UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF KENTUCKY

AT LOUISVILLE

(Filed Electronically)

SHANNYN WHITE )
)
PLAINTIFF )
)
V. )
)
LOUISVILLE-JEFFERSON COUNTY ) COMPLAINT
METRO GOVERNMENT )
Serve: Mayor, Greg Fischer )
527 W. Jefferson Street, 4th Floor )
Louisville, Kentucky 40202 )
)
C/c : Hon. Mike O’Connell )
Jefferson Hall of Justice )
600 West Jefferson Street )
Louisville, Kentucky 40202 ) CASE NO.: __________________
)
-and- )
)
UNNAMED OFFICER #1, Individually and )
in their Official Capacity )
Louisville Metro Police Department )
633 W. Jefferson Street )
Louisville, KY 40202 )
)
-and- )
)
UNNAMED OFFICER #2, Individually and )
in their Official Capacity )
Louisville Metro Police Department )
633 W. Jefferson Street )
Louisville, KY 40202 )
)
DEFENDANTS )

Comes the Plaintiff, SHANNYN WHITE (hereinafter “MS. WHITE”), by and through her

undersigned counsel, and hereby brings this Complaint before this Honorable Court, in which she

1
seeks damages for the violations of her federal rights by the named Defendants, as well as damages

for her state law causes of action. In support of her action thereof, the Plaintiff now hereby alleges

the following:

JURISDICTION AND VENUE

1. This is an action for damages in excess of Fifteen thousand dollars ($15,000.00),

exclusive of attorneys’ fees, costs, and interest.

2. Plaintiff’s claims arise pursuant to 42 U.S.C. § 1983, the First, Fourth and

Fourteenth Amendments of the United States Constitution. This Court has jurisdiction pursuant

to 28 U.S.C. § 1331 and § 1343 over the § 1983 claims pursued herein.

3. That venue is proper in this Court, being the Western District of Kentucky, pursuant

to 28 U.S.C. § 1391.

4. All conditions precedent to the maintenance of this action have been performed or

have occurred prior to the filing of this action.

PARTIES

5. MS. WHITE is, and at all times relevant hereto has been, a lawful and physical

resident of Louisville, Jefferson County, Kentucky in the United States of America.

6. At all times material hereto, and upon information and belief, Defendant OFFICER

#1 was acting within the course and scope of his/her employment as an LMPD officer. Defendant

OFFICER #1 is, and has been, a natural person, sworn by the Commonwealth of Kentucky with

the ability to work as a police officer, and is, and has been, employed by LMPD as a sworn police

officer. Upon information and belief, Defendant OFFICER #1 engaged in and completed LMPD’s

police training academy and has been employed as a police officer with LMPD since that time.

2
Defendant OFFICER #1 is being sued in his/her individual capacity, as well as in his/her official

capacity for his/her actions as an officer for LMPD.

7. At all times material hereto, and upon information and belief, Defendant OFFICER

#2 was acting within the course and scope of his/her employment as a supervisory LMPD officer.

Defendant OFFICER #2 is, and has been, a natural person, sworn by the Commonwealth of

Kentucky with the ability to work as a police officer, and is, and has been, employed by LMPD as

a sworn supervisory police officer. Upon information and belief, Defendant OFFICER #2 engaged

in and completed LMPD’s police training academy and has been employed as a police officer with

LMPD since that time. Defendant OFFICER #2 is being sued in his/her individual capacity, as

well as in his/her official capacity for his/her actions as an officer for LMPD.

8. At all times material hereto Defendant, LOUISVILLE - JEFFERSON COUNTY

METRO GOVERNMENT (hereinafter “Defendant METRO”), is and has been, a political

subdivision of the Commonwealth of Kentucky, organized and existing under the laws of the

Commonwealth of Kentucky with a principle place of business located at 527 W. Jefferson Street,

4th Floor, Louisville, KY 40202.

9. At all times material hereto Defendant METRO, pursuant to Kentucky Revised

Statute (KRS) 67C.101 has and does operate and control the Louisville Metro Police Department

(hereinafter “LMPD”), its police officers, employees, agents, and representatives, including, but

not limited to, Defendants UNNAMED OFFICER #1 (hereinafter “Defendant OFFICER #1”) and

UNNAMED OFFICER #2 (hereinafter “Defendant OFFICER #2”).

