Conner �
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����`� t„���,s Bryan R. Battina
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William K. Forbes
SF� 2 1� ���� Christopher Champagne*
'`Of Counsel
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_ - Phone: (952)314-134d
Fax: (952)314-1249
CERTIFIED MAIL RETURN
RECEIPT REQUESTED
September 25, 2012
Shari Moore '
City Clerk �
31 U City Hail
15 West Kellogg Blvd.
St. Paul, MN 55102
RE: Christopher Conner v. City of St. Paul, Sergeant Shanley, Officer Moore
CT File No.:
NOTICE OF CLAIM PURSUANT TO MINN. STAT. § 3.736
AND/OR MINN. STAT. § 466.05
Dear Ms. Moore:
Please treat this as a Notice of Claim pursuant to Minn. Stat. § 3.736 and or Minn. Stat. §
466.05. Our client was seriously traumatized/injured in an incident in the City of St. Paul by
two of your police officers. The incident took place on or about July 12, 2011 wherein our
client, Christopher Conner was riding his bike home near Dale and Ashlund. Two of your
officers, Sergeant Andrew Shanley and Officer Joshua Moore, noticed Mr. Conner and
decided to harass him. Without reasonable articulable suspicion, they demanded Mr. Conner
to stop which Mr, Conner refused to do. What ensued next could have been ripped from a
Hoflywoad scre�nplay.
As Mr. Conner was riding his bike on the sidewalk, the officers, in their cruiser, jumped the
curb and followed him bumper to tire, no lights, no siren. The cowboy officers, who
apparently were not getting enough action that evening, continued to follow Mr. Conner and
as they got within striking distance, Officer Moore pulled out his taser, hung out the car door
and deployed the taser striking Mr. Conner on his bike. Mr. Conner immediately fell from his
bike to the ground. Officer Moore jumps out of the cruiser and begins to kick Mr. Conner in
the abdomen area until Sergeant Shanley �ets to them at which point he started striking Mr.
Conner with a large flashlight. After the officers were "putting the boots" to Mr. Conner, Officer
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Moore in an act of self-admiration was gleefully commenting to Mr. Conner that "he got him"
with his taser. Mr. Conner was then taken into custody and transported to the station.
Mr. Conner was ultimately charged with possession of drugs. At the suppression hearing
after listening to the admitted testimony of the foregoing by the officers, the charges were
dismissed. I have obtained a copy of the transcript wherein ttie officers testified under oath to
the events described in addition to a number of other inconsistencies and would be happy to
provide a copy if requested,
Mr. Conner has been forever scarred by this incident. The cowboy officers must be held
accountable. Surely the City of St. Paul expects and demands better from those entrusted to
protect and serve.
We are in the process of preparing the appropriate summons and complaint which will be
served within the coming weeks. If however, the City of St. Paul desires to settle this matter
prior to it becoming a media spectacle, my client would be wiling to settle for an amount of
$250,000. Please let me know if you have any questions.
Sinc ly,
.
Bryan Battin
cc: Client
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