Attica Scott Lawsuit

NO.
______________________ JEFFERSON CIRCUIT COURT

DIVISION _________________
JUDGE _________________
ELECTRONICALLY FILED
ATTICA SCOTT PLAINTIFFS
-AND-
ASHANTI SCOTT
-AND-
SHAMEKA PARRISH-WRIGHT
v. COMPLAINT
ALEX EADES, Individually, and in his DEFENDANTS
Presiding Judge: HON. MITCH PERRY (630267)

Official Capacity
Serve: ALEX EADES

633 W. Jefferson Street
Louisville, Kentucky 40202
-AND-
INTERIM CHIEF ROBERT

SCHROEDER, Individually, and in his
Official Capacity
Serve: ROBERT SCHROEDER

-AND-
JOHN DOE
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**** **** **** ****
Plaintiffs, Attica Scott, Ashanti Scott, and Shameka Parrish-Wright, by
counsel, and for their Complaint against Defendants, Alex Eades, Interim Chief
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Robert Schroeder, and John Doe, state as follows:
PARTIES, JURISDICTION, AND VENUE
1. The Plaintiff, Attica Scott, is and was at all times relevant herein a
resident of Jefferson County in the Commonwealth of Kentucky.
2. The Plaintiff, Ashanti Scott, is and was at all times relevant herein a
resident of Jefferson County in the Commonwealth of Kentucky.
3. The Plaintiff, Shameka Parrish-Wright, is and was at all times relevant
herein a resident of Jefferson County in the Commonwealth of Kentucky.
4. Defendant, Alex Eades, is named as a Defendant in his individual
capacity for his individual misfeasance, his individual acts of negligence, for his own

personal tortuous acts, and negligent discharge of his duties, as an officer with
Louisville Metro Police Department (hereinafter “LMPD”), as described throughout
the Complaint. This Defendant is also named in his official capacity and acted under
color of state law.
5. Upon information and belief, Defendant, Alex Eades, is and was at all
times relevant herein employed and/or residing in Jefferson County in the
Commonwealth of Kentucky.
6. Defendant, Interim Chief Robert Schroeder, is named as a Defendant in
his individual capacity for his individual misfeasance, his individual acts of
negligence, for his own personal tortuous acts, and negligent discharge of his duties,
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as Interim Chief of LMPD, as described throughout the Complaint. This Defendant
is also named in his official capacity and acted under color of state law.
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7. Upon information and belief, Defendant, Interim Chief Robert
Schroeder, is and was at all times relevant herein employed and/or residing in
Jefferson County in the Commonwealth of Kentucky.
8. Defendant John Doe is named as a Defendant in his/her individual
capacity for his/her individual misfeasance, his/her individual acts of negligence, for
his/her own personal tortuous acts, and negligent discharge of his/her duties, as an
officer with LMPD, as described throughout the Complaint. Defendant John Doe is
also named in his/her official capacity and acted under color of state law.
9. Upon information and belief, Defendant John Doe is and was at all
times relevant herein employed and/or residing in Jefferson County in the

Commonwealth of Kentucky.
10. All of the actions described herein took place in Jefferson County,
Kentucky.
11. Venue is proper, pursuant to KRS § 452.460, as the events that
transpired giving rise to the causes of action stated herein occurred in Jefferson
County, Kentucky, and this Court has proper jurisdiction of this action.
12. That the claims of the Plaintiffs exceed the minimal jurisdictional
amount of this Court.
FACTUAL BACKGROUND
13. On or about September 23, 2020, Louisville, Kentucky Mayor Greg

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Fischer issued an executive order placing a 9:00 p.m. until 6:30 a.m. curfew, as a
result of protests taking place in Louisville, Kentucky, with the exception of residents
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going to church, work, or seeking medical treatment. The curfew was ordered to last
for seventy-two (72) hours
14. On Thursday, September 24, 2020, Plaintiffs were walking near the
intersection of West Broadway and Third Street in downtown Louisville, before 9:00
p.m., attempting to seek sanctuary on the private property of First Unitarian Church
of Louisville, located at 809 South Fourth Street, Louisville, Kentucky 40203.
15. Plaintiffs walked down South Third Street and approached a barricaded
area blocked off by LMPD officers near the Third Street entrance of the architecture
firm Luckett & Farley, located at 737 South Third Street, Louisville, Kentucky 40202.
16. Unable to access First Unitarian Church by way of South Third Street,

