Case 1:18-cv-03157-JRS-TAB Document 1 Filed 10/11/18 Page 1 of 19 PageID #: 1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF INDIANA
INDIANAPOLIS DIVISION

KEVIN BROWN )
and )
BEVERLY DIANNE BROWN, )
)
Plaintiffs, )
)
vs. ) CASE NO. 1:18-cv-3157
)
INDIANAPOLIS METROPOLITAN POLICE )
DEPARTMENT; CITY OF INDIANAPOLIS; )
and )
OFFICER EMILY PERKINS, Individually, )
and in her Capacity as a Sworn Officer employed )
by the INDIANAPOLIS METROPOLITAN )
POLICE DEPARTMENT, )
)
Defendants. )

COMPLAINT

Come now the Plaintiffs, Kevin Brown and Beverly Dianne Brown, by and through their

attorney, Richard D. Hailey, Ramey & Hailey, of Indianapolis, Indiana, and in support of their

cause of action against the Defendants, and each of them, allege and say as follows:

Introduction

1. This is a civil action brought pursuant to 42 U.S.C. 1983 to address the

deprivations made under color of law to, upon and against the Plaintiffs, and their

respective constitutional rights as secured and guaranteed by the constitution of

the United States of America. Additionally, this Complaint contains state claims

against the Defendants, and each of them.

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Jurisdiction and Venue

2. The jurisdiction of this Court is invoked pursuant to the Civil Rights Act, 42

U.S.C. § 1983; the Judicial Code, 28 U.S.C. §§ 1331 and 1343(a); and the

Constitution of the United States inclusive of the Bill of Rights.

3. This Court has pendent jurisdiction over the state claims as provided under 28

U.S.C. § 1367(a).

Parties

4. Plaintiff Professor Kevin Brown and his spouse, Beverly Dianne (hereinafter

“Dianne”) Brown are residents of the city of Bloomington, county of Monroe,

state of Indiana. However, all of the facts and circumstances complained of

herein occurred in the city limits of the city of Indianapolis, county of Marion,

state of Indiana.

5. Professor Kevin Brown is the Richard S. Melvin Professor of Law at the Indiana

University Maurer School of Law located in Bloomington, Indiana. Professor

Brown is a distinguished African American legal scholar with an extensive record

of publications on the subject of race and discrimination, mostly in the public

education area.

6. Professor Brown is a graduate of Yale University Law School in Hartford,

Connecticut. Upon receiving his J.D., he became licensed to practice in the state

of Indiana and joined the law firm of Baker & Daniels in Indianapolis, Indiana.

7. Professor Brown joined the faculty at the Maurer Law School 30 years ago on

January 1, 1987.

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8. On October 14, 2016, Professor Brown was operating an automobile in a safe and

reasonable manner as he approached the city of Indianapolis on I-70 West. He

and his wife had attended a conference at the Case Western Reserve Law School

where Professor Brown had delivered a paper on a program honoring the lifetime

work of the great civil rights attorney Fred Gray of Alabama.

9. Plaintiff Dianne Brown lives in Bloomington, Indiana with her husband. Their

date of marriage is December 18, 1999.

10. Dianne Brown studied architectural engineering at Indiana University Purdue

University in Indianapolis. At all times relevant to this action, she was fully

employed by Indiana University’s Hudson and Holland Scholars Program as an

Events Specialist. Like her husband, her office is located on the main campus of

Indiana University in Bloomington, Indiana.

11. At the time of the incident complained of in this Complaint, Dianne Brown was a

passenger in their family vehicle as she had accompanied her husband to

Cleveland, Ohio for presentation of his academic paper.

12. Defendant Indianapolis Metropolitan Police Department is a duly recognized law

enforcement agency whose primary responsibilities include the provision of law

enforcement services for the City of Indianapolis.

13. Defendant City of Indianapolis is located in Marion County, state of Indiana and

is a political subdivision of the state. This municipal defendant is sued with

respect to state law claims and with respect to Plaintiffs’ Federal 4th, 5th, 8th and

14th Amendment claims concerning the illegal, unlawful, excessive and

unwarranted force perpetrated upon Plaintiffs. Additionally, the City of

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Indianapolis is directly responsible for the implementation or lack thereof which

led to the constitutional violations complained of herein.

