[SERVE: Cole County Clerk                                        )

P.O. Box 426 311 E. High St.                                       )

Jefferson City, Missouri 65101]                                    )

                                                                                    )

and                                                                              )

                                                                                    )

JOHN DOE, UNKNOWN COLE COUNTY                 )

DEPUTY SHERIFF,                                                     )

in both his official capacity and his individual             )

capacity                                                                       )

[SERVE: Cole County Sheriff                                      )

P.O. Box 426 311 E. High St.                                         )

Jefferson City, Missouri 65101]                                       )

                                                                                     )

and                                                                               )

                                                                                     )

ROGER A. SCHROEDER, Police Chief of                   )

Jefferson City, Missouri, in both his official                 )

capacity and his individual capacity                                  )

401 Monroe St.                                                              )

Jefferson City, Missouri 65101                                        )

                                                                                     )

and                                                                               )

                                                                                     )

CITY OF JEFFERSON CITY, MISSOURI                    )

401 Monroe St.                                                             )

Jefferson City, Missouri 65101                                      )

                                                                                     )

and                                                                               )

                                                                                     )

JASON AMBLER, Jefferson City, Missouri                 )

Police Officer, in both his official capacity and             )

his individual capacity                                                  )

401 Monroe St.                                                             )

Jefferson City, Missouri 65101                                      )

                                                                                     )

and                                                                               )

                                                                                     )

MISSOURI STATE HIGHWAY PATROL,                   )

1510 E. Elm St.                                                              )

Jefferson City, Missouri 65102                                      )

                                                                                      )

and                                                                                )

                                                                                      )

James F. Keathley, Superintendent, Missouri                )

State Highway Patrol, in both his official capacity        )

and his individual capacity                                            )

1510 E. Elm St.                                                              )

Jefferson City, Missouri 65102                                         )

                                                                                      )

and                                                                                )

                                                                                      )

JOHN DOE # 2, UNKNOWN MISSOURI                     )

STATE HIGHWAY PATROL OFFICER,                      )

in both his official capacity and his individual               )

capacity                                                                          )

[SERVE: Missouri State Highway Patrol                        )

1510 E. Elm St.                                                               )

Jefferson City, Missouri 65102                                          )

                                                                                      )

and                                                                                )

                                                                                      )

MISSOURI FARM BUREAU FEDERATION                )

a/k/a MISSOURI FARM BUREAU                                )

FEDERATION %                                                           )

701 Country Club Drive                                                 )

Jefferson City, Missouri 65102                                       )

                                                                                       )

and                                                                                 )

                                                                                       )

CHARLES KRUSE, President of Missouri                     )

Farm Bureau Federation                                                 )

1007 Woodland Drive                                                     )

Dexter, Missouri 63841                                                   )

                                                                                       )

and                                                                                 )

                                                                                       )

MISSOURI FARM BUREAU INSURANCE                   )

SERVICES a/k/a MISSOURI FARM BUREAU              )

FAMILY OF COMPANIES, a/k/a MISSOURI               )

FARM BUREAU INSURANCE, a/k/a                            )

COMPLAINT

(Violation of Civil Rights, Intentional Torts and Negligence)

Plaintiff Maurice L. Gash demands a jury trial on all claims stated in

this Complaint. For his causes of action against Cole County Sheriff Greg

White, Cole County Missouri, John Doe unknown Cole County Deputy

Sheriff, Roger A. Schroeder Jefferson City Police Chief, City of Jefferson

City Missouri, Jason Ambler Jefferson City Missouri Police Officer,

Missouri State Highway Patrol, James F. Keathley Superintendent Missouri

State Highway Patrol, John Doe # 2 unknown Missouri State Highway

Patrol Officer, Missouri Farm Bureau Federation, Charles Kruse President of

Missouri Farm Bureau Federation, Missouri Farm Bureau Insurance

Services, Daniel Cassidy Chief Administrative Officer of Missouri Farm

Bureau Federation. (referred to below as “Defendants”),

Plaintiff Maurice L. Gash states as follows:

appointment with Mr. Kruse. Mr. Gash then left the building and returned to

his motel and met with his attorney to prepare for a court appearance at the

Missouri State Supreme Court at 9:00 am.

