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Repository Story- man sues former Perry Police Chief, says he was framed.

IN THE COURT OF COMMON PLEAS
STARK COUNTY, OHO

MATTHEW D. RUBLE
Plaintiff,

v.

TIMOTHY E. ESCOLA

and

JANINE ENGLAND

and

BOARD OF TRUSTEES OF
PERRY TOWNSHIP, STARK COUNTY, OHIO
3111 Hilton NW
Massillon, Ohio 44646

COMPLAINT

Now comes the Plaintiff, Matthew D. Ruble, by and through his undersigned counsel, and for his Complaint against the above-named Defendants states as follows:
PARTIES, JURISDICTION AND VENUE

1.    At all times relevant herein, Plaintiff Matthew Ruble was an individual who resided in Liberty, Township, Ohio, near Cincinnati, Ohio.

2.    At all times relevant herein, Defendant Timothy E. Escola was an individual who resided in the City of North Canton, County of Stark, and State of Ohio, and was the Chief of Police for the Perry Township Police Department and was therefore an employee of Defendant The Board of Trustees for Perry Township, Stark County, Ohio.
3.    At all relevant times herein, Defendant Janine England aka Janine McMahon, hereinafter referred to as Defendant “Janine England”), was an individual who resided in Wadsworth, Ohio, County of Medina and State of Ohio and was a part-time police officer with the Perry Township Police Department and was therefore an employee of Defendant The Board of Trustees for Perry Township, Stark County, Ohio.
4.    Defendant The Board of Trustees for Perry Township, Stark County, Ohio, at all relevant times herein, was a Township government, a form of limited self-government, organized under Chapter 504 of the Ohio Revised Code and is comprised of three elected Township Trustees and is considered a sui juris entity. At all times relevant herein, Defendant The Board of Trustees for Perry Township, Stark County, Ohio, was the employer of Defendants Timothy Escola and Janine England, while Defendants Escola and England were employed as police officers with the Perry Township Police Department.
5.    This Court has jurisdiction over this matter and over the parties.
6.    This matter is properly venued with this Court.
BACKGROUND ALLEGATIONS
7.    On Wednesday, May 13, 2009, at approximately 3:00 p.m., Defendant Janine England, a part-time Perry Township Police Officer, was dispatched to a private home on Woodlawn Avenue NW in Perry Township, Stark County, Ohio to investigate a possible burglary.  When Defendant England arrived at this personal residence, the homeowner/victim reported that $215.00 in cash was missing from his home.  As Defendant England continued her investigation, she questioned a neighbor who lived across the street from the burglary victim.  The neighbor/witness reported seeing a blue Dodge Neon in the victim’s driveway earlier that day, and observed one man wearing khaki shorts and a khaki hat looking through the garage windows and knocking on the victim’s front door.  However, the neighbor/witness thought the unknown and unidentifiable male was known to the burglary victim and she did not believe a crime was occurring.  Defendant England reported “no suspects at this time.”
8.    On May 17, 2009, the burglary victim reported to Defendant England that one of his personal checks was cashed at a local bank and that he did not write or otherwise authorize anyone to write that particular check.
9.    On May 18, 2009, Defendant England visited the bank identified by the burglary victim and obtained a copy of the victim’s check.  Defendant England observed that the check was written to “Richard Griffin” and contained the forged signature of the burglary victim.  Defendant England then obtained a copy of Richard Griffin’s drivers’ license that was used to cash the check.  Defendant England had the bank teller fill out a written statement concerning the bank transaction by Richard Griffin.
10.    Defendant England returned to the Perry Township Police Department to obtain information on Richard Griffin.  Defendant England learned that Mr. Griffin had a lengthy criminal history including, but not limited to, felony aggravated burglary and obstructing official business.
11.    On May 19, 2009, Defendant England and Defendant Timothy E. Escola, the Chief of the Perry Township Police Department, returned to the local bank and obtained a surveillance photograph of the male individual who cashed the burglary victim’s check.
12.    A photo line-up was presented to the bank teller and she positively identified Richard Griffin as the person who cashed the subject check.  As part of this photo line-up, the bank teller was required to complete a Perry Township Police Department form indicating that she was not influenced in her selection of the photograph and that she was 100% certain of her selected photograph.  Indeed, this form stated that the bank teller “must be 100% positive” in selecting the photograph of a perpetrator of a crime.
