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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF LOUISIANA
LAFAYETTE DIVISION
JASON BRUNGARDT
VERSUS
MICHAEL W. NEUSTROM, in his official
capacity as the duly elected Sheriff of the
Parish of Lafayette; BRANDON GALLIEN,
individually and in his official capacity as a
Deputy Sheriff for the Parish of Lafayette;
MICHAEL G. MCSHEFFREY, individually
and in his official capacity as a Deputy Sheriff
for the Parish of Lafayette; SCARLA N.
CELESTINE, individually and in his official
capacity as a Deputy Sheriff for the Parish of
Lafayette; and ADRIAN THERIOT,
individually and in his official capacity as a
Deputy Sheriff for the Parish of Lafayette
CIVIL ACTION NO.:
JUDGE:
MAGISTRATE:
JURY DEMANDED
COMPLAINT FOR DAMAGES
TO THE HONORABLE, THE UNITED STATES DISTRICT COURT IN AND FOR THE
WESTERN DISTRICT OF LOUISIANA:
INTRODUCTION
This is an action for money damages brought pursuant to 42 U.S.C. § 1983 and 1988, and
under the laws of Louisiana against Michael W. Neustrom, in his official capacity as the duly-
elected Sheriff of the Parish of Lafayette; Brandon Gallien, individually and in his official as a
Deputy Sheriff for the Parish of Lafayette; Michael G. McSheffrey, individually and in his
official as a Deputy Sheriff for the Parish of Lafayette; Scarla N. Celestine, individually and in
her official as a Deputy Sheriff for the Parish of Lafayette and Adrian Theriot, individually and
in his official as a Deputy Sheriff for the Parish of Lafayette.
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JURISDICTION
1.
This action for monetary damages is brought pursuant to 42 U.S.C.1983 as well as the
Constitution of the United States and the State of Louisiana, the United States Code, Louisiana
Civil Code and the Revised Statues of Louisiana. Jurisdiction is founded on 28 U.S.C. § 1331
and 28 U.S.C. § 1343. The plaintiff further invokes jurisdiction of this Honorable Court, under
28 U.S.C. § 1367 to adjudicate claims arising under the Laws of the State of Louisiana including
but not limited to Article 2315, et seq, of the Louisiana Civil Code.
2.
The complaints further allege the Defendants are liable in solido (or according to such
determination as the Court may make) to the plaintiff for the damages, costs, fees and expenses
described in this Complaint for the reasons described in the following sections of this Complaint.
VENUE
3.
Venue lies in this Court under 28 USC § 1391(b) (2), as the events giving rise to this
claim occurred within this judicial district.
PARTIES
4.
Complainant, JASON BRUNGARDT, is a person of the full age of majority and a
resident of Lafayette Parish, Louisiana.
5.
Made defendants herein are the following:
(1) MICHAEL W. NEUSTROM, in his official capacity as the duly elected Sheriff
of the Parish of Lafayette; upon information and belief, the duly-elected Sheriff of
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the Parish of Lafayette, State of Louisiana, and the employer of Lafayette Parish
Sheriff’s Deputies. Michael W. Neustrom is sued herein in his official capacity as
the duly-elected Sheriff of the Parish of Lafayette, who can be served at his place
of employment, the Lafayette Parish Sheriff’s Office, at 316 W. Main Street,
Lafayette, Louisiana;
(2) BRANDON GALLIEN, both individually and in his official as a Deputy Sheriff
for the Parish of Lafayette; upon information and belief, a person of the full age of
majority and a resident of the Parish of Lafayette, who can be served at his
residence at 233 Roman Road, Opelousas, Louisiana;
(3) MICHAEL G. MCSHEFFREY, both individually and in his official as a
Deputy Sheriff for the Parish of Lafayette; upon information and belief, a person
of the full age of majority and a resident of the Parish of Lafayette, who can be
served at his residence at 1113 Tolson Road, Lafayette, Louisiana;
(4) SCARLA N. CELESTINE, both individually and in her official as a Deputy
Sheriff for the Parish of Lafayette; upon information and belief, a person of the
full age of majority and a resident of the Parish of Lafayette, who can be served at
her residence at 206 Dijon Drive, Lafayette, Louisiana; and
(5) ADRIAN THERIOT, both individually and in his official as a Deputy Sheriff for
the Parish of Lafayette; upon information and belief, a person of the full age of
majority and a resident of the Parish of Lafayette, who can be served at his
residence at 403 Gravouia Road, Breaux Bridge, Louisiana.