10. Pursuant to KRS 67C.101, Defendant METRO is ultimately responsible for the

employment, training, retention, supervision and conduct of Defendants OFFICER #1 and

OFFICER #2. Thus, Defendant METRO is, in their official capacity, vicariously liable for the

3
tortious acts and omissions of Defendants OFFICER #1 and OFFICER #2. Defendant METRO is

also responsible for the LMPD policies and procedures that are described in this Complaint,

including the establishment of policies, either formally or by custom, regarding employment,

training, retention.

GENERAL FACTS
(APPLICABLE TO ALL COUNTS)

11. MS. WHITE is a 24-year-old woman, who on May 29, 2020, was exercising her

protected First Amendment rights as a peaceful protester in Downtown Louisville, Kentucky.

12. She was protesting the killings of Breonna Taylor, George Floyd, and other African

Americans at the hands of law enforcement, as well as calling for changes to practices of

systematic racism in the nation’s police departments.

13. Though protests nationwide have caused destruction to property, the protests in

Louisville had been mostly peaceful that evening, including the group MS. WHITE was protesting

with near downtown Louisville.

14. LMPD had decided however, to take a heavy-handed approach against protesters –

peaceful or not – meeting them with a show of force that included flash bangs, tear gas, pepper

balls and 40 millimeter blunt-impact projectiles. These weapons were all used the night MS.

WHITE partook in peaceful protesting.

15. Leaders in Louisville have publicly questioned LMPD’s use of these weapons.

Sadiqa Reynolds, president and CEO of the Louisville Urban League tweeted, “[i]t is insane to

thank people for peaceful protest and then use tear gas because you call it an unlawful gathering.”

She followed that tweet with another stating, “[t]he mayor and LMPD are not on the same page

and it is embarrassing."

4
 16. Louisville Metro Councilman Bill Hollander also said in an interview that police

have a “difficult job in the current situation,” but he had heard from constituents who attended the

protest and was “surprised by the use of tear gas before they were told to be home and when they

saw nothing but peaceful activity.” Hollander even called for an investigation of police tactics,

which included using tear gas without announcing it would be deployed.

17. At a department news conference, Major Dave Allen said tear gas was deployed

because police observed numerous homemade weapons in the crowd and on the streets, including

Molotov cocktails, bricks, wooden blocks, leaf blowers and jars that had been filled with urine and

vomit.

18. However, during the night of the incident, MS. WHITE peacefully stood with

around twenty (20) other protesters near the 500 block of West Jefferson Street. She, like other

members of this small group, was armed with only her cellphone, videotaping and chanting “hands

up, don’t shoot”, as a line of LMPD officers formed to face them head on.

19. This interaction, and the events that followed, were captured on MS. WHITE’s

“Facebook Live” video as well as the videos of other protesters.

20. Despite being unarmed and outmatched by their LMPD counterparts, the group of

protesters remained in their position on the street chanting and without advancing on, or

threatening, the officers.

21. Suddenly, with no warning and for no legitimate reason, LMPD officers, including

Defendant OFFICER #1, opened fire, and MS. WHITE was shot directly in the face with a rubber

bullet by Defendant OFFICER #1.

22. Upon reason and belief, the order to shoot was made by Defendant OFFICER #2.

5
 23. MS. WHITE dropped to her knees, screaming in excruciating pain, and was

immediately unable to see. Other protesters surrounded her in attempts to come to her aid and stop

the significant bleeding from the large wound to her head.

24. Friends of MS. WHITE also proceeded to run out in front of her in attempts to

shield her from further injury by LMPD, but they were then struck by projectiles as well.

25. One of the projectiles was recovered by the Plaintiff’s friends from the street. It was

large and stained with the same green paint that covered MS. WHITE’s face. See Plaintiff’s

Exhibit A.

26. No LMPD officers approached to assist MS. WHITE with treating her injuries or

to summon for emergency services.

27. Instead, MS. WHITE was eventually helped into a car by a group of protesters that

stated they were “protest medics”. The medics and other Good Samaritans then assisted in

transporting MS. WHITE to University of Louisville Hospital.

28. MS. WHITE was unarmed during this interaction.

29. No warnings, directions or commands were given regarding the potential use of

force if the group did not disperse.

30. MS. WHITE was not being charged with a crime. She was not attempting to flee

officers or resist arrest.

31. The group’s actions were not chaotic and neither MS. WHITE, nor those around

her, posed any threat to the safety of LMPD officers.

32. No one in the group was rioting or looting.

33. At the Hospital, MS. WHITE was hosed down to rid the wound of paint, pepper

spray and debris, but the wound was so significant that doctors could not stitch it up. MS. WHITE

6
recalls being unable to see out of her left eye for thirty (30) minutes and out of her right eye for an

hour and a half due to the swelling. Her face also sustained massive bruising and eventual scarring

from the assault. MS. WHITE’s injuries were documented by doctors and herself at the Hospital.

