South

Carolina.

40. That as a direct and proximate result of Defendant's negligence, gross

negligence, carelessness, and/or recklessness, Plaintiff was harmed, suffered economic

loss, and sustained severe and permanent emotional distress, humiliation, mental anguish,

indignity, loss of pleasures and enjoyment of life which required and will in the future

require psychological and psychiatric medical care and treatment.

41. That as a direct and proximate result of Defendant's negligence and/or

recklessness, Plaintiff has and will likely, in the future, be caused to incur medical

expenses.

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42. That Plaintiff is informed and believes that she is entitled to ACTUAL and

CONSEQUENTIAL DAMAGES in an amount that would adequately compensate her for

their injuries and damages.

FOR A SECOND CAUSE OF ACTION AS TO DEFENDANTS LEXINGTON

COUNTY SHERIFF’S OFFICE AND LEXINGTON SCHOOL DISTRICT ONE
Grossly Negligent Supervision, Training, and Retention

43. That Plaintiff incorporates herein by reference all the allegations contained in

the above paragraphs and throughout this entire Complaint as though the same were fully set

forth herein at length.

44. That Defendants were acting under the color or pretense of State law,

customs, practices, usage, or policy at all times mentioned herein by employing agents,

supervisors, or other such personnel and/or employees and had certain duties imposed upon

it with regard to Plaintiff.

45. That Plaintiff is informed and believes that Defendant through the

negligent, reckless, wanton, outrageous, and grossly negligent conduct of its employees are

further negligent, willful, careless, reckless, and grossly negligent in one or more of the

following particulars:

a) In failing to exercise the degree of care that a reasonable employer would have
exercised under the same or similar circumstances;

b) In failing to conduct a proper and adequate background search or review of its

employees before and after hiring;

c) In failing to monitor the conduct of its employees and to take appropriate

steps to discipline and/or terminate them subsequent to the commissions of
negligent, outrageous, willful, wanton, reckless, grossly negligent, and/or
unlawful acts;

d) In failing to properly supervise its employees;

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e) In failing to have in place adequate policies and procedures to monitor its

employees, and if such policies and procedures were in place, in failing to
enforce them;

f) In failing to have in place adequate policies and procedures to mandate

compliance by its employees with state and federal guidelines, statutes, laws,
and regulations, and if such policies and procedures were in place, in failing
to enforce them;

g) In any other such manner that Plaintiff may become aware of through
discovery and/or at trial.

46. That all of which were the direct and proximate cause of the damages suffered

by the Plaintiff herein, said acts being in violation of the laws of the State of South Carolina.

47. That Plaintiff's injuries were of such nature as to require her to expend monies,

to receive additional medical attention, and to require medical necessities.

48. That Plaintiff has suffered and will continue to suffer physical pain,

humiliation, mental anguish, emotional distress, medical expenses, wage loss, and loss of

enjoyment of life.

49. That Plaintiff is informed and believes that she is entitled to ACTUAL and

CONSEQUENTIAL DAMAGES in an amount that would adequately compensate her for

their injuries and damages.

FOR A THIRD CAUSE OF ACTION AS TO DEFENDANT LEXINGTON

COUNTY SHERIFF’S OFFICE
State Law False Imprisonment and Malicious Prosecution

50. That Plaintiff incorporates herein by reference all the allegations contained in

the above paragraphs and throughout this entire Complaint as though the same were fully set

forth herein at length.

51. That Defendants were acting under the color or pretense of State law,

customs, practices, usage, or policy at all times mentioned herein by employing agents,

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supervisors, or other such personnel and/or employees and had certain duties imposed upon

it with regard to Plaintiff.

52. That the Lexington County Sheriff’s Office has a police department and that

officers and/or agents of the Lexington County Sheriff’s Office did arrest Plaintiff without

probable cause.

53. That on or about August 29, 2022, Plaintiff was arrested by officers and/or

employees of the Lexington County Sheriff’s Office.

54. That all criminal charges were dismissed on or about June 23, 2023.

55. That the wrongful arrest and false imprisonment of Plaintiff resulted in her

being taken to the Detention Center and further resulted in her sustaining additional

damages as described herein.

56. That Plaintiff eventually bonded out of jail and the criminal charges were

dismissed.

57. That Plaintiff brings this cause of action against Lexington County Sheriff’s

Office for its wrongful acts.