4. At approximately 11:00 am as Mr. Gash and his attorney arrived back

at his motel he observed a Missouri State Highway Patrolman, and a Cole

County Deputy Sheriff in the process of searching the inside of his vehicle

that was parked at his motel. As Mr. Gash and his attorney approached the

vehicle Jefferson City Missouri Police Officer Jason Ambler placed Mr.

Gash under arrest for peace disturbance, put him in handcuffs, and locked

him in his patrol car in full view of all motel employees and other guests.

Mr. Ambler then transported Mr. Gash to the police station where he was

booked and fingerprinted, and locked up in a small holding cell. Mr. Ambler

then told Mr. Gash that he was not welcome at Farm Bureau and advised

Mr. Gash to not return there with his vehicle ever again. Mr. Gash posted

$500.00 cash bond at the Cole County Sheriff’s Office, and was released

with a court hearing set for November 30, 2007.

5. Mr. Gash subsequently made two court appearances, on November 30,

2007, and January 11, 2008. At the last court appearance Judge Thomas

Sodergren advised Mr. Gash that he did not have to return to his court in

connection with this case, and ordered him to report to the Circuit Clerks

office. The Circuit Clerk advised Mr. Gash that the Prosecutor had one year

to file charges in this case, and for Mr. Gash to “go home and wait”. To

obtain his release and to prepare to defend the criminal charges which to this

date have never been filed, because the Prosecutor found no probable cause,

Mr. Gash has incurred substantial legal fees, and transportation cost.

6. Mr. Gash now seeks damages for the Defendants’ reckless, intentional

and conspiratorial actions that violated his civil rights, restrained his liberty,

damaged his reputation, and which humiliated him in front of his attorney

and various guests at the motel at which he was staying and which inflicted

enormous mental suffering and pain.

JURISDICTION

7. Jurisdiction is conferred by 28 U.S.C. § 1343, which provides for

original jurisdiction of this Court in suits authorized by 42 U.S.C. § 1983, to

redress the deprivation under color of state law, statute, ordinance,

regulation, custom or usage of any right, privilege, or immunity secured by

the Constitution of the United States or by any act of Congress providing for

equal rights of citizens or of all persons within the jurisdiction of the United

States.

8. Plaintiff further invokes the supplemental jurisdiction of this Court to

hear and decide claims arising under state law. 28 U.S.C. § 1367.

9. Plaintiff’s actions for damages are authorized by:

42 U.S.C. § 1983, which provides for redress for the deprivation under color

of any statute, ordinance, regulation, custom or usage of any state or territory

of any rights, privileges or immunities secured to all the citizens or persons

within the jurisdiction of the United States;

– The Fourth, Fifth, Eighth and Fourteenth Amendments of the United States

Constitution;

– the law of the state of Missouri; and

– 42 U.S.C. § 1988, which authorizes Plaintiff’s application for attorneys’

fees and provides that a court may award a reasonable attorneys’ fee as part

of costs in any action or proceeding to enforce a provision of 42 U.S.C. §

1983.

10. Venue is proper in the United States District Court for the Western

District of Missouri under 28 U.S.C. § 1391(a)(2), as the events or omissions

giving rise to Plaintiff’s claims occurred in Cole County, Missouri.

THE PARTIES

11. Plaintiff Maurice L. Gash is and was, at all times relevant to this

complaint, a citizen of Odessa, Lafayette County Missouri. He now resides

at 981 Owl Creek Parkway, Odessa, Missouri 64076.