See Plaintiff’s Exhibit B.

34. Two days later, as she was still experiencing dizziness, vomiting, and issues with

her vision, so MS. WHITE returned to the Hospital for follow up treatment.

35. To this day, MS. WHITE has a large permanent scar from the assault as well as

permanent green marks. See Plaintiff’s Exhibit C.

36. As MS. WHITE was experiencing unemployment due to COVID-19, she did not

have active health insurance, and thus has incurred large amounts of medical debts.

37. As her injuries received national attention, she has also had to endure the mental

anguish of seeing her social media be flooded with death wishes and other cruel remarks by social

media commenters.

38. As a result of the unconstitutional and tortuous actions by the Defendants and/or

their agents, Ms. WHITE sustained serious and significant violations of her Constitutional rights.

39. As a result of the unconstitutional and tortuous actions by the Defendants and/or

their agents, MS. WHITE sustained significant physical, mental and emotional damages.

COUNT I: VIOLATION OF 42 U.S.C. § 1983 AND THE FIRST, FOURTH AND

FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION
(Against Defendants OFFICER #1 and OFFICER #2)

40. The Plaintiff incorporates by reference, as if set forth fully herein, each and every

averment, allegation and statement contained in all previous paragraphs of this Complaint.

41. 42 U.S.C. § 1983 provides that:

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

regulation, custom or usage of any state or territory or the District

7
 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 law shall be liable to the party injured in an action
at law, suit in equity, or other appropriate proceeding for redress...”

42. On May 29, 2020, Defendant OFFICER #1, acting under color of the laws of the

Commonwealth of Kentucky, and in the course and scope of their duties with the LMPD,

unlawfully injured MS. WHITE by shooting her with a rubber bullet without just cause.

43. On that same day, Defendant OFFICER #2, acting under color of the laws of the

Commonwealth of Kentucky, and in the course and scope of their duties with the LMPD,

unlawfully issued the order to fire upon peaceful protesters, which ultimately caused the injuries

to MS. WHITE.

44. These orders and the subsequent assault amount to a constitutional deprivation of

MS. WHITE’s rights, privileges and immunities, as secured by 42 U.S.C. § 1983, the First

Amendments and the Due Process clauses of the Fourth and Fourteenth Amendments to the United

States Constitution. These rights include:

a. The right to protest the government in redress of grievances;

b. the right to only be subjected to reasonable seizures, which encompasses the

right to be free from unnecessary and excessive force during such a seizure of

one’s person;

c. The right to be free from the use of deadly force that is not being used to prevent

the escape of a person whom the officer has probable cause to believe poses a

significant threat of death or serious physical injury to the officer or others; and

d. The right to be free from cruel and unusual punishment, including summary

punishment by law enforcement prior to conviction.

8
 45. Defendants OFFICER #1 and OFFICER #2, and all other reasonable police

officers, knew or should reasonably have known of MS. WHITE’s Constitutional rights at the time

of the conduct as they were and had been clearly established at that time.

46. In the course of their interactions, the named Defendants, acting under the color of

law, and in the course and scope of their duties with the LMPD, deprived MS. WHITE of her

Constitutional rights by shooting her under knowingly improper circumstances, even though they

knew, or should have known, that such circumstances were an unreasonable set of facts to permit

the use of that level of force in light of the facts and circumstances.

47. Defendant Officers also knew, or should have known, that such force was in

violation of MS. WHITE’s rights and that law enforcement officers are prohibited from engaging

in conduct which constitutes a deliberate indifference to these rights.

48. The only “conduct” MS. WHITE was alleged to have engaged in was the conduct

of a peaceful, unarmed protester, who was not fleeing arrest or posing a threat to officers.

Therefore, she maintained her clearly established Constitutional rights under the First, Fourth and

Fourteenth Amendments, including her right to bodily integrity and to be free from unlawful

seizures by law enforcement.

49. When using physical force, LMPD officers are also bound by their Standard

Operating Procedures (hereinafter “SOP”) Manual. Included in those Procedures are the following

requirements from Section 9.1 in regard to use of force:

a. An officer should, to the extent possible, utilize the lowest level of force

reasonable, depending on the situation. (9.1.4)

9
 b. Should physical force be necessary in order to gain control of a situation, an

officer will only use that force which is reasonable to gain control of the subject.