6.
The right of jury trial is herein requested under the Federal Rules of Civil Procedure.
COMMON FACTS ALLEDGED IN SUPPORT OF LIABILITY –
ALL CAUSES OF ACTION
7.
At all times pertinent, the complainant, JASON BRUNGARDT, affirms and attests that:
8.
On April 7, 2014, petitioner, Jason Brundgardt, was incarcerated at the Lafayette Parish
Correctional Center located at 916 Lafayette Street, Lafayette, Louisiana.
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9.
The Lafayette Parish Correctional Center is operated under the direction of Sheriff
Michael W. Neustrom, the policy maker for the Lafayette Parish Sheriff’s Office.
10.
At approximately 3:00 a.m. Jason Brungardt was awaiting booking in the open booking
area of the Lafayette Parish Correctional Center. The open booking area is large area within the
Lafayette Parish Correctional Center compromised of a seating area which allows for staff to
closely monitor and interact with offenders awaiting completion of the booking process. The area
is also equipped with multiple cameras.
11.
Jason Brungardt was escorted from the open booking area to a booking isolation cell. The
booking isolation cell is a small, narrow cell containing a concrete bench and toilet. Visibility in
and out of the cell is limited to a small window on the door and/or wall.
12.
Approximately thirty minutes after being placed in the cell Jason Brungardt placed his
foot into the drain hole of the toilet and flushed the toilet.
13.
Deputy staff oberserved the actions of Jason Brungardt and advised him to stop. Mr.
Brungardt complied.
14.
Deputy Brandon Gallien and Deputy Michael McSheffrey then entered into the cell and
instructed Mr. Brungardt to laydown on the floor of the cell. Mr. Brungardt complied with the
instructions and did not offer any resistance. At no time did Mr. Brungardt pose a threat or
danger to the safety of Deputy Brandon Gallien and Deputy Michael McSheffrey.
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15.
Deputy Brandon Gallien and Deputy Michael McSheffrey each grabbed an arm of Jason
Brungardt and raised his arms up behind his back while he lay on his belly.
16.
While Jason Brungardt lay compliant on the floor of the cell Brandon Gallien and/or
Michael G. McSheffrey and/or Scarla N. Celestine and/or Adrian Theriot began to strike him.
17.
Jason Brungardt laid scared and in agony on the floor with his eyes closed and offering
no resistance while he was struck several times in his torso.
18.
Based on information and belief, Jason Brungardt was kicked approximately a dozen
times while he lay defenseless on the ground.
19.
Several other Lafayette Parish Sheriff’s Deputies entered into the cell at one point Jason
Brungardt was “pepper sprayed”.
20.
While Jason Brungardt lay limp in agonizing pain and without offering any resistance
Lafayette Parish Sheriff’s Deputies began to roll him over on his back and continued to strike
him.
21.
Based on information and belief, Deputy Michael G. McSheffrey stated to other staff
members ‘he has had enough’. Jason Brungardt reported to staff that he was having trouble
breathing, but no one showed any concern for his well being.
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22.
Jason Brungardt was then placed in a restraint chair where his arms, legs and chest were
strapped down preventing him from moving. Jason Brungardt sat in agonizing pain from the
brutal attack, continued to have difficulty breathing and his skin burning from the pepper spray.
23.
Approximately thirty minutes later Jason Brungardt was removed from the restraint chair
and brought to a shower area where he was finally allowed to wash himself on the pepper spray.
24.
Jason Brungardt was instructed to put on an orange prison jumpsuit, but was unable to do
so on his own and had to be assisted by Lafayette Parish Sheriff’s Deputies.
25.
Approximately one hour after being subjected to the attack, experiencing agonizing pain
and continously complaining of problems breathing Jason Brungardt was transported to a local
hospital for evaluation and treatment.
26.
While at the hospital it was determined that Jason Brungardt had suffered four full
fractured ribs and a punctured lung from the attack requiring a chest tube be inserted into him.
27.
Jason Brungardt remained hospitalized for approximately three days before returning to
the Lafayette Parish Correctional Center.
28.
The force used against Jason Brungardt was excessive and was in now way related to
carrying out a legitimate penalogical interest.
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29.
The attack was maliciously and sadistically carried out and continued even though Jason
Brungardt did not offer any resistance.
30.
