Romulus Police Chief Dickerson lawsuit.pdf - MLive.com

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 6 of 18 Pg ID 6Plaintiff downloaded and saved the video of the incident on the Romulus PoliceDepartment computer.30. Defendant Captain Shelby knew that the video existed because he had personallyviewed the video when it was played in Plaintiff’s office.31. On September 21, 2012, a FOIA request was faxed to the Romulus PoliceDepartment by attorney Michael Rataj which concerned the assault of thehandcuffed prisoner, including, among other things, a request for any and allcopies of the video. (Rataj correspondence, Ex. A.)32. On September 24, 2012, Plaintiff received the FOIA request.33. Pursuant to his job duties, Plaintiff prepared a FOIA response letter and requestedall documents/videos, making all of the appropriate exemptions and redactions asprovided in the statute.34. Plaintiff then presented the FOIA packet for Defendant Dickerson’s review.35. When Defendant Dickerson asked what the packet involved, Plaintiff respondedthat the materials involved “the punch” described above.36. Shortly after Plaintiff had spoken with Defendant Dickerson, Defendant CaptainShelby came to Plaintiff’s office and summoned him to meet in DefendantDickerson’s office.37. Once in Defendant Chief Dickerson’s office, Defendant Dickerson asked Plaintiff“Why do we have this?” referring to the video tape which captured the assault ofthe handcuffed prisoner.38. Plaintiff responded that he “had saved it” referring to the video which had beendigitally downloaded on Plaintiff’s department issued computer.