12. The Defendant governmental entities were created by, and established

under, the laws of the State of Missouri. They are authorized to sue or be

sued in their corporate names. They have also purchased one or more

policies of insurance which would provide their employees with coverage

for some or all of Plaintiff’s claims. The individual Defendant employees of

the aforementioned government entities, at all times relevant to the conduct

alleged in this Complaint, were sworn law enforcement officers in the State

of Missouri. They are sued in their individual and official capacities.

13. The Defendant, government entities and their Defendant employees at

all times material to this Complaint, were acting under color of state law.

14. The Defendant Farm Bureau Federation and Farm Bureau Insurance

Services are also registered with the Missouri Secretary of State in

numerous registrations and fictitious names including Missouri Farm

Bureau Federation %, Missouri Farm Bureau Family of Companies,

Missouri Farm Bureau Family of Insurance Companies, Missouri Farm

Bureau Insurance, and some are private corporations and some are nonprofit

corporations , all were created by and established under the laws of

the State of Missouri. They are authorized to sue or be sued in their

corporate names. The individual Defendant employees of the

aforementioned Defendant private corporations, at all times relevant to the

conduct alleged in this Complaint, were employees of said corporations and

are responsible for their own actions and the corporation is liable under the

doctrine of respondeat superior.

FACTUAL BACKGROUND

15. On October 10, 2007, Plaintiff Maurice L. Gash resided at 981 Owl

Creek Parkway, Odessa, Missouri with his wife Nancy L. Gash. On the

afternoon of October 10, 2007 Mr. Gash drove from his home to Jefferson

City, Missouri in his personal Dodge vehicle for the purpose of meeting

with Charles Kruse, the President of Missouri Farm Bureau Federation. Mr.

Gash was conducting a campaign to convince Farm Bureau to change their

ongoing practice of denying certain insurance claims filed by their members.

Mr. Gash used his vehicle as an advertizing tool to promote his website,

FarmBureauLies.com which acts as an advocate for policy holders in

Missouri who received unfair claims treatment from Farm Bureau Insurance.

16. Defendant Jason Ambler was an officer of the Jefferson City Police

Department. During the events in question he was under the supervision of

Jefferson City Police Chief Roger A. Schroeder.

17. Defendant John Doe (unknown Cole County Deputy Sheriff) was an

officer of the Cole County Sheriffs Department. During the events in

question he was under the supervision of Cole County Sheriff Greg White.

18. Defendant John Doe #2 (unknown Missouri State Highway

Patrolman) was an officer of the Missouri State Highway Patrol. During the

events in question he was under the supervision of James F. Keathley,

Superintendent of the Missouri State Highway Patrol.

19. Acting on false, malicious, misleading and unverified information

provided by Dan Cassidy, Chief Administrative Officer of Missouri Farm

Bureau Federation, Officers Jason Ambler, John Doe unknown Cole County

Deputy, and John Doe #2 Unknown Missouri Highway Patrolman located

Plaintiffs vehicle legally parked in the guest parking lot at 4804 Country

Club Drive, Candlewood Suites, the motel where Plaintiff was staying. The

motel is located in Cole County, beyond the Jefferson City limits. At about

11:00 am the aforementioned officers conducted a search of Plaintiffs

vehicle without his permission, or a legal search warrant, and instigated the

seizure of Mr. Gash’s vehicle by summoning a tow truck to remove the

vehicle from where it was legally parked at Mr. Gash’s motel.

20. At approximately 11:00 am as Mr. Gash and his attorney arrived back

at his motel from a hearing at the Missouri Supreme Court he observed the

search of his vehicle in progress. As Mr. Gash and his attorney approached

the vehicle Jefferson City Missouri Police Officer Jason Ambler placed Mr.