Based on information and belief, the staff involved in the incident took steps to disguise,
deceive and cover-up their actions and/or involvement including falsifying information contained
in their reports and/or deliberately misstating the facts and circumstances surrounding the
incident.
31.
Based on information and belief, Sheriff Deputy Scarla N. Celestine, participated in the
attack and/or cover-up following the attack.
32.
Based on information and belief, Sheriff Deputy Adrian Theriot, participated in the attack
and/or cover-up following the attack.
33.
Based on information and belief, Adrian Theriot, an employee believed to be involved in
a very close relationship with the daughter of the Chief Deputy Arthur Lebreton, failed to report
the incident to others out of fear of retaliation, clearly illustarting how deeply-entrenched the
culture of retaliation for reporting inappropriate and even criminal behavior of other employees
is.
34.
Michael W. Neustrom has failed and/or refused to hold accountable high-ranking
supervisors in the face of significant nonfeasance and/or malfeasance by these supervisors and/or
by the officers they oversee.
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35.
Despite the defendants knowledge of the serious problem of improper and excessive use
of force amongst staff of the Lafayette Parish Sheriff’s Office, Michael W. Neustrom has
repeatedly failed to take reasonable steps to address the probem.
36.
Michael W. Neustrom have failed to put in place adequate policies governing use of
force. Policies are grossly lacking in specificity about typical force scenarios that are likely to
arise in the jails and the proper way for personnel assigned to Corrections to handle those
situations.
37.
The insufficiency of the force policies makes it almost impossible to train deputies
adequately on the proper use of force.
38.
Defendants have abjectly failed to develop policies that address the problem of brutality
with employees of the Lafayette Parish Sheriff. Policies regarding use of force, investigation of
use of force, discipline for deputies who have used excessive force or failed to report use of
force, supervisors who have mishandled investigations of force, and training of deputies and
supervisors all fail to meaningfully address the problem. When allegations of deputy violence
arise, they are infrequently investigated, and deputies are rarely disciplined. Defendants have
failed to track incidents of violence, even though systems for doing so are readily available and
commonly used. In this way, Defendants have fostered a pattern and practice of deputy violence
against inmates, which places inmates at a significant, ongoing risk of serious and irreparable
injury. Deputies and supervisors alike have come to believe that committing abuse (or failing to
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investigate abuse) will have absolutely no negative impact on one’s career. As a result, physical
abuse by deputies continues unchecked. The persistent failure or refusal of Michael W.
Neustrom to supervise deputies properly or take action to curb the misconduct demonstrates the
Defendants’ deliberate indifference to the petitioners’ right to reasonable protection from harm.
39.
The failures of Defendant Michael W. Neustrom to take appropriate steps to curb the
pattern of brutality within the Lafayette Parish Sheriff’s Office, as described in this complaint,
constitutes deliberate indifference to petitioner’s basic need for reasonable protection from harm
and violates plaintiff’s right to be free from cruel and unusual punishment, including physical
abuse and intimidation, degrading, cruel, and sadistic treatment, and the wanton and needless
infliction of pain, as guaranteed to petitioner by the Eighth and Fourteenth Amendments to the
Unites States Constitution.
40.
At all times material hereto, Sheriff Deputy Brandon Gallien, was in the course and scope
of his employment with the Lafayette Parish Sheriff’s Office and was acting under color of law,
while employed, controlled, and supervised by Michael W. Neustrom, as the duly-elected Sheriff
of the Parish of Lafayette.
41.
At all times during the offenses described above, Sheriff Deputy Brandon Gallien was
engaged in a personal venture. Deputy Gallien performed the various actions described above
and let his physical presence and support and the authority of his office be known during the said
events.
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42.
At all times material hereto, Sheriff Deputy Michael G. McSheffrey, was in the course
and scope of his employment with the Lafayette Parish Sheriff’s Office and was acting under
color of law, while employed, controlled, and supervised by Michael W. Neustrom, as the duly-
elected Sheriff of the Parish of Lafayette.
43.
At all times during the offenses described above, Sheriff Deputy Michael G. McSheffrey
was engaged in a personal venture. Deputy McSheffrey performed the various actions described
above and let his physical presence and support and the authority of his office be known during
the said events.
44.
At all times material hereto, Sheriff Deputy Scarla N. Celestine, was in the course and
scope of his employment with the Lafayette Parish Sheriff’s Office and was acting under color of
law, while employed, controlled, and supervised by Michael W. Neustrom, as the duly-elected
Sheriff of the Parish of Lafayette.