Plaintiffs attempted to reach the church by way of South Fourth Street.
17. Plaintiffs again were blocked from reaching the church by another
barricade, set up a block from the entrance to the church.
18. Plaintiffs Attica Scott and Ashanti Scott were then immediately
approached by LMPD officers and arrested.
19. The arresting LMPD officers include Defendant Alex Eades and an
unknown officer, listed in the criminal matter Commonwealth vs. Parrish, Shameka,
Jefferson County Case No. 20-F-007639, as “LMPD,” who is identified as John Doe in
this matter.
20. Before the arrest, Plaintiff Attica Scott and others walking with her
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announced to LMPD officers, including Defendants Eades and John Doe, that they
were attempting to reach First Unitarian Church.
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21. Plaintiffs were not permitted to pass the barricade and reach sanctuary,
despite having plenty of time to do so prior the above-mentioned curfew.
22. Plaintiff Attica Scott asked officers three times, “Where do you want us
to go?”
23. Despite Plaintiffs’ reasonable, peaceful, and lawful conduct, LMPD
officers were directed to “encircle” them.
24. LMPD officers commanded Plaintiffs to “sit down” and began arresting
civilians, including the Plaintiffs, preventing them from entering First Unitarian
Church, as permitted by Mayor Fischer’s executive order.
25. Plaintiffs received the following criminal charges as a result of the

above-refenced incident: 1) “riot in first degree,” a felony per KRS 525.020; 2) “failure
to disburse,” a misdemeanor per KRS 525.160; 3) “unlawful assembly,” a
misdemeanor per KRS 525.050; and, 4) “any misdemeanor charge not covered by
these codes.”
26. Plaintiffs pled not guilty to all charges.
27. All charges were dismissed on or about November 16, 2020.
28. Plaintiff Attica Scott is an elected member of the Kentucky House of
Representatives, representing the 41st district.
29. Plaintiff Ashanti Scott is a college student at the University of
Louisville.
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30. Plaintiff Shameka Parrish-Wright is an Operations Manager at The
Bail Project.
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31. The facts contained in the preceding paragraphs are not intended to be
a complete recitation of the facts and/or tortious acts committed by Defendants which
are relevant to this Complaint.
COUNT I: CONSTITUTIONAL VIOLATIONS
32. Plaintiffs reallege and incorporate by reference each and every
allegation stated above as if separately repleaded in full herein.
33. Defendants Alex Eades and John Doe, acting individually, and under
color of state law and by virtue of their official position, office, and employment,
wrongfully and without probable cause, arrested Plaintiffs and caused them to be
charged with multiple criminal offenses, including one felony.

34. Plaintiffs were unlawfully arrested without probable cause or other
legal justification and the charges filed against Plaintiffs did not have a basis in fact.
35. By virtue of their unlawful arrests, Plaintiff’s’ rights under the
Constitution of the Commonwealth of Kentucky were violated, including, but not
limited to, their rights to due process and equal protection.
36. The actions of Defendants, Alex Eades and John Doe, as set forth herein,
constitute a violation of the Constitution of the Commonwealth of Kentucky and
Plaintiffs bring said claim to redress the deprivation and violation, under color of
state law, of the rights, privileges, and immunities guaranteed to Plaintiffs by the
Constitution of the Commonwealth of Kentucky including, but not limited to, the
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Plaintiffs’ rights to due process and equal protection.
37. The actions set forth herein constitute false arrest and unlawful
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imprisonment.
COUNT II: MALICIOUS PROSECUTION

39. As a result of Defendant Alex Eades’ and Defendant John Doe’s actions,
criminal proceedings were instituted against Plaintiffs.
40. Defendants Eades and Doe made false allegations without probable
cause to believe Plaintiffs were guilty of the crimes charged.
41. Defendants Eades and Doe maliciously and without probable cause
instituted judicial proceedings against Attica Scott, Ashanti Scott, and Shameka
Parrish-Wright and said proceedings were dismissed in Plaintiffs’ favor.

42. The actions of Defendants Eades and Doe constitute malicious
prosecution under Kentucky law.
COUNT III: ABUSE OF PROCESS

44. The actions of Defendants Alex Eades and John Doe constitute the
employment of the legal process for some other purpose than which it was intended.
45. The actions of Defendants Eades and Doe constitute the irregular or
wrongful employment of a judicial proceeding.

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46. Defendants Eades’ and Doe’s purpose in having Plaintiffs arrested was
not in order to promote justice but with an ulterior purpose and with a willful act in
the use of process not proper in the regular conduct of the proceeding.
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47. The actions of the Defendants Eades and Doe constitute abuse of process
under Kentucky law.
COUNT IV: INTENTIONAL INFLICTION

OF EMOTIONAL DISTRESS
49. Defendants Alex Eades and Doe acted intentionally and willfully in an
extreme and outrageous manner and/or with reckless disregard of the consequences
of their actions while acting individually, in their official capacity, and as an agents
or servants of the Louisville Metro Police Department.
50. These actions were outrageous and intolerable and they offend generally

accepted standards of decency and morality.
51. As a direct and proximate result of Defendant Eades’ and Defendant
Doe’s intentional, extreme, and outrageous conduct and/or their disregard for the
consequences of their actions, Plaintiff suffered severe emotional distress.
52. The actions of Defendants Eades and Doe constitute the intentional
infliction of emotional distress under Kentucky law.
COUNT V: NEGLIGENT INFLICTION

