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outils Beal toy woe on age 2... that apartment as they @. there one week before! Poa * on another matter, 19. The afore-described events, including entry and search without a proper warrant, use of force, brandishent of weapons, failure to properly identify themselvegimand the unlaw: ul detainment of plaintifé violated plaintiff's &. singe Eeggzon._ Ls from unwarranted intrusion guaranteed: her by noe Rp | ds Nee : Ninth and Fourteenth Amendments to the United States. confei tation. | , > 20. The above-described actions of the officers” who mates, anges ae oo ver t raided her apartment constituted false imprisonment, assault, patter: and illegal entry in violation ofVirginia law, Virginia Code. Section 19.2-59 (1950, as amerided . ‘2h. . The above-descFiped®agtigns of thea Alexandria Police! defendants under color of state Yaw operated to deprive her of | : te Xn the rights, privileges and inmunities“guaranteed ‘her by the ——= Constitution and thé laws of the United States. 22. Asa “result of the foregoing, plaintiff nas suffered} | Severe cnotiondl Bigtress, humiliation and embarrassment. She —— | has also suffered physically, being unable to work, needing medical “ey treatment and she continues: wto date to suffer all of the foregoing WHEREFORE ¢ plaintifé prays for the following telief: a 1. Compensatory Gamages in the amount of ONE HUNDRED t Pee THOUSAND ($100, 000.00} DOLLARS. ae) a ee ea Liv Bo “oO ° ° 2 o Oo —_ 8 m E & ' guagment of the Court pursuant to 28 U.S. C. §2201 3 ze of BEE 5 ¢3 declaring the aforestated actions complained of to be illegal and te Fe ER *2 F388 30 E/8 «]5 8 E45 an 4. Such other relief as the Court may deem proper, ' Axe 5 5 ' Respectfully submitted, & 3 . g - vec: : ELIZABETH ARN" NORTON, in violation of plaintiff's Constitutional rights. . 7 By Counsel . Fn i pacteethient all ecteega dean ae ee ee