D.C. police sued for warrantless arrest of transgender activist

Case 1:17-cv-00353 Document 1 Filed 02/28/17 Page 1 of 8

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

LOURDES ASHLEY HUNTER
1827 Summit Place, N.W.
Washington, D.C. 20009,
No. _________________
Plaintiff,
v.
OFFICER RANDY ROGERS
(Badge No. 5720)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009,

JURY TRIAL DEMANDED

OFFICER CARLOS TEJERA
(Badge No. 10376)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009,
OFFICER JOHN McKNIGHT
(Badge No. 4447)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009,
OFFICER ROBERT OWEN
(Badge No. 3931)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009, and
DISTRICT OF COLUMBIA
c/o Office of the Attorney General
441 4th Street, N.W.
Washington, D.C. 20001,
Defendants.

COMPLAINT
Seeking damages for police misconduct: violation of rights under the
Constitution of the United States and the law of the District of Columbia

Case 1:17-cv-00353 Document 1 Filed 02/28/17 Page 2 of 8

INTRODUCTION
1. On November 16, 2016, several officers of the District of Columbia Metropolitan
Police Department (MPD) entered Plaintiff Lourdes Ashley Hunteras apartment and
arrested her without a warrant based solely on allegations that she had committed
misdemeanor simple assault. The officersa actions violated Ms. Hunteras rights under the
Fourth Amendment to the Constitution of the United States and constitute false arrest
under the laws of the District of Columbia. Ms. Hunter accordingly seeks compensatory
and punitive damages from the officers and the District, as well as attorneysa fees, costs,
and other appropriate relief.
JURISDICTION AND VENUE
2. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. ASS
1331 (federal question). Ms. Hunter brings this action under 42 U.S.C. ASS 1983 to
vindicate her rights under the Fourth Amendment to the United States Constitution. Her
claims under the common law of the District of Columbia arise from the same events as
her constitutional claim and are within the Courtas supplemental jurisdiction pursuant to
28 U.S.C. ASS 1367.
3. Venue is proper in this Court pursuant to 28 U.S.C. ASS 1391(b). The events giving
rise to Plaintiffas claims occurred in the District of Columbia.
PARTIES
4. Plaintiff Lourdes Ashley Hunter is an adult resident of the District of Columbia.
5. Defendant Officer Randy Rogers, Badge No. 5720, is a sworn officer employed
by the MPD. At the time of the events at issue he was acting within the scope of his
employment. He is sued in his individual capacity.
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6. Defendant Officer Carlos Tejera, Badge No. 10376, is a sworn officer employed
by the MPD. At the time of the events at issue he was acting within the scope of his
employment. He is sued in his individual capacity.
7. Defendant Officer John McKnight, Badge No. 4447, is a sworn officer employed
by the MPD. At the time of the events at issue he was acting within the scope of his
employment. He is sued in his individual capacity.
8. Defendant Officer Robert Owen, Badge No. 3931, is a sworn officer employed by
the MPD. At the time of the events at issue he was acting within the scope of his
employment. He is sued in his individual capacity.
9. Defendant District of Columbia is a municipal corporation, the local government
of Washington, D.C., and operates and governs the MPD pursuant to the laws of the
District of Columbia. In this case, the District of Columbia acted through its agents,
employees and servants, including Defendants Rogers, Tejera, McKnight, and Owen.
FACTS
10. On November 16, 2016, Ms. Hunter, the co-founder and Executive Director of the
Trans Women of Color Collective, hosted a dinner and reception in her apartment for
people from around the nation who would be attending the White House Transgender
Community Briefing with her the following day.
11. During the gathering, Ms. Hunteras downstairs neighbors knocked on her door
and told Ms. Hunter they thought she and her friends were being too loud. Ms. Hunter,
some of her guests, and the neighbors engaged in a verbal disagreement regarding
whether Ms. Hunter and her guests were in fact being too loud.