OF EMOTIONAL DISTRESS

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54. The acts and omissions of Defendants Alex Eades and John Doe, while
acting individually, in their official capacity, and as an agent and/or servant of LMPD,
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were negligent in that Defendants Eades and Doe had a duty under in the
circumstances to act with ordinary care toward Plaintiffs, they failed in that duty by
the manner in which they treated Defendants Eades and Doe, and their actions were
the cause in fact and proximate cause of Plaintiffs’ injuries.
55. These actions were outrageous and intolerable and they offend generally
accepted standards of decency and morality.
56. Plaintiffs suffered serious and/or severe emotional injury, such a
reasonable person would not be expected to endure the mental stress engendered by
the circumstances of the case.
57. Plaintiffs have suffered damages by reason of the above-described

conduct in amounts to be proved at trial.
58. The actions of Defendants Eades and Doe constitute the negligent
infliction of emotional distress under Kentucky law.
COUNT VI: NEGLIGENT SUPERVISION AND RETENTION
60. Defendant Interim Chief Robert Schroeder, in his individual capacity
and/or by and through his agents and employees, was responsible for the hiring,
training, supervision, retention and conduct of Defendants Alex Eades and John Doe.

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and/or by and through his agents and employees, had a duty to use reasonable care
in the hiring, training, supervision, and/or retention of Defendants Eades and
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Doe.
and/or by and through his agents and employees, was negligent in hiring, training,
supervision, and/or retention of Defendants Eades and Doe.
63. Defendant Interim Chief Robert Schroeder knew or should have known
of the tortuous conduct of Defendants Eades and Doe.
64. Defendant Interim Chief Robert Schroeder permitted Defendants Eades
and Doe to conduct themselves in an extreme and outrageous manner.
65. The acts and omissions of Defendant Interim Chief Robert Schroeder, in
his individual capacity and/or by and through his agents and employees, in the hiring,

training, supervision, and/or retention of Defendants Eades and Doe was the direct
and proximate cause of harm suffered by Plaintiffs.
66. Defendant Interim Chief Robert Schroeder’s actions constitute a
substantial factor and a direct and proximate cause of the Plaintiffs’ damages.
67. Plaintiffs have suffered damages by reason of the above-described
conduct in amounts to be proved at trial.
68. As a direct and proximate result of Defendant Interim Chief Robert
Schroeder’s negligent hiring, training, supervision, and/or retention of Defendants
Eades and Doe, Plaintiffs have suffered damages including, but not limited to, severe
emotional distress.
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COUNT VII: DEFAMATION

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70. Defendants Alex Eades’ and John Doe’s statements and testimony
regarding Plaintiffs were defamatory in nature in that Defendants alleged Plaintiffs
were responsible for committing criminal offenses, including one felony, without a
factual basis and in reckless disregard for the truth.
71. The allegations suggesting Plaintiffs were responsible for committing
criminal offenses, including one felony, were completely false.
72. Plaintiffs suffered loss of standing and reputation as a result of the false
statements.
73. As such, Defendants Eades’ and Doe’s actions constitute defamation of
character under Kentucky law.

COUNT VIII: FALSE IMPRISONMENT
75. As a result of Defendants Alex Eades’ and John Doe’s actions, while
acting individually, in their official capacity, and as agents and/or servants of the
Louisville Metro Police Department, Plaintiffs were unlawfully detained.
76. Defendants Eades’ and Doe’s actions as set forth herein constitute false
imprisonment under Kentucky law.
COUNT IX: ASSAULT AND BATTERY

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78. Defendants Alex Eades and John Doe assaulted and battered Plaintiffs
while acting individually, in their official capacity, and as agents and/or servants of
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the Louisville Metro Police Department.
79. Defendants Eades’ and Doe’s actions resulted in the reasonable fear of
imminent harm and constitute a threat of unwanted, harmful, and offensive
touching.
80. Defendants Eades’ and Doe’s actions in arresting and incarcerating
Plaintiffs constitute harmful and offensive touching.
81. As a direct and proximate result of Defendants Eades’ and Doe’s assault
and battery of Attica Scott, Ashanti Scott, and Shameka Parrish-Wright, they
suffered severe emotional distress.
82. The actions of Defendants Eades and Doe constitute assault and battery.

