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accompanied by defendants Sergeant Gayle, Officer B riggs, and
Officer Johnson. The police explained to Plaintiff that Mr.
Hales had come to collect his guns and clothing and that he
wished to leave the residence. Plaintiff asked to speak with
Mr. Hales, but the police repeated that he wished t o leave the
residence, whereupon Plaintiff shut and locked the front door,
barricaded the front door with a chair, and proceed ed to lock
the other doors. Mr. Hales thereafter retrieved a crowbar from
a shed and used it to forcibly open the rear slidin g glass door
of the residence. Plaintiff asserts that she then ―attempted to
calm [Mr. Hales] down, stating, ‗ Honey, please don’t do this’ ,
and she reached over and touched [Mr. Hales]‘s left wrist with
her right hand in a non-threatening manner, whereup on one of the
Officers said, ‗That‘s an assault and batter.‘‖ Co mpl. ¶ 10.
Plaintiff further alleges that then, ―[w]ithout war ning or
prior notice, OFFICER BRIGGS handcuffed [Plaintiff‘ s] hands
behind her ba ck and placed her in a police cruiser.‖ Id. ¶ 11.
Plaintiff ―immediately complained that the handcuff s were too
tight on her right wrist and that the circulation o n her right
wrist and hand was being cut off, resulting in numb ness in her
right hand and f ingers.‖ Id. Plaintiff ―continued to complain
while en route to the police station; however, her complaints
were ignored.‖ Id. Jump to an indexed page (39 of 39)