45.
At all times during the offenses described above, Sheriff Deputy Scarla N. Celestine was
engaged in a personal venture. Deputy Celestine performed the various actions described above
and let his physical presence and support and the authority of his office be known during the said
events.
46.
At all times material hereto, Sheriff Deputy Adrian Theriot, was in the course and scope
of his employment with the Lafayette Parish Sheriff’s Office and was acting under color of law,
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while employed, controlled, and supervised by Michael W. Neustrom, as the duly-elected Sheriff
of the Parish of Lafayette.
47.
At all times during the offenses described above, Sheriff Deputy Adrian Theriot was
engaged in a personal venture. Deputy Theriot performed the various actions described above
and let his physical presence and support and the authority of his office be known during the said
events.
48.
As a direct and proximate result of the said incidents by the defendant, petitioner, Jason
Brungardt, suffered the following injuries and damages:
(a) Use of excessive force in violation of his civil rights under 42 U.S.C. §1983;
(b) Pain and suffering;
(c) Mental anguish, and emotional pain and suffering;
(d) Medical bills and expenses;
(e) Loss of enjoyment of life;
(f) For all damages allowed under Civil Code Article 2315;
(g) Attorney’s fees pursuant to 42 U.S.C. § 1988;
(h) Punitive damages against Sheriff Michael W. Neustrom in his personal capacity;
(i) Punitive damages against Sheriff Deputy Brandon Gallien in his personal
capacity;
(j) Punitive damages against Sheriff Deputy Michael G. McSheffrey in his personal
capacity;
(k) Punitive damages against Sheriff Deputy Scarla N. Celestine in her personal
capacity; and
(l) Punitive damages against Sheriff Deputy Adrian Theriot in his personal capacity.
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49.
The actions of the defendant violated the following, clearly established and well-settled
federal and state constitutional rights of Jason Brungardt to be:
(a) Free from the use of excessive and unreasonably justified force against his person;
COUNT ONE:
42 U.S.C. §1983 AGAINST INDIVIDUAL DEFENDANT
50.
By reason of the allegations set forth in paragraphs 1 through 49, petitioner, Jason
Brungardt, was deprived by the Defendants of his rights, under the Eighth and Fourteenth
Amendments to the United States Constitution, to due process of law, right to be free from
punishment without due process, gratuitous and excessive force, degrading and sadistic
treatment.
51.
Petitioner, Jason Brungardt, claims damages for the injuries set forth above under 42
U.S.C. § 1983 against the defendant, Sheriff Michael W. Neustrom, in his official capacity as a
Sheriff for the Parish of Lafayette, for violation of his constitutional rights under Color of Law.
52.
Petitioner, Jason Brungardt, claims damages for the injuries set forth above under 42
U.S.C. § 1983 against the defendant, Brandon Gallien, both in his individual capacity and in his
official capacity as a Deputy Sheriff for the Lafayette Sheriff, for violation of his constitutional
rights under Color of Law.
53.
Petitioner, Jason Brungardt, claims damages for the injuries set forth above under 42
U.S.C. § 1983 against the defendant, Michael G. McSheffrey, both in his individual capacity
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and in his official capacity as a Deputy Sheriff for the Lafayette Sheriff, for violation of his
constitutional rights under Color of Law.
54.
Petitioner, Jason Brungardt, claims damages for the injuries set forth above under 42
U.S.C. § 1983 against the defendant, Scarla N. Celestine, both in his individual capacity and in
his official capacity as a Deputy Sheriff for the Lafayette Sheriff, for violation of his
constitutional rights under Color of Law.
55.
Petitioner, Jason Brungardt, claims damages for the injuries set forth above under 42
U.S.C. § 1983 against the defendant, Adrian Theriot, both in his individual capacity and in his
official capacity as a Deputy Sheriff for the Lafayette Sheriff, for violation of his constitutional
rights under Color of Law.
COUNT TWO:
ASSAULT AND BATTERY AGAINST INDIVIDUAL DEFENDANT
56.
Paragraphs 1 through 49 are incorporated herein by reference as though fully set forth.
57.
Defendant, Deputy Sheriff Brandon Gallien assaulted and battered Jason Brungardt, in
violation of Louisiana state law, specifically, La. C.C. art. 2315, et seq.
58.