3

Case 1:17-cv-00353 Document 1 Filed 02/28/17 Page 4 of 8

12. After verbally interacting for several minutes, the neighbors left the hallway
outside Ms. Hunteras apartment.
13. A short while later, Defendants Rogers, Tejera, McKnight, and Owen knocked at
Ms. Hunteras apartment door.
14. Ms. Hunter opened the door, and one of the officers asked her if asomething [had]
take[n] place between [her] and another neighbor.a Ms. Hunter stated that she didnat
understand what the officer was asking.
15. When the officer said he was ainvestigating a possible assault,a Ms. Hunter
reacted with disbelief, stepped back into her apartment, and closed the door.
16. Several minutes later, the same four officers knocked on Ms. Hunteras door again.
When she opened the door, one of the officers asked for her identification.
17. When Ms. Hunter asked why, the officer responded that they were adoing an
investigation.a After additional questions, the officer stated that they were investigating
an assault.
18. At that point, several individuals came to the stairway leading to the landing on
which the four officers were standing. An officer asked one of the individuals to indicate
who had pushed him. He pointed to Ms. Hunter and stated that she had pushed him.
19. Ms. Hunter asked in disbelief, aI pushed you? I pushed you?a She then began to
explain that there had been no assault and that there had been no excessive noise coming
from her apartment.
20. One of the four officers interrupted her and began to move towards her. She
stated, aYouare not going to listen? Excuse me,a and stepped back into her apartment.

4

Case 1:17-cv-00353 Document 1 Filed 02/28/17 Page 5 of 8

21. None of the circumstances provided probable cause, or any reason, for any of the
officers to believe that unless Ms. Hunter was immediately arrested, she might not be
apprehended, might cause injury to others, or might tamper with, dispose of, or destroy
evidence.
22. The officer who had interrupted Ms. Hunter followed her into her apartment,
where he grabbed her by her arm and neck.
23. Inside the apartment, the officer was joined by another officer.
24. When Ms. Hunter asked the officers to let go of her, the officers stated that they
were arresting her. She asked what for, and one of the officers replied, afor assault.a
25. Ms. Hunter was placed in handcuffs and escorted to the courtyard of her
apartment building, where she was required to sit handcuffed on a picnic bench for
approximately 45 minutes before being transported to the Third District MPD station.
26. She was held in custody from approximately 11 p.m. on November 16, 2016 to 3
a.m. on November 17, 2016.
27. Ms. Hunteras arrest report states that she was arrested for simple assault and
resisting arrest. The United States Attorney declined to prosecute.
28. Ms. Hunter suffered the deprivation of her liberty for several hours as a result of
Defendantsa unlawful actions.
29. Ms. Hunter suffered physical injury and pain as a result of Defendantsa unlawful
actions, including a pinched nerve in her arm from the tight handcuffs, exacerbated osteoarthritis in her knee, and back pain.
30. As a result of Defendantsa unlawful actions, Ms. Hunter suffered emotional
distress and humiliation at being arrested in front of her friends and colleagues from

5

Case 1:17-cv-00353 Document 1 Filed 02/28/17 Page 6 of 8

around the nation who would be with her at the White House the next day, being forced
to sit handcuffed for 45 minutes in the courtyard of her apartment building, and knowing
that many of the participants at the next dayas White House Briefing knew of her arrest
and were talking about it at the White House.
31. As a result of her injuries, Ms. Hunter has been required to receive physical
therapy for her back pain, for which she has paid out of pocket.
32. Ms. Hunteras counsel has timely given notice in writing to the Mayor of the
District of Columbia of the aapproximate time, place, cause, and circumstancesa of her
injuries, pursuant to D.C. Code ASS 12-309. The Notice of Claim letter was delivered to the
D.C. Office of Risk Management via certified mail on or about February 8, 2017.
CLAIMS FOR RELIEF
Claim I: Violation of Fourth Amendment Rights / 42 U.S.C. ASS 1983
(Defendants Rogers, Tejera, McKnight, and Owen)
33. The actions of Defendants Rogers, Tejera, McKnight, and Owen, namely their
warrantless entry into Ms. Hunteras home in order to effect the warrantless arrest,
violated Ms. Hunteras rights under the Fourth Amendment to the United States
Constitution to be free from unreasonable searches and seizures.
34. Defendants Rogers, Tejera, McKnight, and Owen are jointly and severally liable
to Ms. Hunter for this violation of her rights, pursuant to 42 U.S.C. ASS 1983.
Claim II: False Arrest
(All defendants)
35. Defendantsa actions, described above, constituted false arrest under the law of the
District of Columbia.