Gash under arrest for peace disturbance without producing a legal arrest

warrant, or conducting any further investigation with Mr. Gash, or his

Attorney to verify the accuracy of Defendant Farm Bureau and Defendant

Cassidy’s false, malicious, misleading, and unverified statements and

accusations as to what had actually occurred earlier that morning at the

offices of Farm Bureau. Defendant Jason Ambler chose to rely solely on

the false, misleading, and malicious information provided by Defendant

Cassidy. He then placed Plaintiff Gash under arrest and read Mr. Gash his

Miranda Rights, put him in handcuffs, and locked him in his patrol car in

full view of all motel employees and other guest.

21. While Plaintiff was handcuffed and locked in the police car a tow

truck arrived to seize Plaintiffs vehicle. Defendant Jason Ambler cancelled

the seizure of Plaintiffs vehicle and sent the tow truck away.

22. Mr. Ambler then transported Mr. Gash to the police station where he

was booked and fingerprinted, and locked up in a small holding cell. Mr.

Ambler then told Mr. Gash that he was not welcome at Farm Bureau and

advised Mr. Gash to not return there with his vehicle ever again. Mr. Gash

was then transported to the Cole County Jail where he posted $500.00 cash

bond and was released with a court hearing set for November 30, 2007.

23. Plaintiff Gash appeared for a hearing in Cole County Circuit Court on

November 30, 2007. Cole County Prosecutor Mark A. Richardson

continued the case to January 11,2008.

24. Plaintiff Gash appeared for hearing in Cole County Circuit Court on

January 11, 2008. Circuit Court Judge Thomas Sodergren ordered plaintiffs

bond returned and directed Plaintiff Gash to not return to his court

concerning this arrest for Peace Disturbance.

25. On March 31, 2008 Herb Heinen an Investigator from the Cole

County Prosecutors Office advised Plaintiff Gash that his office would not

file charges against Plaintiff for Peace Disturbance at that particular time,

thus subjecting Mr. Gash to eight more months of fear, anxiety, anguish and

mental suffering because of the possibility of being arrested and prosecuted

again.

26. As a result of the seizure of his person, false arrest, illegal search,

malicious prosecution, and months of apprehension not knowing if charges

would be filed and another arrest perpetrated on him by Defendants. Mr.

Gash has experienced overwhelming fear and emotional distress both at the

time of the incident, and in the months since. To defend the charges against

him which were never filed, he has incurred substantial legal fees and

transportation cost.

27. All of the Defendants knew or should have known that their conduct

violated clearly established constitutional or statutory rights of which a

reasonable person should have known.

28. All actions by the Defendant governmental entities were taken under

color of state law.

Count I

Claim Against All Defendants for Unconstitutional Search and Seizure

in violation of the Fourth Amendment and 42 U.S.C. § 1983.

Plaintiff Gash realleges the foregoing allegations in paragraphs 1-28 and

further states as follows:

29. Defendants John Doe, Jason Ambler, and John Doe #2, acting under

color of state law, along with Missouri Farm Bureau Federation, Charles

Kruse, Daniel Cassidy, and Missouri Farm Bureau Insurance Services,

reached an understanding, acted in concert and engaged in a course of

conduct together, and otherwise conspired among and between themselves

to deprive Mr. Gash of his rights under the United States Constitution.

Defendants intentionally and/or recklessly searched Plaintiffs vehicle

without a search warrant issued by a judge or magistrate. The search was

illegal, unconstitutional and unreasonable, as there was no probable cause

for the search and Mr. Gash posed no threat to the officers’ or anyone else’s

safety.

30. Defendants John Doe, Jason Ambler, and John Doe #2, acting under

color of state law, along with Missouri Farm Bureau Federation, Charles

Kruse, Daniel Cassidy, and Missouri Farm Bureau Insurance Services,

intentionally and/or recklessly caused the wrongful and unlawful arrest of

Mr. Gash by relying solely on false, misleading, and malicious information

provided by Defendant Cassidy, claiming that Mr. Gash posed an imminent

threat to Individuals employed at Missouri Farm Bureau Federation.

