IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF GEORGIABRUNSWICK DIVISIONTHURMISHA R. PRICE,**Plaintiff,***-VS-**MICHAEL KANAGO, JOEY HYER,*CAMERON ARNOLD, RESDEN* TALBERT, and DAVID HANEY in*CIVIL ACTION NO.: CV219- TheirIndividual and Official Capacities*as Officers of the Glynn County Police *Department; ROBERT BRICE SASSER,*in his Capacity as Personal *Representative of the Estate of ROBERT*CLIFTON (COREY) SASSER; and*GLYNN COUNTY, GEORGIA,**Defendants.*COMPLAINT FOR DAMAGESTHURMISHA R. PRICE

, Plaintiff in the above-styled action, files this her Complaint for Damages and for compensatory and punitive damages against Defendants

MICHAEL KANAGO

,

JOEY HYER 

,

 CAMERON ARNOLD

,

 RESDEN TALBERT

,

 

and

 DAVID HANEY

 

in TheirIndividual and Official Capacities as Officers of the Glynn County Police Department;

and

ROBERT BRICE SASSER, in his Capacity as Personal Representative of the Estate of ROBERT CLIFTON (COREY) SASSER; AND GLYNN COUNTY, GEORGIA

.Page 1 of 22

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I. INTRODUCTION-1-

Plaintiff

THURMISHA R. PRICE

, brings this action against Defendants to compensate her for damages and injuries suffered through her wrongful arrest and prosecution by Defendantsand to punish the appropriate Defendants, for their wrongful acts against

THURMISHA R. PRICE

such that it will prevent

DEFENDANTS

 from subjecting others to such wrongful and egregiousconduct.

-2-MS. PRICE

 brings this action under the Fourth and Fourteenth Amendments to the UnitedStates Constitution, the Civil Rights Act of 1871, as amended and codified at 42 U.S.C. §1983, 28U.S.C. § 1343, 28 U.S.C. § 1331, false arrest and malicious prosecution, under federal law and 42U.S.C. §1983.

-3-MS. PRICE

seeks damages for violation of her rights protected by the Fourth andFourteenth Amendments to the United States Constitution, the Civil Rights Act of 1871, asamended and codified at 42 U.S.C. §1983, 28 U.S.C. § 1343, 28 U.S.C. § 1331, false arrest,malicious arrest, false imprisonment, and malicious prosecution, under 42 U.S.C. §1983.

-4-MS. PRICE

demands a trial by jury.Page 2 of 22

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II. JURISDICTION-5-MS. PRICE

incorporates by reference and realleges Paragraphs One (1) through Four (4)herein through this specific reference

-6-

This Court has jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1343 because this action arisesas a civil rights action under the laws of the United States.

III. VENUE-7-MS. PRICE

incorporates by reference and realleges Paragraphs One (1) through Six (6)herein through this specific reference.

-8-

Venue properly lies before this Court pursuant to 28 U.S.C. §1391.

-9-

At all times relevant to this Complaint,

 DEFENDANTS KANAGO

,

 HYER 

,

 ARNOLD

,

TALBERT

,

 HANEY

 and the deceased

DEFENDANT SASSER 

, served as police officers of theGlynn County Police Department.

-10-

The incidents and injuries suffered by

MS. PRICE

occurred in this judicial district.

-11-

At all times relevant to this Complaint,

MS. PRICE

resided in Brunswick, Glynn County,Georgia in the Brunswick Division of the United States District Court for the Southern District of Georgia. 28 U.S.C. § 90(c)(5). Page 3 of 22

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