13.    After obtaining a positive photograph identification, Defendant England visited the last known address of Richard Griffin and spoke with Griffin’s former girlfriend.  The former girlfriend wrote a statement indicating that Griffin was still driving her blue Dodge Neon.  The former girlfriend then provided Defendant England a current address where Griffin was residing.
14.    Upon making contact with Richard Griffin, Defendant England observed that he was “visibly shaking, his hands were shaking uncontrollably” and the “vein on his forehead was pulsating” and his voice was “cracking and squeaking.”  When questioned by Defendant England, Griffin first claimed that the check he cashed was for a four wheeler he sold to a friend.  However, Defendant England noted that Griffin “quickly” changed his story and said “I am addicted to heroin and that’s what I used the money for.”  Upon further questioning, Griffin adamantly denied having any involvement with the Perry Township burglary, but then “quickly” recanted his story and claimed that he and “Matthew Ruble” burglarized the Perry Township home.  Mr. Griffin claimed that Matthew Ruble was the person who actually entered the Perry Township home and stole the cash and checks.  Defendant England noted in her report that Richard Griffin was “visibly crying and holding his face in his hands when he said, ‘I need help, please get me help for my habit.’” Mr. Griffin also admitted, “I was in withdraw and I needed the money.”  After obtaining this information from Mr. Griffin, Defendant England advised him to report to the Perry Police Department the next day.  Upon leaving Griffin’s residence, Defendant England observed a blue Dodge Neon parked near the residence and she photographed same for evidence.
15.    On May 20, 2009, Defendant England obtained authorization from the Massillon Prosecutor’s office to file felony burglary charges against Richard Griffin.
16.    On May 20, 2009, at approximately 11:15 a.m., Richard Griffin arrived at the Perry Township Police Department and Defendant England obtained two (2) written statements from Griffin concerning his involvement in the Perry Township burglary.  In Griffin’s first written statement, he indicated that Matthew Ruble entered the Perry Township home and committed the subject burglary while Griffin waited outside.
17.    Defendant England obtained a second written statement from Richard Griffin stating he wrote additional checks that were stolen from the Perry Township home to three other individuals and those checks were cashed by those individuals. Richard Griffin thereafter, but before June 1, 2009, admitted he lied and that the three individuals had nothing to do with the other checks that were cashed.  Griffin admitted that he forged the checks and cashed the checks himself.  Griffin was then arrested and transported and incarcerated into the Stark County Jail.
18.    Upon information and belief, Defendant England and Defendant Escola began to investigate Matthew Ruble.  Defendants Escola and England discovered that Matthew Ruble had no criminal history and only had minor traffic violations on his record.
19.    Upon information and belief, Defendant England and Defendant Escola also discovered that Matthew Ruble resided in the Cincinnati, Ohio area in Monroe Township.  Defendants England and Escola also discovered that Matthew Ruble was employed by Ziegler Tire in Monroe Ohio which is approximately a four (4) hour drive from Canton, Ohio (225 miles distance).
20.    Defendants England and Escola made telephone contact with Matthew Ruble, who was in Monroe Township.  Matthew Ruble was cooperative in the investigation and even offered to travel to the Perry Township Police Department on the weekend to avoid missing work and submit to any additional questioning.  Matthew Ruble also told Defendant Escola that he was working at the Ziegler Tire Company in Monroe Township at the time of the Perry Township burglary.  Indeed, on June 1, 2009, at 12:03 p.m., before any criminal charges were filed against Matthew Ruble, Matthew Ruble’s supervisor faxed a copy of Matthew Ruble’s time clock records to Defendants England and Escola demonstrating that Matthew Ruble was working at the Ziegler Tire in Monroe, Ohio on the date and time of the subject burglary involving Richard Griffin.
21.    During this investigation of Matthew Ruble, upon information and belief, Defendants England and Escola, who were both married, were actively involved in or were beginning an extra-marital affair.