COUNT X: PUNITIVE DAMAGES
84. All actions of the Defendants described herein warrant an award of
punitive damages against the Defendants in that the Defendants actions were
intentional and/or constitute a complete failure to exercise reasonable care under the
circumstances, reckless indifference, deliberate indifference, gross negligence, and
wanton and/or reckless indifference or a complete disregard for the life, safety, or
rights of Plaintiffs.
85. As a direct and proximate result of the negligence and other causes of
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action herein asserted against the Defendants, Plaintiffs, Attica Scott, Ashanti Scott,
and Shameka Parrish-Wright have suffered and continue to suffer compensable
injuries including, but not limited to, mental and emotional pain and suffering; were
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caused to suffer great and lasting humiliation and embarrassment; were caused to
suffer constitutional and dignitary harm; were wrongfully deprived of their liberty
and were subject to ridicule, scorn and contempt; and all other damages which were
both temporary and permanent; all to their damage in an amount which exceeds the
jurisdictional minimum of this Court.
86. The actions and omissions of the Defendants constitute reckless, grossly
negligent, oppressive, and malicious conduct.
87. These actions rise to a level that permits the imposition of punitive
damages.
WHEREFORE, the Plaintiffs demand as follows:

1. Judgment against the Defendants, jointly and severally, in an amount
which will fairly and reasonably compensate Plaintiffs, Attica Scott,
Ashanti Scott, and Shameka Parrish-Wright, for the damages they have
incurred;
2. Punitive damages in an amount that will sufficiently deter and punish
defendants and other individuals similarly situated from committing
similar acts in the future;
3. Trial by jury;
4. Plaintiffs’ costs expended herein, including a reasonable attorney’s fee;
5. Leave to amend this Complaint; and

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6. Any and all other relief to which the Plaintiffs may appear entitled,
including nominal damages.
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Respectfully submitted,
/s/Vanessa B. Cantley___________________
Vanessa B. Cantley
Patrick E. Markey
BAHE COOK CANTLEY & NEFZGER PLC
1041 Goss Avenue
vanessa@bccnlaw.com
patrick@bccnlaw.com
Tel. (502) 587-2002
Fax (502) 587-2006
and
Steven R. Romines
ROMINES WEIS & YOUNG, PSC
600 W. Main Street
Suite 100

sromines@rominesweisyoung.com
Tel. (502) 587-8822
Fax (502) 568-3600
Counsel for Plaintiffs, Attica Scott, Ashanti Scott,

and Shameka Parrish-Wright
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NO. ______________________ JEFFERSON CIRCUIT COURT
DIVISION _________________
JUDGE _________________
ELECTRONICALLY FILED
ATTICA SCOTT PLAINTIFFS
-AND-
ASHANTI SCOTT
-AND-
SHAMEKA PARRISH-WRIGHT
v. PLAINTIFFS’ FIRST SET OF INTERROGATORIES AND

REQUESTS FOR PRODUCTION OF DOCUMENTS TO
DEFENDANTS ALEX EADES AND

INTERIM CHIEF ROBERT SCHROEDER
ALEX EADES, Individually, and in his DEFENDANTS

Official Capacity
Serve: ALEX EADES

-AND-
INTERIM CHIEF ROBERT

SCHROEDER, Individually, and in his
Official Capacity

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-AND-
JOHN DOE
**** **** **** ****
1
Plaintiffs, Attica Scott, Ashanti Scott, and Shameka Parrish-Wright, by
counsel, hereby request that Defendants Alex Eades and Interim Chief Robert
Schroeder answer the following Interrogatories and Requests for Production of
Documents according to Civil Rules 33 and 34, under oath and in writing, within
forty-five (45) days from service hereof. In accordance with CR 34, Defendants are
requested to produce the documents requested herein for inspection and copying at
the offices of Plaintiffs’ counsel at the 1041 Goss Avenue, Louisville, Kentucky
40217.
These Interrogatories and Requests for Production of Documents contained
herein are continuing and must be supplemented when appropriate, as required by

the Kentucky Rules of Civil Procedure.
DEFINITIONS AND INSTRUCTIONS
Plaintiffs define various words and phrases which may appear in these
Interrogatories and Requests for Production of Documents so as to help Defendants
fully and accurately understand the objectives of Plaintiffs’ discovery efforts while
assisting Defendants’ efforts to locate and furnish the relevant information. Plaintiffs
incorporate the following definitions into each Interrogatory and/or Request and rely
on these definitions to clarify the language therein to the extent necessary.
1. “Defendants” means Defendant Alex Eades, Interim Chief Robert
Schroeder, and/or all representatives acting on their behalf with respect to any matter
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inquired about in these requests including but not limited to all employees, attorneys,
consulting agents or any other representative.
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2. “Eades” means Alex Eades and/or all representatives acting on his
behalf with respect to any matter inquired about in these requests including but not
limited to all employees, attorneys, consulting agents or any other representative.
3. “Schroeder” means Interim Chief Robert Schroeder and/or all
representatives acting on his behalf with respect to any matter inquired about in
these requests including but not limited to all employees, attorneys, consulting agents
or any other representative.
4. “Lawsuit” refers to the suit entitled Attica Scott, et al. v. Alex Eades,
et al., filed in the Commonwealth of Kentucky, Jefferson Circuit Court.
5. The term “document” means and includes each and every medium

