1vTHE crncurr cour! FOR HAMILTON COUNTY, TENNESS! 2oocT 1S PH 13 KENNETH CHARLES ROGERS, ) LARRY L. HENRY: CLERK Plaintiff, ) v ov EP >On no, SOC IOSF HAMILTON COUNTY, TENNESSEE, } Defendant. } COMPLAINT COMES the Plaintiff, by and through undersigned counsel, and would state the following 1 All parties, events, and causes of action cited herein are sufficiently connected to Hamilton County so as to vest jurisdiction and venue in the Hamilton County Circuit Court, ML * on orabout January 19, 2018, Hamilton County Deputy Officer Carl Glenn Young shot the unarmed and fleeing Plaintiff, thereby causing him serious and life-threatening injuries. m. According to official representations, Young meant to fire Taser prongs, not bullets Iv. Accordingly, the Plaintiff claims that Young acted negligently and thereby caused his serious injuries. Because Hamilton County failed to train and monitor Young properly, this incident occurred, Page 1 of 3v. ‘Young's actions violated the provisions of the Tennessee Governmental Tort Liability Act, found at T.C.A. § 29-20-101, et seq, Vi. At this time, Plaintiff alleges that, at a minimum, Young acted negligently. vu. Further, Young has admitted to having so acted in the afore-stated manner. The Defendant is thus vicariously liable for his negligent actions pursuant to T.C.A. § 29-20-101 vu. ‘ WHEREFORE, PREMISES CONSIDERED, Plaintiff asks for damages in the amount of Three Million Dollars ($3,000,000,00), discretionary costs, and any other such relief as the evidence in this case may prove him entitled Respectfully submitted, LAW OFFICES OF JOHN M. WOLFE, JR. fore! ol salle ie fe No. 010319 Counsel for Plaintiff 707 Georgia Avenue, Suite 302 Chattanooga, TN 37402 423.266.8400 | Phone 423.265.8055 | Fax Johnmwolfejexecomeast.net Page 2 of 3