31. The actions of all Defendants, acting individually and/or in concert,

were wanton and malicious and subjected Mr. Gash to the unconstitutional

and unreasonable search and seizure of his vehicle in violation of the Fourth

Amendment. And the arrest of Mr. Gash without probable cause. The

Defendants’ actions also deprived Mr. Gash of his right to due process and

his right to be free from cruel and unusual punishment, in violation of the

Fifth, Eighth and Fourteenth Amendments.

32. The actions of the Defendants proximately and directly caused Mr.

Gash grievous permanent injury along with an attendant loss of liberty.

Defendants’ actions also caused him severe mental pain, suffering, anguish

and humiliation.

33. At all times relevant to this Complaint, Defendant John Doe was the

agent, employee and servant of Defendant White, and Cole County

Missouri, and was acting under the supervision of Defendant White. Jason

Ambler was the agent, employee and servant of Defendant Schroeder, and

The City of Jefferson City, Missouri, and was acting under the supervision

of Defendant Schroeder. John Doe #2, was the agent, employee and servant

of Defendant Keathley and the Missouri State Highway Patrol, and was

acting under the supervision of Defendant Keathley.

34. Defendants White, and Cole County Missouri recklessly supervised

Defendant John Doe, resulting in the illegal search and wrongful arrest and

the consequent damages to Mr. Gash. Defendant Schroeder, and Defendant

Jefferson City also recklessly failed to provide Defendant Jason Ambler with

adequate training and supervision, resulting in the illegal search and

wrongful arrest and the consequent damages to Mr. Gash. Defendant

Keathley, and Defendant Missouri State Highway Patrol also recklessly

failed to provide Defendant John Doe # 2 with adequate training and

supervision, resulting in the illegal search and wrongful arrest and the

consequent damages to Mr. Gash. The Defendants’ actions violated Gash’s

rights under the Fourth, Fifth, Eighth and Fourteenth Amendments.

Count II

Claim against All Defendants for Wrongful Arrest and Imprisonment in

the Absence of Probable Cause, in Violation of the Fourth, Fifth, Eighth

and Fourteenth Amendments and 42 U.S.C. § 1983.

Plaintiff Gash realleges the foregoing allegations in paragraphs 1-34 and

further states as follows:

35. The false and wrongful arrest and imprisonment of Mr. Gash without

probable cause or reasonable cause that any law had been violated was

deliberately and/or recklessly conducted or brought about by Defendants

John Doe, John Doe #2, and Jason Ambler, all acting under color of state

law, along with Missouri Farm Bureau Federation, Charles Kruse, Daniel

Cassidy, and Missouri Farm Bureau Insurance Services, they reached an

understanding, acted in concert and engaged in a course of conduct together,

and otherwise conspired among and between themselves to deprive Mr.

Gash of his rights under the United States Constitution.

36. Defendants knew or should have known that they had no probable

cause to seize and arrest Mr. Gash, or to cause his arrest, as Mr. Gash had

committed no crime, but, rather, was the victim of the Defendants’ wanton,

malicious and unconstitutional conduct.

37. The Defendants, acting individually and/or in concert with each other,

unconstitutionally arrested and detained Mr. Gash, subjecting him to

unreasonable seizure and arrest in violation of the Fourth Amendment. The

Defendants’ actions also deprived Mr. Gash of his right to due process and

his right to be free from cruel and unusual punishment, all in violation of the

Fifth, Eighth, and Fourteenth Amendments.

38. The actions of the Defendants proximately and directly caused Mr.

Gash grievous permanent injury along with an attendant loss of liberty.

Defendants’ actions also caused severe mental pain, suffering, anguish and

humiliation.

39. At all times relevant to this Complaint, Defendants John Doe, John

Doe #2, and Jason Ambler were the agents, employees and servants of

Defendants Cole County, the Missouri State Highway Patrol, and the City of

Jefferson City, and were acting under the supervision of Defendants White,

Keathley, and Schroeder.