upon which information is or can be printed, recorded, or reproduced by mechanical
means, by hand or by any other method, whether by you or someone else, that is or
has been within your possession, custody, control, or of which you have knowledge
or access, including, without limitation, the following: advertisements; agreements;
aperture cards; books; brochures; calendars; calculations; charts; circulars; codes;
computer records or printouts; communications; contracts; copies; correspondence;
data processing cards, discs or tapes; diaries; directives; drafts; drawings;
ELECTRONIC MAIL MESSAGES; file folders; files; films; forms; graphs; indexes;
inspection reports; journals; ledgers; letters; local, state and federal government
hearing records and reports; magnetic tapes, cards, or discs or other products of any
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device for recording sound or electronic impulses; maps; memoranda; minutes or
other records of meetings or conferences; motion picture films; negatives; newspaper
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stories or clippings; notebooks; notices; notices of deficiencies; notices of rejections;
opinions or reports of consultants; pamphlets; photographs; pictures; plans; position
papers; press releases; progress reports; publications; reports; reports of studies;
specifications; statistical data; schedules; schedule revisions; sketches; status
reports; stenographic or handwritten notes; stenographic or wire or magnetic
recordings; studies; summaries; summaries or records of conversations of interviews
or telephone conversations; summaries or reports of investigations or negotiations;
surveys; specifications; telegrams; trip reports; videotapes; voice recordings in any
form; and working papers. The term “document” also includes the original and
every copy which is not identical to the original, specifically including every copy

which contains any commentary or notation whatsoever that does not appear on the
original. The term “document” also includes all drafts of each of the above.
6. The term “computer data” means any documents, information or
data ever placed into or stored on any of your computers or computers upon which
your employees perform their job duties, including, but not limited to, any hard
drives, servers, lap tops, disks, storage systems, retrieval systems and similar
systems, E-mails, Internet transmissions, electronic bulletin boards, websites, diary
systems, calendar systems, tickler systems and any other computer programs or
magnetic storage disks or media.
7. “Photographs,” “photos,” “videos,” and “videotapes” mean all

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films, negatives, slides, photos, digital images, visual images stored on computers,
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Polaroids, movie pictures, videotapes, movies, and pictures, whether developed or
not.
8. The term “all documents” means and includes all documents,
computer data, photographs, photos, videos, and videotapes that in any manner or
form are relevant in any way to the subject matter of the above-captioned Lawsuit,
including, without limitation, all documents that contain, record, reflect,
summarize, evaluate, comment upon, or discuss the events giving rise to the above-
captioned Lawsuit or that in any manner state the background of, or were the basis
for, or that relate to, record, evaluate, comment upon, or were referred to, relied
upon, utilized, generated, transmitted, or received in connection with same. It does

not include multiple, identical copies of the same document.
9. The term "specific" and/or "specifically" as hereinafter used in these
interrogatories, means precisely, exactly or definitely, setting forth in detail the
precise and exact sequence of events or transactions entailed in the occurrence
which is the subject of the interrogatory, however if you are not able to be "specific,"
then a general answer should be provided.
10. “Communication” means any oral or written utterance, notation, or
statement of any nature whatsoever, by and to whomsoever made including, but not
limited to, correspondence, conversations, dialogues, discussions, interviews,
consultations, agreements, and other understandings between or among two or

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more persons.
11. “Statement” as that term is used herein includes (a) a written
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statement signed or otherwise adopted or approved by the person making it; and (b)
any stenographic, mechanical, electrical or other recording, or any transcription
thereof which is a substantially verbatim recital of a statement made by the person
and contemporaneously recorded.
12. “Incident(s),” “incident(s) in question,” “occurrence(s),”
“occurrence(s) in question,” “event(s),” “claim(s),” or “allegation(s)” means
and/or refers to the events and factual allegations more fully described in Plaintiffs’
Complaint, including, but not limited to, paragraphs no. 13–31.
13. “Expert” means any expert who is expected to testify at the Lawsuit by
deposition or in person, either in your case in chief or rebuttal, as well as any expert

who has been informally consulted with, retained or specially employed in
anticipation of litigation or preparation for the Lawsuit but will not be called to testify
and whose work product forms a basis either in whole or in part of the testimony of an
expert who may be called as a witness.
14. “Person” or “persons” means not only natural persons, but also
corporations, partnerships, organizations, associations, industry groups, entities,
joint venturers, or any government or governmental entity, commission, or agency
and any divisions or departments or other units of any of the entities defined
herein.
15. The term “contractual indemnity agreements” means any