22.    Upon information and belief, Defendants England and Escoloa knew that Richard Griffin’s statement implicating Matthew Ruble in the Perry Township burglary was not, standing alone, legally sufficient to justify a felony burglary charge against Matthew Ruble and was not legally sufficient in obtaining a finding of probable cause against Matthew Ruble as it related to this burglary.  This is especially true given Griffin’s lengthy criminal history, Griffin’s numerous lies concerning the Perry Township burglary, Griffin’s admitted heroin addiction, Griffin’s lies concerning the stolen, cashed checks, that Matthew Ruble resided and worked in the Cincinnati, Ohio area, the fact that Mr. Ruble adamantly stated that he was working on the date and time of the Perry Township burglary (which was subsequently verified through time card records that were faxed to Defendants England and Escola before any criminal charges were filed against Matthew Ruble), and Mr. Ruble’s complete lack of a criminal history.
23.    Despite the fact that all evidence clearly established that Matthew Ruble was not involved in the Perry Township burglary, Defendants England and Escola, upon information and belief, and in furtherance of their plan to secretly conduct their extra-marital affair in a distant location where they would not be recognized, conspired to falsify evidence against Matthew Ruble to justify a day-long trip together to the Cincinnati, Ohio area.
24.    As such, on Sunday May 30, 2009, at 9:00 a.m., Defendant England returned to the home of the neighbor/witness who lived across the street from the burglarized home in Perry Township, Ohio.
25.    The surprised neighbor/witness first questioned why Defendant England was still investigating the burglary because she understood “the guy who did it [Griffin] was in the Stark County Jail.”  Defendant England responded “there were two men that were involved in the burglary.”  Upon hearing this claim, the neighbor/witness reported that she only saw one (1) male at her neighbor’s home on the date of the burglary as she originally reported to Defendant England on May 13, 2009.
26.    Defendant England then presented to the neighbor/witness a “photo line-up” of six (6) men.  This “photo line-up” included a photograph of Matthew Ruble but contained no photograph of Richard Griffin.
27.    Unlike the previous photo line-up that Defendants England and Escola conducted with the bank teller, Defendant England did not present the neighbor/witness with the Perry Township Police Department form that a witness is required to sign to verify the witness was not influenced in their selection of a photograph and that they are 100% certain in their selection.
28.    Instead, when the “photo line-up” was presented by Defendant England, the neighbor/witness  told Defendant England that she could not select anyone because she did not see the perpetrator’s face, and the photographs in the “line-up” did not sufficiently reveal the height and physical make-up of the suspect.
29.    Nonetheless, Defendant England convinced the neighbor/witness to select an individual by stating, “well, if you had to select someone, who would you select.”  When the witness reluctantly eliminated three of the photographs, Defendant England advised the witness that “you are on the right track.”  The witness/neighbor again stated she was reluctant to choose from the three (3) remaining photographs.  Defendant England advised the neighbor/witness she needed to select one of the photographs.  Defendant England continued these suggestive statements until the neighbor/witness hesitantly selected Matthew Ruble’s photograph.  The visibly elated Defendant England then exclaimed, “That’s it.”  Although it was clear the witness did not feel comfortable participating in this “photo line-up”, and was even more uncomfortable selecting anyone because she did not see the perpetrator’s face, Defendant England falsely reported that the neighbor/witness “within the first five seconds” was “comfortable” selecting Matthew Ruble as the person who burglarized the Perry Township home.
30.    Upon information and belief, Defendant England, as part of her conspiracy with Defendant Escola, conducted this suggestive and improper “photo line-up” with the neighbor/witness so to intentionally mislead the Clerk of Courts in obtaining probable cause to issue an arrest warrant for Matthew Ruble.
31.    On June 1, 2009, at 12:00 p.m., Defendants England and Escola received a facsimile from Matthew Ruble’s supervisor of Matthew Ruble’s time cards which clearly demonstrated that Matthew Ruble was working at the Monroe, Ohio Ziegler Tire on the date and time of the Perry Township burglary.
32.    On June 1, 2009 at approximately 2:40 p.m., Defendant England, who was off-duty, and without first obtaining authorization from the Massillon Prosecutor’s Office, filed felony burglary charges against Matthew Ruble.  Defendant England presented false information to the Massillon Clerk of Courts to obtain probable cause for an arrest warrant to be issued for Matthew Ruble.  Once the arrest warrant was issued for Matthew Ruble, Defendant England caused same to be transmitted to the Monroe, Ohio  Police Department.