40. Defendants White, Keathley, and Schroeder, recklessly supervised

Defendants John Doe, John Doe #2, and Jason Ambler, resulting in the

illegal search and seizure of Mr. Gash’s vehicle, his wrongful arrest and the

consequent damages. Defendants Cole County, the Missouri State Highway

Patrol, and the City of Jefferson City also recklessly failed to provide

Defendants John Doe, John Doe # 2, and Jason Ambler with adequate

training and supervision, resulting in the wrongful arrest of Mr. Gash, the

illegal search and seizure of his vehicle, and the consequent damages. The

Defendants’ actions violated Mr. Gash’s rights under the Fourth, Fifth,

Eighth and Fourteenth Amendments.

Count III

Claim for Conspiracy Under 42 U.S.C. § 1983 against all

Defendants,

Plaintiff Gash realleges the foregoing allegations in paragraphs 1-40 and

further states as follows:

41. Defendants John Doe, John Doe #2, and Jason Ambler under color of

state law, along with Missouri Farm Bureau Federation, Charles Kruse,

Daniel Cassidy and Missouri Farm Bureau Insurance Services , reached an

understanding, acted in concert and engaged in a course of conduct together,

and otherwise conspired among and between themselves to deprive Mr.

Gash of his rights under the United States Constitution, and did deprive Mr.

Gash of his right to be free from unlawful and unreasonable seizure and

arrest and unlawful and unconstitutional detention. Defendants also deprived

Mr. Gash of his right to be free from cruel and unusual punishment and his

right not to be deprived of liberty unreasonably and without due process of

law. The conspiracy violated Mr. Gash’s rights as protected by the Fourth,

Fifth, Eighth and Fourteenth Amendments of the United States Constitution.

42. Defendants conspired between and among themselves to subject Mr.

Gash to unreasonable search and seizure, and wrongful arrest in the absence

of probable cause. Acting intentionally and/or recklessly, Defendants, along

with others, violated the constitutional rights of Mr. Gash.

43. Defendants John Doe, John Doe # 2, and Jason Ambler along with

Missouri Farm Bureau Federation, Charles Kruse, Daniel Cassidy, and

Missouri Farm Bureau Insurance Services committed the overt acts set forth

in this Count and in Counts I and II, which are hereby realleged. These acts

include, but are not limited to, the unconstitutional search and seizure of Mr.

Gash’s vehicle, seizing Mr. Gash unreasonably and illegally, and subjecting

him to an unlawful and unconstitutional detention. All of these acts violated

the constitutional rights of Mr. Gash.

44. The conspiratorial actions of the Defendants proximately and directly

caused Mr. Gash grievous permanent injury along with an attendant loss of

liberty. Defendants’ actions also caused severe mental pain, suffering,

anguish and humiliation.

Count IV

Monell Claim Under 42 U.S.C. § 1983 Against Defendant White, in his

Official Capacity, and Cole County, Against Defendant Keathley, in his

official capacity, and The Missouri State Highway Patrol, Against

Defendant Schroeder, in his official capacity, and the City of Jefferson

City

Plaintiff Gash realleges the foregoing allegations in paragraphs 1- 44 and

further states as follows:

45. Sheriff White (a final policymaker for the Sheriff’s Department), Cole

County, Superintendent Keathley, (a final policymaker for the Missouri

State Highway Patrol), and Chief Schroeder, (a final policymaker for the

Jefferson City Police Department), had in effect, both before and at the time

of the events alleged in this Complaint, policies, practices, customs and

procedures which operated to deprive Mr. Gash of his constitutional rights.