6

Case 1:17-cv-00353 Document 1 Filed 02/28/17 Page 7 of 8

36. Ms. Hunteras arrest for simple assault, a misdemeanor, was an unlawful
warrantless arrest under D.C. Code ASS 23-581, as the misdemeanor in question was not
committed in the presence of the officers and the defendants had no probable cause, or
any reason, to believe that unless Ms. Hunter was immediately arrested, she might not be
apprehended, might cause injury to others, or might tamper with, dispose of, or destroy
evidence.
37. Defendants Rogers, Tejera, McKnight, and Owen are jointly and severally liable
to Ms. Hunter for this violation of her rights under the law of the District of Columbia.
38. Defendant District of Columbia is liable under the doctrine of respondeat
superior for the damages inflicted upon Ms. Hunter by the false arrest committed by its
agents Rogers, Tejera, McKnight, and Owen while acting within the scope of their
employment as MPD officers and on behalf of and in the interests of their employer.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff requests that this Court:
(a) RULE that the actions of Rogers, Tejera, McKnight, and Owen violated
Plaintiffas rights under the Fourth Amendment to the United States Constitution and the
laws of the District of Columbia;
(b) ENTER JUDGMENT awarding Plaintiff compensatory damages against all
defendants in an amount appropriate to the evidence adduced at trial;
(c) ENTER JUDGMENT awarding Plaintiff punitive damages against defendants
Rogers, Tejera, McKnight, and Owen in an amount appropriate to the evidence adduced
at trial;

7

Case 1:17-cv-00353 Document 1 Filed 02/28/17 Page 8 of 8

(d) ENTER JUDGMENT awarding Plaintiff her costs and reasonable attorneysa fees
in this action as provided in 42 U.S.C. ASS 1988; and
(e) GRANT Plaintiff such other and further relief as this Court may deem just and
proper.
JURY DEMAND
Plaintiff requests a trial by jury.

Respectfully submitted,
/s/ Scott Michelman
Scott Michelman (D.C. Bar No. 1006945)
Arthur B. Spitzer (D.C. Bar No. 235960)
Shana Knizhnik*
American Civil Liberties Union
of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434
Washington, D.C. 20008
Tel. 202-457-0800
Fax 202-457-0805
smichelman@acludc.org
February 28, 2017

Counsel for Plaintiff

*

Admitted in New York. Practicing in D.C. under supervision of a D.C. Bar member
while D.C. Bar application pending, pursuant to D.C. Ct. App. R. 49(c)(8).
8

Case 1:17-cv-00353 Document 1-1 Filed 02/28/17 Page 1 of 2
CIVIL COVER SHEET
JS-44 (Rev. 7/16 DC)

I. (a) PLAINTIFFS

DEFENDANTS

Lourdes Ashley Hunter

Officer Randy Rogers (Badge No. 10376); Officer Carlos
Tejera (Badge No. 10376); Officer John McKnight (Badge No.
4447); Officer Robert Owen (Badge No. 3931); District of
Columbia

11001

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(IN U.S. PLAINTIFF CASES ONLY)

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________
(EXCEPT IN U.S. PLAINTIFF CASES)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED

(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)

ATTORNEYS (IF KNOWN)

Karl A. Racine, Attorney General of the District of Columbia
441 4th St, NW, Washington, D.C. 20001

Scott Michelman, Arthur B. Spitzer, Shana Knizhnik
American Civil Liberties Union of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434 Washington,
D.C. 20008 202-457-0800
II. BASIS OF JURISDICTION

III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR

(PLACE AN x IN ONE BOX ONLY)

o
o

1 U.S. Government
Plaintiff
2 U.S. Government
Defendant

o
o

3 Federal Question
(U.S. Government Not a Party)
4 Diversity
(Indicate Citizenship of
Parties in item III)

PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
PTF
DFT

Citizen of this State
Citizen of Another State
Citizen or Subject of a
Foreign Country

o1 o1
o2 o2
o3 o3

Incorporated or Principal Place
of Business in This State
Incorporated and Principal Place
of Business in Another State
Foreign Nation

PTF

DFT

o4 o4
o5 o5
o6 o6

IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)

o

A. Antitrust
410 Antitrust

o

o

o

B. Personal Injury/
Malpractice
310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury
362 Medical Malpractice
365 Product Liability
367 Health Care/Pharmaceutical
Personal Injury Product Liability
368 Asbestos Product Liability

E. General Civil (Other)

Real Property
210 Land Condemnation
220 Foreclosure
230 Rent, Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
Personal Property
370 Other Fraud
371 Truth in Lending
380 Other Personal Property
Damage
385 Property Damage
Product Liability

C. Administrative Agency
Review
151 Medicare Act

Social Security
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
Other Statutes
891 Agricultural Acts
893 Environmental Matters
890 Other Statutory Actions (If
Administrative Agency is
Involved)