(9.1.5)

c. Special Impact Munitions Systems (SIMS) should only be utilized by officers

trained and qualified in their use. These include the 40mm launcher and the

sock round, which is fired from designated shotguns. The potential exists for

SIMS projectiles to inflict injury or death when they strike the face, eyes, and

neck. Officers should avoid intentionally striking these body areas, unless

deadly force is authorized (9.1.11)

d. Lethal force backup must be in place as support, prior to the deployment of

SIMS. Any time a SIMS is used, the subject should be transported to the

hospital for examination. (9.1.11)

e. The use of SIMS by the SWAT Team and SRT will be in accordance with the

manufacturer’s recommendations and the team’s operations manual. (9.1.11)

50. Defendant OFFICER #1’s actions in shooting MS. WHITE contravene LMPD’s

policies and training regarding the use of force and SIMS.

51. None of the reasonings for using force, including SIMS applied to MS. WHITE as

the Defendant Officers had no reason to believe MS. WHITE was engaging in any criminal

activity, as they didn’t take action to arrest her.

52. Said behavior is indicative that the Defendants acted in a manner that was

objectively unreasonable, intentional, reckless, deliberate, callously indifferent, wanton and/or

malicious, and was indicative of a total and reckless disregard of and indifference toward the

Constitutional rights of MS. WHITE.

10
 53. Defendant Officers were consciously aware that their actions resulted in an

unlawful and unreasonable seizure and punishment of MS. WHITE and were not only in violation

of MS. WHITE’S clearly established constitutional rights, but that they were likely to, and in fact

did, cause harm or injury to MS. WHITE.

54. Further, the Defendants’ actions were carried out in such a manner and with such a

significant amount of unnecessary actions that they shock the conscience, and unreasonably

restrained MS. WHITE of her freedom.

55. The Defendants’ actions were a deliberate deprivation of the Plaintiff’s rights

guaranteed by the U.S. Constitution under the First, Fourth and Fourteenth Amendments, as well

as those afforded under all other applicable state and federal laws, including but not limited to

those within 42 U.S.C. § 1983.

56. As the Defendants’ conduct was in part due to the following of the practices,

policies and customs of LMPD/Louisville Metro Government, the Officers have been properly

sued individually and in their official capacities under 42 U.S.C. § 1983, as the city itself is also

responsible for subject constitutional violations.

57. As a direct and proximate result of the constitutional violations described herein

and committed by Defendant OFFICER #1 and OFFICER #2, MS. WHITE suffered physical

injury, financial loss, embarrassment, and psychological harm which has created damages in

excess of the jurisdictional limits of this Court.

58. Defendants are therefore liable for their conduct which resulted in MS. WHITES’s

unlawful seizure and punishment, as well as all damages sustained by her.

59. The Plaintiff, SHANNYN WHITE, accordingly seeks damages including, but not

limited to, compensatory and nominal damages, legal fees, destruction of earning capacity,

11
physical and mental pain and suffering, and punitive damages from Defendants OFFICER #1 and

OFFICER #2.

WHEREFORE, the Plaintiff, SHANNYN WHITE, demands judgment against

Defendants OFFICER #1 and OFFICER #2, for all her damages, including costs and reasonable

attorneys’ fees pursuant to 42 U.S.C. § 1988, and any and all other relief this Court deems just and

proper.

COUNT II: VIOLATIONS OF 42 U.S.C. § 1983 AND THE FIRST FOURTH AND
FOURTEENTH AMENDMENTS TO THE UNITED STATES CONSTITUTION
(Against Defendant METRO)

60. The Plaintiff incorporates by reference, as if set forth fully herein, each and every

averment, allegation and statement contained in all previous paragraphs of this Complaint.

61. In order to establish a municipal liability under 42 U.S.C. § 1983, a Plaintiff must

show that the alleged constitutional violation occurred because of a municipal custom or policy.

Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 694 (1978). That requisite showing can be made by

demonstrating one of the following: “(1) the existence of an illegal official policy or legislative

enactment; (2) that an official with final decision-making authority ratified illegal actions; (3) the

existence of a policy of inadequate training or supervision; or (4) the existence of a custom of

tolerance or acquiescence of federal rights violations.” Burgess v. Fischer, 735 F.3d 462, 478 (6th

Cir. 2013).

62. Defendant METRO should also be held liable for MS. WHITE’s Constitutional

violations under § 1983 based on the following theories of culpability: (1) that an official with

final decision-making authority ratified illegal actions, (2) the existence of a policy of inadequate

training or supervision and (3) the existence of a custom of tolerance or acquiescence of federal

rights violations.