14. Defendant Officer Emily Perkins is a duly sworn law enforcement officer under

the laws of the state of Indiana. Based upon best knowledge and belief, her career

with the Indianapolis Metropolitan Police Department started sometime prior to

the Fall of 2000. During her tenure as a police officer, she has received several

complaints of excessive force, rudeness and lack of professionalism. The

overwhelming majority of these complaints have been found to be unfounded by

her employer. All claims brought herein against Officer Perkins are brought

against her in both her individual and official capacity.

15. Additionally, Officer Perkins’ record includes an unsuccessful tenure at the Police

Academy where she was found to have communication issues, lack motivation to

execute tasks and experienced difficulty in getting along with superiors and other

team members. Notwithstanding the latter, she returned to district duty and was

working a shift on the streets on October 14, 2016.

Uncontroverted Facts

16. On October 14, 2016, Kevin and Dianne Brown were the owners and occupants

of a residence located at 3701 Mabels Way, Bloomington, Indiana.

17. Dianne Brown, at all times relevant to this action, was the lawful wife of Kevin

Brown.

18. On or about October 14, 2016, at approximately 9:00 p.m., Plaintiff Professor

Kevin Brown was driving west on I-70 heading into the downtown area of

Indianapolis, commonly known as the “Spaghetti Bowl.”

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19. It is common knowledge to the public and law enforcement who travel through

Indianapolis’s Spaghetti Bowl that this is an area that is plagued with motor

vehicle accidents as it is a stretch of highway that attempts to merge and intersect

two major interstates, namely I-70 and I-65. Further complicating this hazardous

location are frequent construction projects and numerous exits and exit ramps to

downtown city streets. Additionally, throughout this area known as the Spaghetti

Bowl there are no and/or inadequate side shoulders adjacent to the travel way.

20. On the evening of October 14, 2016, the Spaghetti Bowl was made even more

dangerous by the presence of construction projects. The combination of the

Spaghetti Bowl’s inherent dangers, darkness, construction and a heavy traffic

pattern for 9:00 in the evening made the area more unsafe.

21. As Professor Brown approached the downtown area, he was driving

approximately 55-60 miles per hour. As he approached the intersect of I-70 West

and I-65, he noticed a reduction in lanes due to the construction that was present.

In fact, due to the construction on I-70 at I-65 South, once his lane of traffic split,

it narrowed down to one lane.

22. Somewhere before the split of the I-70 West and I-65, Professor Brown noticed

flashing lights of a police squad car in his rear view mirror. Since he was not

speeding, he did not believe that the squad car was attempting to pull him over, so

he veered to the right lane next to him in order to let the squad car pass. When he

veered into the right lane, he then noticed that the squad car veered into the right

lane behind him.

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23. Professor Brown assumed that the squad car behind him had changed lanes in

order to pass him on the right so he immediately veered to the left to provide

room for the squad car to pass. However, again the squad car changed lanes with

him and pulled behind him. At this point, he realized that the squad car was

attempting to flag him down.

24. Due to the fact that Professor Brown was on one of the most dangerous segments

of highway in Marion County, he decided that it would be best to get well past the

construction and pull off and stop in a safe location. This was a route that he was

very familiar with as he had driven into the Spaghetti Bowl on many occasions

from an easterly direction. He decided that the Michigan-Ohio Street exit, which

was less than a half mile away, would be the safest place to pull over. Therefore,

Professor Brown proceeded to the Michigan-Ohio Street exit and looked for a safe

place to pull over. Once he found a safe location, he pulled completely off of the

highway lanes.

25. After pulling off the highway and before exiting his vehicle, Professor Brown and

his wife noticed an officer who would later be identified as Officer Emily Perkins

approaching their car, yelling at them, “Why didn’t you stop? Why did you keep

going?” Additionally, Professor Brown saw what he assumed was a drawn

weapon in the hands of Officer Perkins. He was not sure if the weapon was a

firearm or a Taser but he immediately became frightened and apprehensive.

26. Officer Perkins continued to approach Professor Brown, demonstrating a loud,

aggressive attitude. Officer Perkins was clearly agitated.

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27. Professor Brown attempted to calm Officer Perkins by assuring her that he was a

Professor of Law at Indiana University in Bloomington and a practicing attorney.