OR

o

Bankruptcy
422 Appeal 27 USC 158
423 Withdrawal 28 USC 157
Prisoner Petitions
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Conditions
560 Civil Detainee a Conditions
of Confinement
Property Rights
820 Copyrights
830 Patent
840 Trademark
Federal Tax Suits
870 Taxes (US plaintiff or
defendant)
871 IRS-Third Party 26 USC 7609

o

D. Temporary Restraining
Order/Preliminary
Injunction

Any nature of suit from any category
may be selected for this category of
case assignment.
*(If Antitrust, then A governs)*

F. Pro Se General Civil
Forfeiture/Penalty
625 Drug Related Seizure of
Property 21 USC 881
690 Other

Other Statutes
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
430 Banks & Banking
450 Commerce/ICC
Rates/etc.
460 Deportation
462 Naturalization
Application
465 Other Immigration
Actions

470 Racketeer Influenced
& Corrupt Organization
480 Consumer Credit
490 Cable/Satellite TV
850 Securities/Commodities/
Exchange
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of State
Statutes
890 Other Statutory Actions
(if not administrative agency
review or Privacy Act)

Case 1:17-cv-00353 Document 1-1 Filed 02/28/17 Page 2 of 2

o

G. Habeas Corpus/
2255

o

K. Labor/ERISA
(non-employment)
710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
740 Labor Railway Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act

*(If pro se, select this deck)*

*(If pro se, select this deck)*

o

o

L. Other Civil Rights
(non-employment)
441 Voting (if not Voting Rights
Act)
443 Housing/Accommodations
440 Other Civil Rights
445 Americans w/Disabilities a
Employment
446 Americans w/Disabilities a
Other
448 Education

o

I. FOIA/Privacy Act
895 Freedom of Information Act
890 Other Statutory Actions
(if Privacy Act)

442 Civil Rights a Employment
(criteria: race, gender/sex,
national origin,
discrimination, disability, age,
religion, retaliation)

530 Habeas Corpus a General
510 Motion/Vacate Sentence
463 Habeas Corpus a Alien
Detainee

o

o

H. Employment
Discrimination

152 Recovery of Defaulted
Student Loan
(excluding veterans)

o

M. Contract
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of
Judgment
153 Recovery of Overpayment
of Veteranas Benefits
160 Stockholderas Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise

J. Student Loan

N. Three-Judge
Court
441 Civil Rights a Voting
(if Voting Rights Act)

V. ORIGIN

o 1 Original o 2 Removed o 3 Remanded
Proceeding

from State
Court

from Appellate
Court

o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to
or Reopened

from another
district (specify)

Litigation

o 8 Multi-district

District Judge
from Mag.
Judge

Litigation a
Direct File

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

Liability for Violation of Plaintiff's Fourth Amendment Rights (42 U.S.C. ASS 1983), Supplemental Jurisdiction (28 U.S.C. ASS 1367)
VII. REQUESTED IN
COMPLAINT

CHECK IF THIS IS A CLASS
ACTION UNDER F.R.C.P. 23

DEMAND $
JURY DEMAND:

Check YES only if demanded in complaint

VIII. RELATED CASE(S)
IF ANY

(See instruction)

YES

If yes, please complete related case form

02/28/2017
DATE: _________________________

NO

YES

NO

SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44
Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I.

COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.

III.

CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.

IV.

CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.

VI.

CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.

VIII.

RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerkas Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.

Case 1:17-cv-00353 Document 1-2 Filed 02/28/17 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Lourdes Ashley Hunter

Plaintiff(s)

v.
Officer Randy Rogers (Badge No. 10376); Officer
Carlos Tejera (Badge No. 10376); Officer John
McKnight (Badge No. 4447); Officer Robert Owen
(Badge No. 3931); District of Columbia
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) OFFICER CARLOS TEJERA
(Badge No. 10376)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: American Civil Liberties Union of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434
Washington, D.C. 20008

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Case 1:17-cv-00353 Document 1-2 Filed 02/28/17 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

Officer Carlos Tejera

.

a I personally served the summons on the individual at (place)
on (date)

; or

a I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or

a I served the summons on (name of individual)

, who is

designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

a I returned the summons unexecuted because

; or

a Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.

