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| | COMPLAINT |
 | | The Defendant, SHANON PICKARD, is a citizen and resident of Cheatham County, Tennessee, and was at all times material to the allegations in this Complaint, acting in his capacity as a Dispatch Operator employed by the State of Tennessee and was acting under color of state law. |
 | | The Defendant, Lieutenant Jerry Andrews, is believed to be a citizen and resident of Putnam County, Tennessee, and was at all times material to the allegations in this Complaint, acting in his capacity as a Lieutenant State Trooper and Shift Commander for the Tennessee Highway Patrol employed by the State of Tennessee. |
 | | The THP dispatchers, the City of Cookeville dispatchers, Defendants Chesebro and Graham, and Defendants Hood, Brock, and Pickard, negligently misinterpreted information from an unknown and unreliable informant, and set in motion the series of events that resulted in the violations of the Plaintiffs’ civil rights. |
| www.putnampit.com /hall/SMOAK.htm (4017 words) |
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