Wyoming Court Papers.pdf - KELOLAND.com

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Case 1:12-cv-00210-SWS Document 1 Filed 09/17/12 Page 21 of 22
Defendants acts were not the result of a "split-second" decision that an officer is sometimes
required to make. Defendants' acts were deliberately planned and carried out over the course of
Mr. Willoughby's entire trial and appeal. Defendants acts' are so egregious and shocking to the
conscious that Deputy Gehlhausen, a fellow law enforcement officer, recorded multiple
conversations and continually urged that the exculpatory evidence be disclosed. Defendants'
unconscionable acts were the driving force behind Mr. Willoughby's constitutional violation.
52. The acts or omissions, of each Defendant, described above, were the legal and
proximate cause ofMr. Willoughby's wrongful conviction and incarceration, causing his injuries
alleged herein.
WHEREFORE, Plaintiff demands judgment against Defendants as follows:
1) For an amount that will reasonably compensate Plaintiff for all injuries and
damages, general and specific, sustained and provided for by law;
2) For punitive damages against Defendants according to proof;
3) For interest as allowed by law;
4) For Plaintiff's costs, disbursements and reasonable attorney's fees incurred herein;
and
5) For such other and further relief as the Court may deem just and proper.
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