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13JE-CC00s87
STATE OF MISSOURI COUNTY OF JEFFERSON
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IN THE CIRCUIT COURT OF TFIE TWENTY-THIRD ruDICIAL CIRCUIT OF MISSOURI, AT HILLSBORO, JEFFERSON COLINTY, MISSOURI DIVISION NO.
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Plaintiff,
vs.
Cause No.
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PETITION FOR DAMAGES
Comes now Plaintiff, Anthony Burgio, Jr., by his counsel Anthony R. Dorsett and for its cause of action states as follows:
1. 2. 3. 4.
Plaintiff is a person resident in Jefferson County who owns and operates a solely
owned business within the city limits of the city of Arnold, MO.
and which has been operating for the relevant time mentioned in this pleading.
follows: Every person who, under color of any statute, ordinance, regulation, cltstom, or
of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any
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citizen of the United States or other person within the jurisdiction thereof to the deprivation
of
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any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the
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party injured in an action at law, suit in equity, or other proper proceedingfor redress.
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5. 6.
42 USC $ 1983 has been made applicable to state action in the State of Missouri. Since as early as May 15, 2012 until her election loss, Arnold Ward
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councilwoman Doris Borgelt, has engaged on behalf of herself and in concert with the city of
Arnold, in a deliberate campaign to harass Plaintiff and his business in deprivation of his civil
rights as protected by the code.
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7. 8. 9.
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businesses owned by
attempt to have
Plaintifls
10. .
Doris Borgelt has deliberately interfered with business contracts in which Plaintiff
have been engaged, causing loss of these contracts to the damage of Plaintiff.
11
Between May 15, 2012 through June 6, 2012, there was a continuous and
deliberate effort by Doris Borgelt to harass the shop owned by Plaintiff, and its employees and patrons about the issue of business licenses, which had all been properly and duly issued by the
city of
Arnold. 12.
Commencing in October 2012, again at the instance and insistence of Mrs. Doris
Borgelt efforts were made to have the premises inspected, the parking lot measured, and
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verification of proper street signage solely to badger and harass Plaintiff.
through the end of the month of October. Those issues continued
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13.
At the end of November 2012 Mrs. Borgelt once again came to the property with
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camera in hand and asked a customer to leave. On that day as well Plaintiff was challenged as to
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whether he was receiving stolen electronics or drugs as alleged by Mrs. Borgelt in an email to the
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chief of police and Mary Holden, knowing these allegations were false.
14.
Plaintiff does not conduct his business affairs in violation of the law and
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moreover has never knowingly received any stolen electronic devices, nor has he participated in any drug sales.
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Borgelt to force Plaintiff to close his business through constant stream of harassment and false
allegations.
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16.
Plaintiff has been damaged in an amount in excess of $25,000.00 as and for the
actions of the city of Arnold, by its agent Doris Borgelt. Wherefore, Plaintiff prays damages against the Defendant, city of Arnold in a reasonable amount in excess of $25,000.00, his attorney's fees, prejudgment interest, post judgment interest
and his costs expended.
THE SCHNAARE LAW FIRM, P.C. 321 Main Street - P.O. Box 440 Hillsboro, MO 63050-0440 (636)789-335s - - (636)797-33ss Attorney for Plaintiff
y:\municipal\burgio city of arnold\burgio petition.docx