46. Sheriff White, Cole County, Superintendent Keathley, Missouri State

Highway Patrol, Chief Schroeder, and Jefferson City Missouri are

accountable under 42 U.S.C. § 1983 because they established policies and

practices that were intended to and did encourage, endorse and permit their

agents and employees to violate the constitutional rights of Mr. Gash, and

other similarly situated persons. At a minimum, Sheriff White, Cole County,

Superintendent Keathley, Missouri State Highway Patrol, Chief Schroeder,

and Jefferson City were deliberately and/or recklessly indifferent to such

constitutional violations.

47. The unconstitutional policies, practices, customs and procedures of

Sheriff White, Cole County, Superintendent Keathley, Missouri State

Highway Patrol, Chief Schroeder, and Jefferson City Missouri include, but

are not limited to:

A. A policy, practice, custom or procedure of failing to properly train and

supervise officers to avoid the inappropriate use of police powers;

B. A policy, practice, custom or procedure of failing to train and supervise

officers in the techniques of properly conducting investigations;

C. A policy, practice, custom or procedure of failing to train and supervise

officers as to their obligation to truthfully report occurrences rather than to

falsify information.

D. A policy, practice, custom or procedure of covering up police misconduct

by falsifying and fabricating evidence without regard to whether the policies,

practices and customs might result in the unlawful arrest, prosecution or

conviction of innocent persons;

E. A policy, practice, custom or procedure of failing to discipline officers

who violate the Constitution or law or otherwise transgress the rights of

criminal suspects during their investigations;

F. A policy, practice, custom or procedure of being deliberately indifferent

to the violation by law enforcement officers of the rights of the accused;

48. Sheriff White, Cole County, Superintendent Keathley, Missouri State

Highway Patrol, Chief Schroeder, and Jefferson City Missouri

acquired and used the policies, practices, customs and procedures described

above before and during the illegal vehicle search, arrest, investigation and

prosecution of Mr. Gash.

49. These policies, practices, customs and procedures, as described above,

were implemented intentionally and/or recklessly to deprive suspects and

Defendants, including Mr. Gash, of his constitutional rights and were a

direct and proximate cause of the Constitutional violations and injuries set

forth in Counts I, II and III of this Complaint.

Supplemental State Claims

50. With regard to the following State Claims, all Governmental

Defendants were, at all material times, acting under Color of State Law and

in their official capacities or as agents of law enforcement. The

governmental entities and Sheriff White, Superintendent Keathley, and

Chief Schroeder are liable as to all the State Claims listed under the doctrine

of respondeat superior. Alternatively, with regard to intentional torts, the

governmental entities, Cole County, Missouri State Highway Patrol, and

Jefferson City Missouri are liable, along with Sheriff White, Superintendent

Keathley, and Chief Schroeder for the failure to properly train and supervise

employees, and or to establish appropriate policies, as described in Count

IV. And with regard to the State Law Claims the corporate employee

Defendants were acting as agents for The Missouri Farm Bureau

Federation and Farm Bureau Insurance Services and the corporate

Defendants are responsible for their actions under the doctrine of

respondeat superior.

Count V

State Law Claim for False Arrest

Plaintiff Gash realleges the foregoing allegations in paragraphs 1-50 and

further states as follows:

51. Defendants Cole County, the City of Jefferson City, the Missouri State

Highway Patrol, White, Schroeder, and Keathley acting through their agents,

and Defendants John Doe, John Doe #2, and Jason Ambler, along with

Missouri Farm Bureau Federation, Charles Kruse, Daniel Cassidy, and

Missouri Farm Bureau Insurance Services in concert each with the other, did

willfully and unlawfully and under color of legal authority, illegally arrest

and/or permit the illegal arrest and/or procure the arrest of Mr. Gash without

legal excuse and detained him against his will without due and legal process.

The arrest was directly and proximately caused by Farm Bureau Federation

and Farm Bureau Insurance Services acting through its agents Charles

Kruse and Daniel Cassidy providing, false, incomplete, or misleading

information to the arresting authorities instigating and resulting in an illegal

arrest. As a result of the false arrest, Mr. Gash was unlawfully detained,

falsely imprisoned and caused to suffer great pain and emotional distress.