Case 1:17-cv-00353 Document 1-3 Filed 02/28/17 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Lourdes Ashley Hunter

Plaintiff(s)

v.
Officer Randy Rogers (Badge No. 10376); Officer
Carlos Tejera (Badge No. 10376); Officer John
McKnight (Badge No. 4447); Officer Robert Owen
(Badge No. 3931); District of Columbia
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) DISTRICT OF COLUMBIA
c/o Office of the Attorney General
441 4th Street, N.W.
Washington, D.C. 20001

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: American Civil Liberties Union of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434
Washington, D.C. 20008

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Case 1:17-cv-00353 Document 1-3 Filed 02/28/17 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

Karl A. Racine, Attorney General of the District of Columbia

.

a I personally served the summons on the individual at (place)
on (date)

; or

a I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or

a I served the summons on (name of individual)

, who is

designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

a I returned the summons unexecuted because

; or

a Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.

Case 1:17-cv-00353 Document 1-4 Filed 02/28/17 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Lourdes Ashley Hunter

Plaintiff(s)

v.
Officer Randy Rogers (Badge No. 10376); Officer
Carlos Tejera (Badge No. 10376); Officer John
McKnight (Badge No. 4447); Officer Robert Owen
(Badge No. 3931); District of Columbia
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) DISTRICT OF COLUMBIA
c/o Office of the Attorney General
441 4th Street, N.W.
Washington, D.C. 20001

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: American Civil Liberties Union of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434
Washington, D.C. 20008

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Case 1:17-cv-00353 Document 1-4 Filed 02/28/17 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

Mayor, District of Columbia, c/o Office of Attorney General

.

a I personally served the summons on the individual at (place)
on (date)

; or

a I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or

a I served the summons on (name of individual)

, who is

designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

a I returned the summons unexecuted because

; or

a Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.

Case 1:17-cv-00353 Document 1-5 Filed 02/28/17 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Lourdes Ashley Hunter

Plaintiff(s)

v.
Officer Randy Rogers (Badge No. 10376); Officer
Carlos Tejera (Badge No. 10376); Officer John
McKnight (Badge No. 4447); Officer Robert Owen
(Badge No. 3931); District of Columbia
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) OFFICER JOHN McKNIGHT
(Badge No. 4447)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: American Civil Liberties Union of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434
Washington, D.C. 20008

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Case 1:17-cv-00353 Document 1-5 Filed 02/28/17 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

Officer John McKnight

.

a I personally served the summons on the individual at (place)
on (date)

; or

a I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or

a I served the summons on (name of individual)

, who is

designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

a I returned the summons unexecuted because

; or

a Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.

Case 1:17-cv-00353 Document 1-6 Filed 02/28/17 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Lourdes Ashley Hunter

Plaintiff(s)

v.
Officer Randy Rogers (Badge No. 10376); Officer
Carlos Tejera (Badge No. 10376); Officer John
McKnight (Badge No. 4447); Officer Robert Owen
(Badge No. 3931); District of Columbia
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) OFFICER RANDY ROGERS
(Badge No. 5720)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: American Civil Liberties Union of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434
Washington, D.C. 20008

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Case 1:17-cv-00353 Document 1-6 Filed 02/28/17 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

Officer Randy Rogers

.

a I personally served the summons on the individual at (place)
on (date)

; or

a I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or

a I served the summons on (name of individual)

, who is

designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

a I returned the summons unexecuted because

; or

a Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.

Case 1:17-cv-00353 Document 1-7 Filed 02/28/17 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Columbia
__________
District
of __________
Lourdes Ashley Hunter

Plaintiff(s)

v.
Officer Randy Rogers (Badge No. 10376); Officer
Carlos Tejera (Badge No. 10376); Officer John
McKnight (Badge No. 4447); Officer Robert Owen
(Badge No. 3931); District of Columbia
Defendant(s)

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No.

SUMMONS IN A CIVIL ACTION
To: (Defendantas name and address) OFFICER ROBERT OWEN
(Badge No. 3931)
MPD Third District Station
1620 V Street, N.W.
Washington, D.C. 20009

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) a or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) a you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffas attorney,
whose name and address are: American Civil Liberties Union of the District of Columbia
4301 Connecticut Avenue, N.W., Suite 434
Washington, D.C. 20008

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

Case 1:17-cv-00353 Document 1-7 Filed 02/28/17 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)

Officer Robert Owen

.

a I personally served the summons on the individual at (place)
on (date)

; or

a I left the summons at the individualas residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)

, and mailed a copy to the individualas last known address; or

a I served the summons on (name of individual)

, who is

designated by law to accept service of process on behalf of (name of organization)
on (date)

; or

a I returned the summons unexecuted because

; or

a Other (specify):
.
My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Serveras signature

Printed name and title

Serveras address

Additional information regarding attempted service, etc:

Print

Save As...

Reset

.