58. That Lexington County Sheriff’s Office, through its officers, agents, and/or

employees, was negligent, reckless, willful, and wanton, in one or more of the following

particulars:

a) In arresting Plaintiff without probable cause;

b) In falsely arresting Plaintiff;

c) In arresting Plaintiff without evidence;

d) In ordering an arrest when Defendants’ obtained said alleged evidence

improperly and in violation of Plaintiff’s constitutional rights;

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e) In violating established precedent and in arresting Plaintiff without probable

cause;

f) In failing to take the degree of skill and care that a reasonable and/or prudent
person would have done under the same or similar circumstances;

g) In arresting Plaintiff without proof and based on innuendo and/or rumors; and

h) In any other such manner that Plaintiff may become aware of through
discovery and/or at trial.

59. That as a direct and proximate result of Defendants’ negligent and/or reckless

acts; Plaintiff suffered injuries and damages as further described herein, including but not

limited to losing her housing.

60. That as a direct and proximate result of Defendants’ negligent and/or reckless

acts; Plaintiff suffered severe emotional distress/mental anguish that no reasonable person

should expect to endure.

61. That Plaintiff’s emotional distress/mental anguish was of such nature so as to

require them to expend monies, to receive additional medical attention, and to require medical

necessities.

62. That Plaintiff has suffered and will continue to suffer physical pain,

humiliation, mental anguish, emotional distress, medical expenses, wage loss, and loss of

enjoyment of life.

63. That Plaintiff is informed and believes that she is entitled to ACTUAL,

CONSEQUENTIAL in an amount that would adequately compensate her for her severe

emotional distress/mental anguish, injuries, and damages.

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FOR A FOURTH CAUSE OF ACTION

AS TO DEFENDANT SHELLEY COLLINS
Malicious Prosecution/Prosecution Without Probable Cause
Under 42 U.S.C. § 1983

64. That Plaintiff incorporates herein by reference all the allegations contained in

the above paragraphs and throughout this entire Complaint as though the same were fully set

forth herein at length.

65. That during the time period in question, Plaintiff had the right under the

Fourth Amendment to not be prosecuted without probable cause. See Durham v. Horner,

690 F.3d 183 (4th Cir. 2012).

66. That during the time period in question, Defendant Shelley Collins was well

aware that probable cause did not exist to arrest and prosecute Plaintiff, intentionally,

recklessly, and with malice causing Plaintiff to be arrested, held on bail, and prosecuted.

67. Defendant Shelley Collins knew she obtained a warrant for Plaintiff’s arrest

maliciously and that Plaintiff was arrested without probable cause and that Defendants did

not have probable cause to prosecute Plaintiff for the alleged charges that were instituted

against her.

68. That Defendant Shelley Collins failed to inform all persons associated in

issuing the warrant for Plaintiff’s arrest and the Court in the prosecution of Plaintiff about

the lack of probable cause in arresting and prosecuting Plaintiff and upon information and

belief, made false or misleading information and material omissions in there statements to

the Lexington County Sheriff’s Department, and Magistrate Judge.

69 That as a direct and proximate cause of Defendant Shelley Collins’ actions

and inactions, Plaintiff was arrested, charged, and prosecuted without probable cause.

70. That all of the charges stemming from Defendant Shelley Collins’ malicious

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prosecution and obtaining a warrant for the arrest of Plaintiff were when Plaintiff was

found not guilty by a jury on June 23, 2023.

71. That as a direct and proximate cause of Defendants’ actions and inactions,

Plaintiff has been injured and damaged in that she has been deprived of the rights,

privileges, and immunities afforded to the citizens of the State of South Carolina and the

United States; has been subject to economic loss, psychological injury; has endured and

will endure mental anguish and emotional distress; has incurred expenses, and medical

bills, and will incur expenses and medical bills in the future; has been deprived of the

enjoyment of her life, thereby entitling her to an award of ACTUAL, CONSEQUENTIAL,

PUNITIVE DAMAGES, costs, and reasonable attorney fees.

RELIEF REQUESTED

72. That Plaintiff incorporates herein by reference all the allegations contained in

the above paragraphs and throughout this entire Complaint as though the same were fully set

forth herein at length.

73. WHEREFORE, Plaintiff demands a trial by jury as provided for in the

Seventh Amendment to the Constitution of the United States of America and prays for

judgment against the Defendants both jointly and in combination as follows:

a. Actual damages on all causes of action;

b. Incidental damages on all causes of action;

c. Consequential damages on all causes of action;

d. Punitive damages on the FOURTH cause of action;

e. For reasonable attorney’s fees and the costs and expenses of this action pursuant to
28 U.S.C. § 1988; and

f. For such other and further relief as the court may deem just and proper.

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Respectfully submitted,

s/Tyler D. Bailey
Federal ID #12294
BAILEY LAW FIRM, L.L.C.
1430 Richland Street (29201)
P.O. Box 532
Columbia, South Carolina 29202
Telephone: (803) 667-9716
Facsimile: 1-803-526-7642
Email: tyler@baileylawfirmsc.com

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