Page 2 of 54.
Monroe County, Tennessee is a political subdivision of the State of Tennessee. Itcan be served with process through the County Mayor, Tim Yates, 105 College Street,Madisonville, TN 37354.5.
This Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C.§§ 1331 and 1343(a).6.
All of the material conduct which forms the subject matter of this Complaint took place in Monroe County, Tennessee, and all defendants are believed to be residents of MonroeCounty, Tennessee; therefore, this Court has personal jurisdiction over the Defendants.7.
Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b)(1) and (2).8.
On May 26, 2010 a Writ of Execution was issued by Michael W. Catalano, Clerk of the Tennessee Supreme Court, to recover court costs taxed to George Joseph Raudenbush, III
, in the amount of $469.50. A true and correct copy of the Fieri Facias/Writof Execution
(the “Writ of Execution”)
is attached here to as Exhibit 1.9.
On June 8, 2010 the Monroe County Sheriff’s Department, a department within
the government of defendant Monroe County, Tennessee, at the direction of defendant Bivens,seized a 45-
foot tool workshop/trailer (the “Trailer”), VIN EF2157482M, containing vari
oustools and other items utilized by the Plaintiffs in their missions projects. The Trailer andcontents are believed by the Plaintiffs to have a value of at least $100,000.10.
The Trailer was seized by the Defendants under the purported authority of theWrit of Execution.11.
At the time the Trailer was seized and presently, the Trailer was owned by thePlaintiffs. At the time the Trailer was seized and presently, Mr. Raudenbush had no ownershipinterest in the Trailer.
Case 3:11-cv-00220 Document 1 Filed 05/13/11 Page 2 of 5 PageID #: 2