Defendant, Deputy Sheriff Michael G. McSheffrey assaulted and battered Jason
Brungardt, in violation of Louisiana state law, specifically, La. C.C. art. 2315, et seq.
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59.
Defendant, Deputy Sheriff Scarla N. Celestine assaulted and battered Jason Brungardt, in
violation of Louisiana state law, specifically, La. C.C. art. 2315, et seq.
60.
Defendant, Deputy Sheriff Adrian Theriot assaulted and battered Jason Brungardt, in
violation of Louisiana state law, specifically, La. C.C. art. 2315, et seq.
61.
At all times material and present, defendant Deputy Sheriff Brandon Gallien, was acting
within the course and scope of his employment with the Lafayette Parish Sheriff’s Office, and
therefore, Michael W. Neustrom as the duly-elected Sheriff of the Parish of Lafayette is
vicariously liable pursuant to Louisiana state law for the assault and battery, committed by its
employee, Deputy Sheriff Brandon Gallien.
62.
At all times material and present, defendant Deputy Sheriff Michael G. McSheffrey, was
acting within the course and scope of his employment with the Lafayette Parish Sheriff’s Office,
and therefore, Michael W. Neustrom as the duly-elected Sheriff of the Parish of Lafayette is
vicariously liable pursuant to Louisiana state law for the assault and battery, committed by its
employee, Deputy Sheriff Michael G. McSheffrey.
63.
At all times material and present, defendant Deputy Sheriff Scarla N. Celestine, was
acting within the course and scope of his employment with the Lafayette Parish Sheriff’s Office,
and therefore, Michael W. Neustrom as the duly-elected Sheriff of the Parish of Lafayette is
vicariously liable pursuant to Louisiana state law for the assault and battery, committed by its
employee, Deputy Sheriff Scarla N. Celestine.
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64.
At all times material and present, defendant Deputy Sheriff Adrian Theriot, was acting
within the course and scope of his employment with the Lafayette Parish Sheriff’s Office, and
therefore, Michael W. Neustrom as the duly-elected Sheriff of the Parish of Lafayette is
vicariously liable pursuant to Louisiana state law for the assault and battery, committed by its
employee, Deputy Sheriff Adrian Theriot.
COUNT THREE:
65.
Paragraphs 1 through 49 are incorporated herein by reference as though fully set forth.
66.
Prior to April 7, 2014, Michael W. Neustrom as the duly-elected Sheriff of the Parish of
Lafayette developed and maintained policies or customs exhibiting deliberate indifference to the
constitutional rights of the people of Lafayette Parish, specifically regarding the use of excessive
force and/or unjustified force, which caused the violation of Jason Brungardt’s constitutional
rights.
67.
It was the policy and/or custom of Michael W. Neustrom as the duly-elected Sheriff of
the Parish of Lafayette to inadequately and improperly investigated complaints of deputy
misconduct, and the acts of misconduct which were instead tolerated.
68.
It was the policy and/or custom of the Michael W. Neustrom as the duly-elected Sheriff
of the Parish of Lafayette, to inadequately supervise and/or train its sheriff deputies, including
the defendant deputy thereby failing to adequately discourage further constitutional violations on
the part of its sheriff deputies.
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69.
As a result of the above described policies and/or customs, Deputy Sheriff’s for the
Parish of Lafayette, including the defendants, Deputy Brandon Gallien, Deputy Michael G.
McSheffrey, Deputy Scarla N. Celestine and Deputy Adrian Theriot, believed that their actions
would not be properly monitored by supervisory officers and that misconduct would not be
investigated or sanctioned, but would be tolerated.
70.
The above described policies and customs demonstrate a deliberate indifference on the
part of the policy makers of the Parish of Lafayette to the constitutional rights of persons within
the Parish of Lafayette and were the cause of the violations of plaintiff’s rights alleged herein.
COUNT FOUR:
SPOILIATION OF THE EVIDENCE
71.
Paragraphs 1 through 49 are incorporated herein by reference as though fully set forth.
72.
Defendant’s intentional destroyed, mutilated, altered, and/or concealed evidence
including but not limited to: statements and reports.
COUNT FIVE:
73.
Paragraphs 1 through 49 are incorporated herein by reference as though fully set forth.
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74.