He pulled out his driver’s license and his bar admission card and tried to assure

Officer Perkins that he only desired to pull over in a safe place and not in the

middle of the notoriously dangerous Spaghetti Bowl under construction with

heavy traffic.

28. Officer Perkins continued her loud and aggressive questioning of why he didn’t

stop in the middle of an obviously dangerous highway before getting to the

Michigan-Ohio Street exit. Any and everything he said to Officer Perkins only

tended to incite her and otherwise escalate her aggressive behavior.

29. Once Officer Perkins had Professor Brown’s bar association card and his driver’s

license, she went back to her squad car. While she was running the check on the

identification provided, other police officers arrived in the vicinity. The first two

arriving police officers were later identified as Officer Daniel Disney and Officer

Cook.

30. After the Browns noticed the arrival of additional police officers, Officer Perkins

came back to their automobile and ordered them, in an aggressive and hostile

voice, to get out of the car. Her “get out of the car” command was specifically

directed at Professor Brown. Professor Brown began to ask questions as to why

he was being asked to exit his automobile.

31. Once he had exited his automobile, Professor Brown was handcuffed. As

Professor Brown was being handcuffed, he asked his wife Dianne to begin

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recording what was happening. Before she could complete the recording of any

of the events, her phone was taken from her by Officer Perkins.

32. After Officer Perkins took the cell phone that was being used to record the

incident from Dianne Brown, she ordered Dianne Brown out of the automobile

and cuffed her, also.

33. Witnessing the handcuffing of his wife, Professor Brown began to talk to Officers

Disney and Cook. Unlike Officer Perkins, both of them were very calm and

addressed Professor Brown with respect and in a non-threatening manner.

34. Ultimately, a supervisor, later identified as Sgt. David Kinsey, arrived, and he

immediately told Officers Disney and Cook to take the handcuffs off of the

Browns. Further, Sgt. David Kinsey apologized to the Browns and initially

indicated that they would not be going to jail but would be getting a traffic

citation. Professor Brown explained to Sgt. Kinsey that he, in fact, was not

attempting to flee but merely was looking for a safe place to pull off of the

otherwise dangerous highway. He further informed the assisting officers that he

had changed lanes in an effort to let Officer Perkins’s squad car pass him but

when he was convinced that he was being asked to pull over, he assessed the

highway situation and did, in fact, pull over at a safe location. Ultimately, an

unidentified Indianapolis Metropolitan Police Department lieutenant arrived at the

scene. After the lieutenant arrived at the scene, handcuffs were reapplied to

Professor Brown. Professor Brown was informed that he was going to be taken

into custody. After being handcuffed a second time, he was then placed in Officer

Cook’s squad car.

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35. Other officers who assisted at the scene have testified under oath that they did not

feel threatened by the Browns. Further, they did notice that Officer Perkins was

quite agitated. Assisting officers did not feel that the Browns posed any threat to

themselves, the officers in the vicinity or the public at large. At least one

assisting officer admitted that he would have handled the situation “differently.”

More than one assisting officer testified that they did not see any aggressive or

otherwise threatening behavior from the Browns.

36. Professor Brown and Dianne Brown have no recollection of being told exactly

what the charges were that warranted the arrest of Professor Brown nor were they

given any rights under Miranda. Notwithstanding the latter, the Browns

continued to explain their thought process of stopping at a safe place once they

realized that a squad car was trying to pull them over. Once Professor Brown was

in Officer Cook’s squad car, Officer Cook explained the booking process to him.

Officer Cook also drove Professor Brown to a corner filling station near Ohio and

College for transfer to a Marion County Sheriff’s van that would ultimately take

him to the lockup. Simultaneously, Dianne Brown was not re-handcuffed but

was allowed to drive their family automobile first to the corner of Ohio and

College and then to the Marion County lockup.

37. As a result of the foregoing, Officer Perkins filed a report and signed a Probable

Cause Affidavit which resulted in formal criminal charges being brought against

Professor Brown.

38. Late in the evening of October 14, 2016 the Browns, realizing that they needed

assistance, Dianne Brown contacted Crystal Brown Williams, Professor Brown’s

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daughter, who is an attorney in the Corporate Legal Department of the Eli Lilly

Corporation. Attorney Williams immediately contacted the jail and tried to

expedite the release of her father, which did not occur until well into the early

morning hours of October 15, 2016.

