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HEARNAP — Part 26
Page 152
152 / 500
5. The United States is a Federal sovereign amenable
to suit-pursuant to the Tederal Torts Claim act, 28 U.S.C.
violation of the Constitution of the United States. .
' . i x
$2675, et seq., as amended, and for illegal actions coxmitted in i
: 1
{
“IXI. NATURE OF ACTION .
6. Plaintiff brings this action for ‘mond ‘ar
\ %, Pe
as a result of the grievous and wanton conduct of théyaforenamed
defendants. in illegally breaking into plaintiff's apartment in a
search for’ the then fugitive/Pateicia Hearst. The defendants
involved in the actual brgak<fp\weresacting upon unreliable and
sketchy information. The entry into" ‘plaintiff's apartment by the
“i,
defendants involved was performed, without proper identification,
is
° ee
declaratory relief in order to redress injuries sigceréa by her
without a warrant, with ‘excessive force, with wanton disregare — |
for the safety and well-beling of the plaintiff, all of which .
were motivagea in part by the FeGeral Bureau of Investigation's
continuing ener Fagenent over its failure to apprehend Patricia
he _ o-
Hearst. AS will ec described in the following, these actions i
H
h |
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t
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violated plaintiff's Sights under the Fourth, Fifth and Ninth
Amendments to the united States Constitution as well as “unéer
62 U.S.C. §§1983, 21985, and the Virginia Constitution and State
a
> Ty. -CAUSES OF ACTION - oof
> 7. At approximately 10:10 o'clock P.M. on March 15,
1978}*plaintife, a single woman, who, because of her roommate's
absence was at the time living alone, heard a knock at her
Alexandria, Virginia apartment door and the voice of a male
Kor & AnsuulALes, LID
——-
203 830-9959
demanding entrance and claiming to be from the Federal
ay Qrrrck BOR 1218
MORIA, FeRGeA 19'S
Bureau of Investigation. Plaintifé then requested the
WABHINGTON, DB. €, 20003
r
- oat wAPMINGTON SVLGING, uw, WF,
Ay!
Misthi hs
fen HONTH COLUMBUS OTNET?
at
following information from the person or persons at the oor:
Po el ta te meget ey
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