Further, plaintiff specifically alleges defendant, Michael W. Neustrom as the duly-elected
Sheriff of the Parish of Lafayette, condoned the establishment of practices, procedures, customs,
and policies, written and unwritten, which allowed the deprivation of plaintiff’s constitutional
rights as set out herein. Such written and unwritten practices, procedures, customs, and policies
include but are not limited to:
(a) Inadequate and improper training, education, supervision,
and discipline of law enforcement agents/officers/deputies
commissioned and employed by it;
(b) Condoning and allowing police behavior that has been
declared unconstitutional and unlawful;
(c) Inadequate and improper procedures, policies and practices
for identifying and taking appropriate action against law
enforcement agents/officers/deputies and employees who
are in need of re-training, corrective measures, re-
assignment, or other disciplinary and non-disciplinary
actions through a positive and early warning system
designed to prevent the violations of citizens’
constitutional and civil rights, including those of plaintiff;
(d) Negligent selection, appointment, and retention of Brandon
Gallien, Michael G. McSheffrey, Scarla N. Celestine, and
Adrian Theriot;
(e) Failure to conduct appropriate and adequate internal
investigations;
(f) Failure to correct a police “code of silence”;
(g) Failure to provide a meaningful avenue for independent and
impartial internal investigations;
(h) Vicarious liability for the acts and omissions of Brandon
Gallien, Michael G. McSheffrey, Scarla N. Celestine, and
Adrian Theriot under the doctrine of respondeat superior
and La. C.C. Art. 2317; and
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(i) All other acts and omissions which constitute actionable
injury, including negligence, intentional negligence and
negligence per se under Louisiana law.
75.
As a result of their unlawful and unconstitutional conduct, defendants, Michael W.
Neustrom, in his official capacity as the duly-elected Sheriff of the Parish of Lafayette; Brandon
Gallien, individually and in his official as a Deputy Sheriff for the Parish of Lafayette; Michael
G. McSheffrey, individually and in his official as a Deputy Sheriff for the Parish of Lafayette;
Scarla N. Celestine, individually and in his official as a Deputy Sheriff for the Parish of
Lafayette and Adrian Theriot, individually and in his official as a Deputy Sheriff for the Parish
of Lafayette, jointly, individually and in solido, deprived plaintiff of his civil rights under 42
U.S.C. § 1983. Said defendants are liable, individually, jointly and in solido, unto plaintiff for
such damages.
76.
The malicious actions, lack of actions, breach of duties, negligence and gross negligence
of defendants individually and/or together caused physical and emotional harm and ultimately
the injuries to Jason Brungardt and constitute wrongful and intentional torts under Louisiana
Civil Code Articles 2315, 2316, and 2320.
77.
The defendant, Michael W. Neustrom, as the duly-elected Sheriff of the Parish of
Lafayette, acted in violation of Louisiana Civil Code Article 2315 and 2316 by negligently
hiring, training, supervising and disciplining of the defendants, Deputy Sheriff Brandon Gallien,
Deputy Sheriff Michael G. McSheffrey, Deputy Sheriff Scarla N. Celestine, and Deputy Sheriff
Adrian Theriot, regarding constitutional rights and/or the use of force.
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78.
As a direct and proximate cause of the negligence and intentional acts, and constitutional
torts and violations of his civil rights under 42 U.S.C. § 1983 and other Louisiana laws,
petitioner suffered damages of physical harm and severe mental anguish.
WHEREFORE, petitioner, Jason Brungardt, prays that a jury trial be had as to the issues
triable by jury; that compensatory damages to be fixed by a jury against the defendants,
individually, jointly and in solido, be awarded; that punitive damages to be fixed by a jury
against the defendants, Sheriff Michael W. Neustrom, Deputy Sheriff Brandon Gallien, Deputy
Sheriff Michael G. McSheffrey, Deputy Sheriff Scarla N. Celestine, and Deputy Sheriff Adrian
Theriot be awarded; that all costs of this action be assessed against the defendants, individually,
jointly and in solido; that attorney’s fees be awarded herein to plaintiff and that such attorney’s
fees be assessed against the defendants, individually, jointly and in solido; and, for any and all
other relief that this Court deems just and proper.
Respectfully submitted:
L. CLAYTON BURGESS, A P.L.C.
605 West Congress Street
Lafayette, Louisiana 70502-52 7050150
Telephone: (337) 234-7573
Facsimile: (337) 233-3890
s/L. Clayton Burgess
L. CLAYTON BURGESS, T.A. (22979)
Attorney for Plaintiff
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