39. A Probable Cause Affidavit was filed under incident number DP160124717 on

October 15, 2016. Most, if not all, of the factual allegations contained in the

Probable Cause Affidavit were either misleading or false.

40. The aforementioned Probable Cause Affidavit indicates that Professor Brown was

speeding, traveling approximately 60-65 miles per hour in a 50 mile per hour

zone. This allegation is false, as the Browns contend they were not exceeding the

speed limit as indicated in the Probable Cause Affidavit.

41. The Probable Cause Affidavit indicates that Professor Brown made unsafe lane

changes. Specifically, it alleges that he slammed on his brakes and changed lanes

on more than one occasion. This allegation is false, as Professor Brown did not

make unreasonable lane changes but merely changed lanes to allow the squad car

to pass. When he became convinced that the squad car was not desiring to pass

but instead was attempting to pull him over, he looked for a safe place to exit the

driving portion of the highway.

42. Finally, the Probable Cause Affidavit infers that Professor Brown pulled off from

Officer Perkins’s squad car while lights and siren were being used. This inference

of a criminal offense is false, as Professor Brown at no time accelerated his auto

in an attempt to flee Officer Perkins.

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43. The Probable Cause Affidavit indicates that after pulling over, Professor Brown

yelled at Officer Perkins in a belligerent voice. This statement is false. The

Browns dispute that they ever used loud and/or belligerent language or displayed

an aggressive attitude towards members of the IMPD . The Probable Cause

Affidavit indicates that the location where the Browns stopped was a dangerous

location. This statement is false. The Browns did not stop until they were sure

they could safely pull over as to provide for the safety of not only their own

vehicle but also the squad car behind them.

44. The Probable Cause Affidavit filed in this matter indicates that the passenger,

namely Plaintiff Dianne Brown, was belligerent when approached by Officer

Perkins. This statement is false. While the Browns continued to ask questions

about their detention and ultimate handcuffing, they were never belligerent or

loud. It should be noted that neither was charged with being belligerent or loud,

i.e. disorderly conduct.

45. As a result of the above, Professor Brown was charged with two counts of

resisting law enforcement; one count of resisting law enforcement by fleeing and

;one count of resisting law enforcement by force, notwithstanding the fact that

there were not sufficient facts nor probable cause for these charges. Additionally,

there was no probable cause for the stop, handcuffing or the charges that were

ultimately filed.

46. The charges filed by the Indianapolis Metropolitan Police Department against

Professor Brown were not supported by the true and actual facts and

circumstances of the encounter and were ultimately dismissed.

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47. As a result of the information, i.e. charges filed, against Professor Brown, one

count being a Level 6 Felony and a second count as a Class A Misdemeanor,

Professor Brown had to engage the services of a criminal practitioner, namely

Katie Jackson-Lindsay, of Indianapolis, Indiana.

48. Plaintiffs, through their counsel, served a valid Tort Claims Notice within 180

days, pursuant to what is commonly referred to as the Indiana Tort Claims Act.

Legal Claims – Count I – 42 U.S.C. § 1983 Excessive Force, False Arrest,

Confinement and False Imprisonment

49. Plaintiff incorporates by reference all of the preceding allegations in the foregoing

paragraphs as though fully set forth in this Count.

50. 42 U.S.C. § 1983 provides:

“Every person who under color of any statute, ordinance, regulation,

custom, or usage, of any state or territory or the District of Columbia,
subjects, or causes to be subjected, any citizen of the United States or
other person within the jurisdiction thereof to the deprivation of any rights,
privileges, or immunities secured by the Constitution and laws, shall be
liable to the party injured in an action at law, suit in equity, or other proper
proceeding for redress . . .”

51. Officer Perkins is considered and deemed a “person” within the meaning of 42

U.S.C. § 1983.

52. Officer Perkins actions and/or omissions were made under color of state law

based upon her authority and official position as a sworn officer of the

Indianapolis Metropolitan Police Department.

53. Officer Perkins actions were not reasonable and constituted a violation and

deprivation of Plaintiff’s rights under the 4th, 5th, 8th and 14th Amendments of

the United States Constitution.

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54. As a proximate result of the acts, omissions and failures of Officer Perkins,

Plaintiffs have suffered harms and losses.

55. The actions of Officer Perkins were made knowingly, intentionally and/or with

reckless disregard for the rights and privileges of Plaintiffs, and therefore

actionable under 42 U.S.C. § 1983.