52. Mr. Gash suffered physical and mental pain and humiliation, and

loss of freedom, companionship, and income.

53. The false arrest instigated by the Farm Bureau corporate Defendants

was done maliciously, willfully, and recklessly at the direction of

Defendants, justifying an award of punitive damages.

Count VI

State Law Claim for Abuse of Process

Plaintiff Gash realleges the foregoing allegations in paragraphs 1-53 and

further states as follows:

54. Defendants Cole County, the City of Jefferson City, the Missouri State

Highway Patrol, White, Schroeder, and Keathley acting through their agents,

and Defendants John Doe, John Doe #2, and Jason Ambler, along with

Missouri Farm Bureau Federation, Charles Kruse, Daniel Cassidy, and

Missouri Farm Bureau Insurance Services, acting in concert each with the

other, did willfully, unlawfully, maliciously, and improperly use the Court’s

process primarily for an ulterior, improper, and illegal purpose and, as a

result of these actions and omissions, Plaintiff Gash did suffer great distress,

pain, anguish, fear, and incurred monetary damages. The abuse of process

was directly and proximately caused by the failure of the governmental

agencies and by the failure of Defendants White, Schroeder, and Keathley to

provide adequate training, supervision and policies. The abuse of process

was also caused by the Defendants Farm Bureau Federation and Farm

Bureau Insurance Services misrepresenting the actions taken by the plaintiff

on its property to instigate and procure the removal, arrest, and to prevent

plaintiff from coming onto its property.

55. Because of the malicious, willful, reckless nature of Defendants’

actions, an award of punitive damages is justified.

Count VII

State Law Claim for Negligence Resulting in Wrongful Arrest and

Detention

Plaintiff Gash realleges the foregoing allegations in paragraphs 1-55 and

further states as follows:

56. If Defendants White, Schroeder, and Keathley, acting through their

agents, and Defendants John Doe, John Doe #2, and Jason Ambler did not

act intentionally, deliberately, and in bad faith, they did negligently bring

about a wrongful arrest and detention of Plaintiff Gash and put together an

unreliable case against him through negligent investigation, irresponsible

procurement of evidence, and inadequate training, supervision and policies.

The Defendant governmental entities as well as Defendant White, Keathley,

and Schroeder are responsible for this negligence under the doctrine of

CLAIM FOR DAMAGES

65. The actions of Defendants deprived Plaintiff Gash of his civil rights

under the Fourth, Fifth, Eighth and Fourteenth Amendments of the

Constitution of the United States.

66. The intentional, malicious, and/or reckless actions or omissions of

Defendants constituted the unlawful an unreasonable search and seizure,

false or unlawful arrest, and illegal detention, all in violation of Mr. Gash’s

constitutional rights.

67. The unlawful, intentional, malicious and/or reckless actions of

Defendants caused Mr. Gash to suffer emotional stress, mental pain and

anguish, humiliation and continuing mental, and emotional injuries. Mr.

Gash has incurred, and continues to incur, substantial expense to treat these

injuries.

68. Defendants’ actions were deliberate, reckless, wanton, malicious

and/or cruel, which justifies an award of punitive damages.

69. Defendants’ actions caused Mr. Gash to have to make a $500 cash

bond, incur legal fees in defending the charges which were ultimately

dismissed or not actually filed.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests the following relief:

1. That this Court assume jurisdiction of this cause to determine this

controversy and set this case for hearing on the merits;

2. The award of compensatory damages to Plaintiff Gash in the amount

of $1,000,000.00.

3. The award of punitive damages against the Defendants, jointly and

severally, in the amount of $1000.000.00.

4. That this Court, pursuant to 42 U.S.C. § 1988, allow the Plaintiff costs,

expenses and attorneys’ fees, and also grant such alternative relief as may

seem to the Court, just, proper, and equitable.