33.    After filing the felony burglary charge against Matthew Ruble, Defendants Escola and England, who was still off duty, returned to the Stark County Jail and requested Richard Griffin write another statement implicating Matthew Ruble in the Perry Township burglary. During this meeting, Defendants Escola and England directed Richard Griffin what to write, including the statement that Mr. Griffin had met Matthew Ruble at an Italo’s restaurant before the Perry Township burglary.
34.    During this meeting, Defendants Escola and England repeatedly assured Richard Griffin that if he “helped put Matthew Ruble at the Perry Township home,” Griffin would get better treatment in his criminal case.
35.    On June 2, 2009, at approximately 8:00 a.m., Defendants Escola and England met at the Perry Township Police Department for the purported purpose of driving to Monroe, Ohio to transport Matthew Ruble back to Stark County on his felony burglary charge.  Upon information and belief, Defendant Escola, while in his position as Police Chief, had never traveled outside the Stark County area to transport a prisoner.  Nevertheless, and as part of their conspiracy to frame Matthew Ruble so as to cover their personal tryst, Defendants Escola and England, while in plain clothes, drove a Perry Township Police Department cruiser to Monroe, Ohio.
36.    While Defendants Escola and England were en route to purportedly transport Matthew Ruble, the Monroe Police Department arrived at the Ziegler Tire in Monroe, Ohio at 9:00 a.m.
37.    The Monroe Police officer entered Ziegler Tire and arrested Matthew Ruble in the presence of his co-workers and supervisor/ boss.  Matthew Ruble was handcuffed, transported to the Warren County Jail, was searched, finger printed, photographed, and incarcerated.
38.    While Matthew Ruble sat in a jail cell, Defendants England and Escola were driving from Perry Township to Monroe, Ohio kissing and caressing each other, much of which was surreptitiously being recorded by the police cruiser video camera. Rather than go directly to the jail to pick up Matthew Ruble, Defendants England and Escola engaged in other activity that was clearly outside the scope of their employment until approximately 3:30 p.m.
39.    At approximately 4:00 p.m., on June 2, 2009, Defendants England and Escola arrived at the Ziegler Tire in Monroe, Ohio.  Defendants England and Escola questioned and obtained statements from Matthew Ruble’s supervisor and co-worker who both verified that Matthew Ruble was working on the date and time of the Perry Township burglary.  During this visit, Defendants England and Escola made false and disparaging remarks regarding Matthew Ruble, including the false claim that he was a criminal and a thief.
40.    Defendants England and Escola then left Ziegler Tire but did not arrive at the Warren County Jail until approximately three and a half (3_) hours later.  There is no record of the whereabouts of Defendants Escola and England during this 3_ hour period.
41.    At approximately 7:30 p.m., Defendants England and Escola arrived at the Warren County Jail to transport Matthew Ruble to the Stark County Jail.  Matthew Ruble was handcuffed and placed in the rear seat of the Perry Township Police cruiser.  During the four (4) hour trip to Stark County, Defendants England and Escola were again being surreptitiously recorded by the police cruiser camera caressing, fondling and kissing each other.  This activity caused Escola to drive erratically and off the marked roadway.
42.    At approximately 1:00 a.m. on June 3, 2009, Defendants Escola and England booked Matthew Ruble into the Stark County Jail.
43.    On June 3, 2009, at approximately 2:50 p.m., and while England was again off-duty, she and Defendant Escola traveled to the Stark County Jail to meet with Richard Griffin.  Within minutes of this meeting, Richard Griffin purportedly recanted his statement that Matthew Ruble was involved in the Perry Township burglary.
44.    Thereafter, at 3:55 p.m., Defendant England requested that all criminal charges against Matthew Ruble be dismissed.  Plaintiff Matthew Ruble was later released from jail on June 3, 2009.
45.    On June 8, 2009, Defendant England filed a felony obstruction of justice charge against Richard Griffin.  In two separate documents (the Affidavit of Fact and Criminal Complaint) England admitted that Richard Griffin had recanted his story about Matthew Ruble days before she caused the felony burglary charge to be filed against Matthew Ruble.
FIRST CAUSE OF ACTION
(False Arrest)