56. When considering the totality of the circumstances, Perkins’ conduct was clearly

excessive and was objectively and subjectively unreasonable. Further, Officer

Perkins lacked probable cause for the stop, arrest and detention that ensued.

Professor Brown never forcibly resisted, obstructed or interfered with Officer

Perkins nor did he flee in an automobile; therefore, there was no probable cause to

support the allegations which ultimately were filed in a court of law.

57. Further, Officer Perkins’ conduct was not reasonable in light of clearly

established law.

58. At the time of the stop and continuing through the detention of the Plaintiffs,

Officer Perkins lacked probable cause to arrest and or detain Plaintiffs.

Therefore, Officer Perkins’ conduct constituted false arrest and unlawful

detention and ultimately the filing of a Probable Cause Affidavit containing false

and misleading statements.

Legal Claims - Count II – Against the City of Indianapolis

59. The Plaintiffs, and each of them, incorporate by reference all of the allegations of

the foregoing paragraphs as though fully set forth in this Count.

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60. This claim is brought pursuant to 42 U.S.C. § 1983 to redress the deprivation of

rights under color of state law of Plaintiff’s rights secured by the 4th, 5th, 8th and

14th Amendments to the Constitution of the United States.

61. Pursuant to Monell v. Department of Social Services, 436 U.S. 658 (1978), the

United States Supreme Court found that a local governing body or municipality

may be named as a defendant under 42 U.S.C. § 1983.

62. Pursuant to Thomas v. Cook County Sheriff’s Department, 604 F. 3d 293, 303 (7th

Cir. 2009),

“A local governing body may be liable for monetary damages under §

1983 if the unconstitutional act complained of is caused by: (1) an official
policy adopted and promulgated by its officers; (2) a government practice
or custom that, although not officially authorized, is widespread and well
settled; or (3) an official with final policy making authority.”

63. As a matter of policy, custom or practice, the city of Indianapolis failed to have

appropriate policies in place and/or otherwise failed to train its officers as to

familiarize them with the legal components of probable cause necessary for a

valid arrest.

64. As a matter of policy, custom or practice, the city of Indianapolis failed to

properly supervise and train its officers re use of common courtesy when

interacting with members of the public that they serve.

65. As a matter of policy, custom or practice, the city of Indianapolis failed to

implement proper implicit bias training for its officers.

66. The failure to provide the aforementioned training and implementation of

appropriate policies contributed to and caused the deliberate indifference to

Plaintiffs whom Officer Perkins came into contact with on October 14, 2016.

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67. As a matter of policy, custom or practice, the city of Indianapolis did not provide

body cameras to its officers although the technology was readily available and

used by numerous metropolitan police agencies throughout the nation.

68. The failure to use body cameras amounts to a lack of accountability for officers

who use unreasonable and excessive force. Implementation and use of body

cameras would greatly contribute to the resolution of factual conflicts between

law enforcement and the citizens at large which often evolve from false arrest and

detention encounters. Here, the only attempt to film the encounter was

interrupted by Officer Perkins when she commandeered Dianne Brown’s

telephone to stop her from filming the encounter that ensued after the illegal stop

in this matter.

69. IMPD, in the case of Officer Perkins, also knew or should have known that she

had a history of poor to unacceptable behavior and was prone to aggressive and

otherwise defensive behaviors and attitudes.

70. Police misconduct in the absence of accountability, correction and proper

supervision is a foreseeable consequence.

71. Officials and officers of the Indianapolis Metropolitan Police Department were

aware, or should have been aware, that by 2016 there existed a disproportionate

tendency for their officers to mistreat or otherwise display inappropriate behaviors

when interacting with black citizens in their jurisdiction. This treatment included

stops and detentions without justification which was a by-product of a lack of

training, especially in the area of implicit bias. The latter, resulting in a culture of

indifference and tolerance of officers’ who violate the constitutional rights of

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citizens. Historically, the Indianapolis Metropolitan Police Department has failed

to exercise proper discipline over officers, even in the most obvious examples of

abuse and misconduct. The city of Indianapolis’s practices, customs and policies,

through its IMPD, as well as its failure to properly train and supervise, resulted in

the arrest and detention of Plaintiffs.

