COMMONWEALTH OF KENTUCKY BREATHITT CIRCUIT COURT CASENO, 16-C-QOLLS JASON CRIGGER PLAINTIFF, vs. ‘COMPLAINT DARRELL STEVE MCINTOSH, Individually and Oficial Capacity asa Breathitt County Deputy Sheri his DEFENDANT ‘Serve: Darrell Steve Melntosh Re 1812 Jackson, Kentucky 41339 Serve: Hon. Gary Salyers County Attorney 1149 Main Street, Jackson, Kentucky 41339 Comes the Plaintiff Jason Crigger, and for his complaint against the Defendant, Darrell Steve Mcintosh, Individually, and in his oficial capacity as a Breathitt County Deputy Sherif, and states as follows; |The Plaintiff states that he is employed as a icensed EMT with Arrow= Med Ambulance. 2. The Defendant, Darrell Steve Metntosh, i a deputy sheriff with the Breathitt County Sheriff's Department, and, as such, drives a Breathitt County Police Cruiser and claims wo possess arrest powers 3. ThePI it's employer, Arow-Med Ambulance, is currently involved in civil dispute with the Defendant, Darrel Steve MeIntosh, who owns a competing ambulance service. The related civil action is styled Arrow-Med Ambulance vs. DarrellSteve Melntosh and was filed on October 21, 2015, in the Breatitt Cireuit Court (15-Cle 0240), ‘The Plaintiff states that on June 22, 2016, he was in the process of ‘eanspoting a patient from a dialysis treatment in Jackson, Breathitt County, Kentucky, to her home in Campton, Wolfe County, Kentucky. 5. “The Pai states that on Highnay 15 in Jackson, Breathit Couny, Kentucky, the Defendant, Darrell Steve McIntosh, activated his emergency lights and siren and caused the ambulance that the Plaintiff was operating to be pulled over, The Defendant, Darrell Steve Melntosh, acting under color of sate law then caused the Plaintito be detained for approximately five minutes onthe side ofthe road, while the Aatyss patent remained in the back ofthe ambulance, 6 ‘The Plaintiff states that he was falsely imprisoned forthe five minutes and falsely arested without probable case by the Defendant, During the five minute detention ofthe Plait, the Defendant, Darrell Steve Melntosh, proceeded to verbally tarass the Pai over a private civil allegation that somehow the PlaintfFand others ‘wer involved in some type of activity to cause him to be wrongly filmed, presumably related to the civil Ikigation (15-C.00240), Atone point the Defendant, Mefntosh told ‘he Plain that ie was fling the Defendant that that would be some type of luspecified HIPAA violation, The PlaintifT was not charged with any crime during the five minute detention. 7. The temporary arrest and detention of the Plaintiff was without probable «cause and was solely eaused by the Defendant misusing his position as a Deputy Sheriff ‘o intimidate the Plaintiff as to the unrelated civil litigation (15-C1-00240) between‘Atrow-Med Ambulance and the Defendant's ambulance company. As a result ofthe Defendants actions, the Plain was falsely detained and imprisoned without just cause and without probable cause, thus violating his civil rights under 42 USC 1983 and the Fourth Amendment othe United States Constitation. 8. The Plaintiff further alleges a state law claim of false imprisonment in that the Defendant misuse his authority a a Breaths Deputy Sherif to cause him to be detained for reasons unrelated 1 any legitimate law enforcement purpose. 9. The Plain tates asa result of the Defendants actions, he has suffered humiliation, embarassment, pain and suffering asthe evens took plein full view of| the traveling pubic. 10, The Plant further states tha if the Defendant is not restrained, he belioves the Defendant, and those aetng in concert with the Defendant, will continue to harass other employees Armow-Med Ambulance and potentially eause harm to other ‘employees or thie patients in the Artow-Med Ambulances. 11. The Plaintfseeks punitive damages in that he Defendant ated with ‘alice and hada vindictive purpose in causing the Plano be pulled over and detained WHEREFORE, te Plait seeks rele as follows: 1. Judgment against the Defendant in both his individual and offical capacity. Compensation forthe Plaintf?'s humiliation and suffering, and embarassment,3. Punitive damages against the Defendant Metntosh in his ind capacity 4. Injunetive reliet mandating thatthe Defendant, or anyone acting in concert. \ith the Defendant cease interfering withthe Plaintiff or the Plaintiff's employer, Arrow- Med Ambulance “Teal by ju Any and al other relief deemed appropriate, including attorney fees and costs pursuant to 42 U.S.C, 1988, RESPECTFULLY SUBMITTED, PILLERSDORF, DEROSSETT & LANE 124 WEST COURT STREET PRESTONSBURG, KY 41633 ‘Telephone No. (606) 886-6090 Telecopier No. (606) $86-6145