46.    Plaintiff hereby incorporates paragraphs 1 through 45, inclusive, of this Complaint, as though fully rewritten and realleged herein.
47.    Defendants Escola and England, while acting within the scope of their employment with the Defendants the Trustees of Perry Township, Ohio, (hereinafter referred to as “Defendant Perry Township”), and while acting within their official capacity as police officers with Defendant Perry Township, intentionally manufactured false evidence in an effort to intentionally mislead the Clerk of the Massillon Municipal Court to issue a finding of probable cause which resulted in felony burglary charges to be filed against Matthew Ruble and a warrant to be issued for Matthew Ruble’s arrest.
48.    At the time Defendants Escola and England obtained the “probable cause” determination, they knew that they did not have probable cause to believe that Matthew Ruble was involved in the Perry Township burglary.
49.    Therefore, the arrest warrant and the complaint charging Matthew Ruble was utterly void.
50.    Despite the lack of probable cause, Defendants Escola and England arrested Plaintiff under process of law.
51.    The arrest of Plaintiff by Defendants Escola and England was malicious.
52.    As a direct and proximate result of Defendant England and Escola’s false arrest of Plaintiff, Plaintiff has suffered and continues to suffer damages.
SECOND CAUSE OF ACTION
(False Imprisonment)

53.    Plaintiff hereby incorporates paragraphs 1 through 52, inclusive, of this Complaint, as though fully rewritten and realleged herein.
54.    Defendants Escola and England, while in their official capacity as Police Officers who were employed by Defendant Perry Township, confined Plaintiff Matthew Ruble intentionally and without lawful privilege and against Plaintiff’s consent for over twenty-four (24) hours.
55.    This false arrest of Plaintiff by Defendants Escola and England was pursuant to a warrant that was obtained by using false and fabricated evidence as set forth hereinabove.
56.    As a direct and proximate result of this false imprisonment, Plaintiff Matthew Ruble has suffered and continues to suffer injuries and other damages.
THIRD CAUSE OF ACTION
(Malicious Prosecution)