72. The city of Indianapolis’s practices, customs and policies, as well as its failure to

train and supervise, resulted in a deprivation of Plaintiff’s rights under the 4th, 5th,

8th and 14th Amendments of the Constitution of the United States.

73. As a result of the foregoing in Counts I and II of Plaintiffs’ Complaint, Plaintiffs

have been harmed and have suffer damages including a temporary loss of the

liberty and freedom.

Legal Claims - Count III – State Tort Cause of Action for Assault

74. Plaintiffs incorporate by reference all of the material allegations contained in the

foregoing Counts and paragraphs as though fully alleged in this Count.

75. On October 14, 2016, Indianapolis Metropolitan Police Department Officer

Perkins committed an assault and battery upon the persons of Prof. Kevin Brown

and his wife by unlawfully resorting to physical contact to handcuff and otherwise

restrain them when the same was unnecessary and without probable cause.

76. At the time of Officer Perkins’ assault and battery upon the Browns, they posed

no threat to Indianapolis Metropolitan Police Department officers, Officer

Perkins, or any other individuals.

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77. As a proximate result of the assault and battery committed by Officer Emily

Perkins, Plaintiff’s spouse Dianne Brown has been injured and damaged and

otherwise suffered consortium losses.

Legal Claims – Count IV – State Tort Cause of Action for

Intentional Infliction of Emotional Distress

78. Plaintiffs incorporate by reference all of the material allegations contained in the

rhetorical paragraphs preceding this Count as though fully presented in this

Count.

79. The tort of intentional infliction of emotional distress arises in Indiana when a

Defendant engages in extreme and outrageous conduct that intentionally or

recklessly causes emotional distress to another.

80. As a result of the acts, omissions and intentional conduct heretofore outlined in

this Complaint, both Plaintiffs have been subjected to and should be compensated

for intentional infliction of emotional distress.

81. The conduct of the Defendants during their encounter with the Plaintiffs was so

outrageous in character and so extreme in degree as to go beyond all possible

bounds of decency and should be regarded as atrocious and utterly intolerable in a

civilized community.

82. Under prevailing social and cultural norms and values, the conduct of the

Defendants was so outrageous that a reasonable person would be compelled to

determine that it constitutes a reckless disregard for humanity and therefore is

outrageous and extreme by its very nature.

83. This claim in this Count in brought against Officer Perkins both individually and

in her official capacity.

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WHEREFORE, Plaintiffs, by counsel, respectfully pray that this Court find in their favor

and against the Defendants, and each of them, and order the following relief:

A. Issue a declaratory judgment that Defendants’ acts, policies and procedures

violated 42 U.S.C.§ 1983;

B. Award all appropriate injunctive relief to preclude the Defendants, their officers,

agents and employees acting in concert with them, from engaging in any policy or

practice that violates 42 U.S.C. § 1983;

C. Award all relief available under 42 U.S.C. § 1983 and 42 U.S.C. § 1988,

including compensatory and punitive damages, attorneys’ fees and costs, and all

other appropriate relief;

D. Award relief for reasonable medical and hospital expenses, past, present and

future;

E. Award consortium damages to Dianne Brown for her losses as defined by

consortium law of the state of Indiana;

F. Further, that this Court award any and all damages and relief proper under the

laws of the state of Indiana to the parties suffering harm from the conduct

complained of.

Respectfully submitted,

s/Richard D. Hailey
Richard D. Hailey, #7375-49
RAMEY & HAILEY
P.O. Box 40849
Indianapolis, IN 46240

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Telephone: (317) 582-0000

Facsimile: (317) 582-0080
Email: rich@rameyandhaileylaw.com
Attorney for Plaintiffs,
Kevin Brown and Beverly Dianne Brown

CERTIFICATE OF SERVICE

I hereby certify that on the 11th day of October, 2018, a copy of the foregoing Complaint
for Damages was filed electronically. Service of this filing will be made on all ECF-registered
counsel by operation of the Court’s electronic filing system. Parties may access this filing
through the Court’s system.

s/Richard D. Hailey
Richard D. Hailey

RAMEY & HAILEY

P.O. Box 40849
Indianapolis, IN 46240
E-mail: marybeth@rameyandhaileylaw.com
rich@rameyandhaileylaw.com
Telephone: (317) 582-0000
Facsimile: (317) 582-0080

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