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agreement whereby any person or business firm may be liable to pay a sum of
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money upon the happening of a particular event or contingency or upon the
occurrence of a loss, judgment, peril, or risk.
16. “Insurance policy” means any type of agreement or insurance policy
under which any person or organization may be liable to pay all or part of any
judgment which may be entered in this Lawsuit, or to indemnify or reimburse for
the costs or attorneys’ fees incurred in being a party to this Lawsuit, or to indemnify
or reimburse for payments made to satisfy any judgment entered in this Lawsuit.
“Insurance policy” also includes all types of insurance policies, including but not
limited to comprehensive director and officer, errors and omissions, employment
practices liability, general liability, bonds, workers’ compensation, limited liability,

automobile, boiler and machinery, nuclear, fidelity, personal injury, property care,
custody and control, contractual liability insurance, commercial blanket bond
coverage, builder’s risk, all risk, excess and umbrella. Further, “insurance policy”
means and includes, but is not limited to all insurance policies and attachments
thereto, and other similar documents pertaining to the insurance policy, including,
but not limited to, declaration pages, certificates of insurance, exclusions,
endorsements, amendments, riders, and binders.
17. The term "identify" with reference to a document means to state the
date, author, type of document, or some other means of identifying it and its present
location or custodian. If any such document was, but is no longer, in your possession
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or subject to your control, state what disposition was made of it. With reference to a
person it means to state the person or entity’s full name, current home address and
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telephone number, current business address, telephone number, and company
affiliation, immediate past business address and company affiliation, current or
other relevant employment classification or job title and job description, his or her
social security number, and his or her education, certification, and job title.
INTERROGATORIES
1. Please identify the person or persons answering these Interrogatories
or who contributed information used in answering these Interrogatories, including
the official position and/or job title of each. If more than one person provided the
answers or information, identify the specific Interrogatories answered by each

person.
ANSWER:
2. Please state whether Defendants have obtained, taken, or made any
written statements or stenographic, mechanical, electrical, or other type of recorded
statements (or transcription thereof) from any of the named Plaintiffs, or any other
person that you believe possesses knowledge of facts relevant to this lawsuit. If so,
identify the document and provide the date such statement was obtained and the
identity of the person from whom the statement was obtained.
ANSWER:
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3. Please state whether Defendant, the Louisville Metro Police
Department (hereinafter “LMPD”), any other Defendant or any of the Defendants’
agents have made or possess any photographs, movies, visual recordings or voice
recordings of any of the Plaintiffs or the Plaintiffs’ family members. If so, identify
these records and provide the date such recording was made or obtained and the
identity of the person from whom the statement was take of or obtained from.
ANSWER:
4. Have Defendants, the LMPD, or any other related parties/individuals
conducted an investigation into the incidents at issue that form the basis of this

litigation? If so, please identify any and all reports prepared and/or conclusions
reached in said investigation. Please identify each document that formed the basis
of opinions, was used to refresh your recollection, or that was used as an aid to help
you complete your answers to these Interrogatories. If not, please explain why.
ANSWER:
5. State the names and addresses of all persons known to you to possess
knowledge of relevant facts concerning the occurrence complained of, and provide
full details of all knowledge or information possessed by each.
ANSWER:
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6. Please identify any and all exhibits, demonstrative evidence, or other
documentary evidence, that you intend to utilize at the trial of this matter.
ANSWER:
7. Please identify the names, phone numbers and addresses of all persons
you will call to testify or intend to call to testify at the trial of this matter.
ANSWER:
8. For each person identified in the answer to Interrogatory No. 7 above,
please give a summary of the expected testimony of each witness.

ANSWER:
9. Please identify the name, address, telephone number and
qualifications of any person who may be called as an expert witness on your behalf.
For each person identified, please state the subject matter to which the expert
witness is expected to testify, a synopsis of the facts and opinions that he/she is
expected to testify to, and a summary of the grounds for each such opinion held.
ANSWER:
10. If you or your counsel believes another person, entity and/or third
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party is or may be liable for the actions described in the Plaintiffs’ Complaint and/or
would justify apportionment of comparable fault, please identify said person, entity,
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and/or third party and describe in specific detail how said party(ies) are liable for
the actions described in the Plaintiffs’ Complaint and please describe in specific
detail any/all facts that may warrant apportionment.
ANSWER:
11. Provide the following information for each of your years of employment
with the LMPD:
1. Job Title and location of assignment;
2. All compensation for each year of their employment, including, but
not limited to, contributions to pensions or retirement accounts;

3. Job description for each position held;
4. Experience and qualification for each position each such employee
held;
5. All disciplinary actions (of any nature), with particularity to
allegations, reasons, and dates, that have been taken against you.
Specifically stating what the action was, why it was taken, and the
result of said action.
ANSWER:
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12. Please identify each and every legal action (of any nature), within the
past 10 years, to which you have been a party. Specifically identify the dates of each
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action, the causes of action involved in each action, and the results of said legal
action.
ANSWER:
13. Please describe in detail an overview of your activities and daily
operations in your capacity as an employee of LMPD, including at the time of the
subject occurrence.
ANSWER:

14. Please identify and describe in detail the procedures to be followed by
those employed in your capacity as a police officer at LMPD at the time of the
occurrence, and identify where such procedure is located in the Standard Operating
Procedures (herein after “SOP”) maintained and used by LMPD, or any other SOP
which you followed in your capacity as a police officer.
ANSWER:
15. Please identify and describe in detail the procedures to be followed by

COM : 000026 of 000035
police officers employed by LMPD when implementing a curfew, and please state
12
whether you contend that you followed such procedures at the time of the
occurrence.
ANSWER:
16. Please describe in specific detail the duties of a police officer employed
by LMPD, identifying all SOP which govern the conduct of police officers employed
by LMPD.
ANSWER:

17. Please identify by whom and describe in specific detail how police
officers employed by LMPD are evaluated in their job performance, including by
whom commendations would be awarded and also by whom disciplinary action
would be invoked or taken by.
ANSWER:
18. Please describe in detail the nature and duration of the training or
COM : 000027 of 000035
experience sufficient to qualify one for such appointment as a police officer and/or
13
interim police chief with the LMPD and state whether you satisfied such
requirements.
ANSWER:
19. Please provide your entire work history prior to LMPD, including the
name and address of your employer, your title, job duties, direct supervisor (by
name, address, and telephone number), dates of employment, your rate of pay, and
reason for leaving.
ANSWER:

20. State whether, as the result of your involvement in the occurrence, you
were subject to any internal administrative procedures and please list:
1. The substance of the charges made against you in such procedures;
2. The names and addresses of all persons who preferred such charges;
and
3. The date and outcome of such procedure, including the date and
nature of subsequent disciplinary action against you, if any was taken.
ANSWER:
21. State whether you were/are insured against judgments of personal

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liability based on any abuse of your lawful authority.
ANSWER:
14
22. State the “chain-of-command” in place during your tenure as a
narcotics detective, including the name, title, and job duties of each person in the
chain-of-command.
ANSWER:
23. Please list your education history, including the name of the
institution attended, the dates of attendance, and any degree(s) obtained.
ANSWER:
REQUESTS FOR PRODUCTION OF DOCUMENTS

1. Please provide copies of all documents identified in your Answers to
Interrogatories.
RESPONSE:
2. In regard to Interrogatory No. 2, please attach a copy of any and all
written or recorded statements.
RESPONSE: COM : 000029 of 000035
15
3. In regard to Interrogatory No. 3, please provide copies of any and all
photographs and/ or recordings made or in your possession.
RESPONSE:
4. In regard to Interrogatory No. 4, please provide copies of any and all
materials compiled during any investigation performed, as well as the final report.
RESPONSE:

5. Please provide a copy of each trial exhibit that you anticipate
introducing into evidence at trail.
RESPONSE:
6. In regard to Interrogatory No. 9, please provide a copy of all material
prepared by each expert witness pertaining to the subject matter of this action and
any documents they will present or that are intended to presented to the expert
during testimony for this action.
RESPONSE:
COM : 000030 of 000035
16
7. In regard to Interrogatory No. 11, sub-part 5, please provide a copy of
any and all documents regarding or evidencing disciplinary actions taken against
any of the Defendants.
RESPONSE:
8. Please provide a copy of the specific section of the SOP identified in
these Answers, as well as a complete copy of the SOP as it is maintained by LMPD.
This should also include any separate SOP or operational/instructional manual
maintained by the Defendants that is not included in the LMPD SOP.
RESPONSE:

9. Please provide a copy of any books, records, reports made in the
ordinary course of business, printed or documentary material, photographs,
videotapes, drawings or documents, or other tangible objects that describe, record,
or are otherwise relevant to the occurrence which is the subject of this lawsuit.
RESPONSE:
10. Please provide a copy of any and all documents reflecting the
organizational structure of the LMPD, including, but not limited to, documents
COM : 000031 of 000035
reflecting the names and rank of each person within the organizational structure.
RESPONSE:
17
11. Please provide a copy of any and all training materials you have within
your custody or control that relate in any way to your training as a police officer
and/or interim police chief.
RESPONSE:
12. Please provide a copy of any and all documents, (including but not
limited to, minutes, power-point presentations, inter-office communiqués, electronic
mail, memoranda, or anecdotal notes), that relate in any way to any of the Plaintiffs

in this action.
RESPONSE:
13. Please provide a copy of any and all documents, (including but not
limited to, minutes, power-point presentations, inter-office communiqués, electronic
mail, memoranda, or anecdotal notes), that relate in any way to your job
performance or expectations, including but not limited to arrest rates and conviction
rates within your department.
RESPONSE:
COM : 000032 of 000035
18
14. Please provide a copy of all documents that you or your attorney used
during any hearings of the Merit Board, whether admitted into evidence or used for
any other purpose.
RESPONSE:
15. Please provide a copy of any press releases or prepared statements
provided to the press, and any drafts or previous versions of press releases or
prepared statements.
RESPONSE:

16. Please provide a copy of any body camera footage of the subject
occurrence and/or which includes the Plaintiffs
RESPONSE:
17. The complete employee file of Defendant Eades.
RESPONSE:
18. The complete employee file of Defendant Schroeder.
RESPONSE: COM : 000033 of 000035
19
Respectfully submitted,
/s/ Vanessa B. Cantley ____

Vanessa B. Cantley
Patrick E. Markey
BAHE COOK CANTLEY & NEFZGER PLC
1041 Goss Avenue
vanessa@bccnlaw.com
patrick@bccnlaw.com
(502) 587-2002 – Telephone
(502) 587-2006 – Facsimile
and
Steven R. Romines
ROMINES WEIS & YOUNG, PSC
600 W. Main Street
Suite 100

sromines@rominesweisyoung.com
Tel. (502) 587-8822
Fax (502) 568-3600
Counsel for Plaintiffs, Attica Scott, Ashanti Scott,

and Shameka Parrish-Wright
COM : 000034 of 000035
20
CERTIFICATE OF SERVICE
I hereby certify that on the 14th day of June 2021, a copy of the foregoing
pleading was filed with the Complaint initiating this lawsuit, to be served, either
electronically, personally or by First-Class Mail, postage prepaid, upon the following
Defendants:
ALEX EADES, Individually, and in his Official Capacity
Serve: ALEX EADES

-AND-
INTERIM CHIEF ROBERT SCHROEDER


/s/ Vanessa B. Cantley _______
Counsel for Plaintiffs
COM : 000035 of 000035
21

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NO.

______________________ JEFFERSON CIRCUIT COURT

ATTICA SCOTT PLAINTIFFS

ALEX EADES, Individually, and in his DEFENDANTS

Presiding Judge: HON. MITCH PERRY (630267)

Serve: ALEX EADES

INTERIM CHIEF ROBERT

Serve: ROBERT SCHROEDER

**** **** **** ****

Plaintiffs, Attica Scott, Ashanti Scott, and Shameka Parrish-Wright, by

PARTIES, JURISDICTION, AND VENUE

resident of Jefferson County in the Commonwealth of Kentucky.

resident of Jefferson County in the Commonwealth of Kentucky.

3. The Plaintiff, Shameka Parrish-Wright, is and was at all times relevant

herein a resident of Jefferson County in the Commonwealth of Kentucky.

4. Defendant, Alex Eades, is named as a Defendant in his individual

Presiding Judge: HON. MITCH PERRY (630267)

Louisville Metro Police Department (hereinafter “LMPD”), as described throughout

color of state law.

times relevant herein employed and/or residing in Jefferson County in the

6. Defendant, Interim Chief Robert Schroeder, is named as a Defendant in

as Interim Chief of LMPD, as described throughout the Complaint. This Defendant

Jefferson County in the Commonwealth of Kentucky.

8. Defendant John Doe is named as a Defendant in his/her individual

times relevant herein employed and/or residing in Jefferson County in the

Presiding Judge: HON. MITCH PERRY (630267)

11. Venue is proper, pursuant to KRS § 452.460, as the events that

amount of this Court.

13. On or about September 23, 2020, Louisville, Kentucky Mayor Greg

for seventy-two (72) hours

of Louisville, located at 809 South Fourth Street, Louisville, Kentucky 40203.

Presiding Judge: HON. MITCH PERRY (630267)

barricade, set up a block from the entrance to the church.

approached by LMPD officers and arrested.

were attempting to reach First Unitarian Church.

despite having plenty of time to do so prior the above-mentioned curfew.

23. Despite Plaintiffs’ reasonable, peaceful, and lawful conduct, LMPD

officers were directed to “encircle” them.

Church, as permitted by Mayor Fischer’s executive order.

25. Plaintiffs received the following criminal charges as a result of the

Presiding Judge: HON. MITCH PERRY (630267)

to disburse,” a misdemeanor per KRS 525.160; 3) “unlawful assembly,” a

26. Plaintiffs pled not guilty to all charges.

27. All charges were dismissed on or about November 16, 2020.

28. Plaintiff Attica Scott is an elected member of the Kentucky House of

Representatives, representing the 41st district.

29. Plaintiff Ashanti Scott is a college student at the University of

30. Plaintiff Shameka Parrish-Wright is an Operations Manager at The

are relevant to this Complaint.

COUNT I: CONSTITUTIONAL VIOLATIONS

32. Plaintiffs reallege and incorporate by reference each and every

allegation stated above as if separately repleaded in full herein.

charged with multiple criminal offenses, including one felony.

Presiding Judge: HON. MITCH PERRY (630267)

35. By virtue of their unlawful arrests, Plaintiff’s’ rights under the

Constitution of the Commonwealth of Kentucky were violated, including, but not

limited to, their rights to due process and equal protection.

constitute a violation of the Constitution of the Commonwealth of Kentucky and

Plaintiffs’ rights to due process and equal protection.