57.    Plaintiff hereby incorporates paragraphs 1 through 56, inclusive, of this Complaint, as though fully rewritten and realleged herein.
58.    Defendants England and Escola, while in their official capacity as Police Officers employed by Defendant Perry Township, acted with malice in instituting and/or continuing a criminal prosecution against Plaintiff Matthew Ruble for a felony burglary charge.
59.    At the time of this malicious prosecution, Defendants Escola and England lacked probable cause to believe that Matthew Ruble was involved in the Perry Township burglary.
60.    Criminal charges filed by Defendants England and Escola against Plaintiff Matthew Ruble were dismissed by the State of Ohio at the request of Defendants England and Escola, and therefore the termination of the malicious prosecution was in favor of Plaintiff Matthew Ruble.
61.     As a direct and proximate result of this malicious prosecution, Plaintiff Matthew Ruble has suffered and continues to suffer injuries and damages.
FOURTH CAUSE OF ACTION
(Abuse of Process)

62.    Plaintiff hereby incorporates paragraphs 1 through 61, inclusive, of this Complaint, as though fully rewritten and realleged herein.
63.    In the alternative, if probable cause existed, Defendants England and Escola, while in their official position as police officers employed by Defendant Perry Township, caused a criminal, legal proceeding to be set in motion against Plaintiff Matthew Ruble in proper form and with probable cause.
64.    Defendants England and Escola used the original legal proceedings and perverted such legal proceedings in an attempt to accomplish an ulterior purpose for which the criminal legal proceedings were not designed.
65.    As a direct and proximate result of this abuse of process, Plaintiff Matthew Ruble has been damaged.
FIFTH CAUSE OF ACTON
(Intentional Infliction of Emotional Distress)

66.    Plaintiff hereby incorporates paragraphs 1 through 65, inclusive, of this Complaint, as though fully rewritten and realleged herein.
67.    The actions of Defendants Escola and England, while in their official capacities as police officers employed by Defendant Perry Township, as set forth hereinabove, were so outrageous in character and so extreme in degree as to go beyond all possible bounds of decency and those actions would be regarded as atrocious and utterly intolerable in a civilized community.
68.    As a direct and proximate result of this outrageous conduct, Defendants England and Escola sought to intentionally inflict emotional distress upon Plaintiff Matthew Ruble.
69.    As a direct and proximate result of this intentional infliction of emotional distress, Plaintiff Matthew Ruble has suffered and continues to suffer injuries and damages.
SIXTH CAUSE OF ACTION
(Defamation)

70.    Plaintiff hereby incorporates paragraphs 1 through 69, inclusive, of this Complaint, as though fully rewritten and realleged herein.
71.    Plaintiff, at all times relevant herein, was a private citizen.
72.    Defendants Escola and England, while in their official capacity as police officers employed by Defendant Perry Township made numerous false statements of fact regarding Matthew Ruble.
73.    As a direct and proximate result of these false statements made against Plaintiff Matthew Ruble, Defendants England and Escola caused injury and damage to Plaintiff’s reputation and caused him other injuries.
74.    As a direct and proximate result of these defamatory statements made by Defendants England and Escola, Plaintiff Matthew Ruble has suffered and continues to suffer injury and damages.
SEVENTH CAUSE OF ACTION
(Civil Conspiracy)

75.    Plaintiff hereby incorporates paragraphs 1 through 74, inclusive, of this Complaint, as though fully rewritten and realleged herein.
76.    Defendants Escola and England, while acting in their official capacity as police officers employed by Defendant Perry Township, constituted a malicious combination of two persons who intentionally and/or maliciously caused injuries to Plaintiff by engaging in the unlawful act of false imprisonment, false arrest, intentional infliction of emotional distress, defamation, malicious prosecution, and abuse of process, as set forth hereinabove.
77.    As a direct and proximate result of this civil conspiracy, Plaintiff has suffered and continues to suffer injuries and damages.
EIGHTH CAUSE OF ACTION
(42 U.S.C. §1983 Deprivation of Fundamental Constitutional Rights)

78.    Plaintiff hereby incorporates paragraphs 1 through 77, inclusive, of this Complaint, as though fully rewritten and realleged herein.
79.    Defendants, England and Escola, while acting in their official capacity as police officers employed by Defendant Perry Township, and while acting under the color of State law, manufactured false evidence to obtain an invalid and void arrest warrant and criminal charges against Plaintiff Matthew Ruble and eventually arrested and incarcerated Plaintiff on a false charge of felony burglary without just and legal cause, thereby violating Plaintiff’s rights under the laws in the Constitution of the United States, in particular, the Fourth, Fifth and Fourteenth Amendments.
80.    Defendants England and Escola, while acting in their official capacity as police officers employed by Defendant Perry Township, and while acting under the color of State law, searched and seized Plaintiff without probable cause thereby violating the Fourth Amendment of the United States Constitution which grants Plaintiff the right to be free of unreasonable police seizures and searches.
81.    Defendants England and Escola also violated Plaintiff’s Fifth Amendment Rights under the United States Constitution which prohibits deprivation of life, liberty or property without due process of law.
82.    As a direct and proximate result of Defendants England and Escola’s violations of Plaintiff’s clearly established Constitutional rights as set forth herein, Defendants have violated the guarantees and rights to which Plaintiff is entitled under the Fourth, Fifth and Fourteenth Amendments of the United States Constitution and that said violations have caused and continue to cause injury and damages to Plaintiff.
NINTH CAUSE OF ACTION
(42 U.S.C.§1983 - Deprivation of Constitutional Rights by Defendant Perry Township)

83.    Plaintiff hereby incorporates paragraphs 1 through 82, inclusive, of this Complaint, as though fully rewritten and realleged herein.
84.    Defendant Perry Township was negligent in hiring Defendant England and failed to provide adequate training and supervision over Defendants England and Escola which resulted in the unconstitutional and wrongful actions taken by Defendants England and Escola against Plaintiff Matthew Ruble as set forth hereinabove.
85.    Defendant Perry Township is directly liable and responsible for the actions of Defendants England and Escola because of their failure to properly supervise and train those officers and under the doctrine of respondent superior.
86.    As a direct and proximate result of these Constitutional violations and the failure to supervise and properly train, Defendant Perry Township has caused injuries and damages to Plaintiff Matthew Ruble.
TENTH CAUSE OF ACTION
(Punitive Damage)

87.    Plaintiff hereby incorporates paragraphs 1 through 86, inclusive, of this Complaint, as though fully rewritten and realleged herein.
88.    Plaintiff states that the aforementioned conduct of Defendants England and Escola demonstrated a malicious and conscious disregard for the rights and safety of Plaintiff Matthew Ruble and such conduct had a great probability of causing substantial harm and did cause substantial harm to Plaintiff Matthew Ruble.
89.    As a direct and proximate result of the conduct of Defendants England and Escola as fully described herein, Plaintiff suffered damages and injuries and entitles Plaintiff to an award of punitive damages against Defendants England and Escola.
WHEREFORE, Plaintiff demands judgment against each Defendant named, jointly and severally, in an amount exceeding Twenty-Five Thousand Dollars in Compensatory Damages and, in addition, Punitive damages in an amount exceeding Twenty-Five Thousand Dollars, and, costs, attorney fees, interest and such further relief to which Plaintiff may be entitled.
Respectfully submitted,

SCHULMAN ZIMMERMAN & ASSOCIATES

________________________________
Allen Schulman, Jr.
Ohio Supreme Court No. 0001124
236 Third Street S.W.
Canton, Ohio 44702
(330) 456-4400 (Telephone)
(330) 456-3641 (Facsimile)

_______________________________
Brian L. Zimmerman
Ohio Supreme Court No. 0042351
236 Third Street S.W.
Canton, Ohio 44702
Telephone (330) 454-8056
Facsimile (330) 454-2434

REQUEST FOR SERVICE

Plaintiff hereby requests that service of the foregoing Complaint be made on Defendants at the addresses listed in the caption of this Complaint by certified mail, return receipt requested, addressees only.

______________________________
Brian L. Zimmerman
Counsel for Plaintiff

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