12
 (1) That an official with final decision-making authority ratified illegal actions

63. First, none of LMPD’s even minimalistic policies were followed by the Defendants

or other officers during the night of the shooting of MS. WHITE. Rather, Defendant OFFICER #2

and other commanding LMPD officer ratified the illegal actions of the unnecessary and improper

use of less-lethal weapons by ordering these types of less-lethal weapons to be utilized on peaceful

protesters.

64. Further, MS. WHITE’s shooting was not an isolated occurrence that evening or

during the duration of the protests. LMPD has ratified these actions, allowing its officers to

repeatedly violate their own policies as well as established constitutional law, resulting in injuries

to numerous protesters.

(2) The existence of a policy of inadequate training or supervision

65. Additionally, LMPD’s barebones SOP policies regarding the use of less-lethal

ammunition are indicative of the existence of a policy of inadequate training or supervision. In

comparing LMPD’s SOP policies to other departments across the country, it is clear that the level

of guidance given to LMPD officers regarding use of these weapons is less than adequate to ensure

the rights of protesters are being protected.

66. For example, Minneapolis Police Department’s policy manual lists the following

policies in regards to the use of less-lethal weapons:

a. Under Policy 5-317(I), the “MPD recognizes that combative, non-compliant,

armed and or otherwise violent subjects cause handling and control problems

that requires special training and equipment. The MPD has adopted the less-

lethal force philosophy to assist with the de-escalation of these potentially

violent confrontations.” See also, Policy 5-317(V)(C), noting the launcher “can

13
 be used when the incapacitation of a violent or potentially violent subject is

desired.”

b. Policy 5-317(II) defines a 40mm less-lethal round as a “[d]irect fire round used

in situations where maximum deliverable energy is desired for the

incapacitation of an aggressive, non-complaint subject.”

c. Under Policy 5-317(III)(D), MPD officers are forbidden from deploying the

40mm launchers for crowd-management purposes.

d. Policy 5-317(III)(B)(1) notes that “[t]he use of the 40mm less-lethal round

should be considered a level slightly higher than the use of an impact weapon

and less than deadly force when deployed to areas of the subject’s body that are

considered unlikely to cause death or serious physical injury.”

e. Policy 5-317(IV)(B)(1) outlines the acceptable “target areas” as follows:

• Large muscle groups in the lower extremities (buttocks, thigh, knees);

• Alternative target areas (ribcage area to waist and larger muscle areas of

shoulder).

f. Policy 5-317(IV)(B)(1) notes the following as areas to avoid:

• Head;

• Neck;

• Spinal cord;

• Groin; and

• Kidneys.

g. Policy 5-317(IV)(B)(2) states that “[o]fficers shall be aware that delivery of the

40mm impact projectiles to certain parts of the human body can cause grievous

14
 injury that can lead to permanent physical or mental incapacity or possible

death” (emphasis added).

h. Policy 5-317(IV)(B)(2) states that the “[a]reas susceptible to death or possible

severe injury are the head, neck, throat, and chest” and that these areas should

be avoided “[u]nless deadly force is justified” (emphasis added).

i. Policy 5-317(V) requires medical assistance to be rendered in accordance with

Policy 5-306. Further, if possible, officers are to take photographs of any

injuries to the subject.

67. These policies are far more detailed in giving guidance to officers than LMPD’s

policies. Such policies are indicative of an improper level of training in place within LMPD as to

the use of less-lethal weapons.

(3) The existence of a custom of tolerance or acquiescence of federal rights violations

68. Lastly, the failure to report, or to accurately report, the use of deadly force by

LMPD officers has also occurred repeatedly in the days of protesting. This indicates the existence

of a custom of tolerance or acquiescence of federal rights violations. LMPD has made it clear that

they do not intend to document or track these incidents, in efforts to review or document for

compliance with LMPD and constitutional standards. Rather LMPD will continue their custom of

acquiescence of such potential violations of federal rights.

69. Further, various groups controlled by Defendant METRO, including Louisville

Metro Council, have been made aware of the actions of officers, and have not sought to take any

steps to review these uses of force or the policies of LMPD. Multiple officers, including

commanding officers Major Aubrey Gregory and Assistant Chief Joshua Judah, have testified

about the actions of LMPD on these nights and yet Metro Council has taken no steps to review

15
their constitutionality or the constitutionality of LMPD’s SOP Manual regarding these procedures,

despite many council members making public comments about their concerns.

70. The decision of Defendant METRO to promote the conduct performed by the

LMPD Officers as alleged herein were outrageous, reckless and with blatant disregard for the

rights of the public, including the Plaintiff’s rights and were of a nature which shocks the

conscience.

71. Such a failure by Defendant METRO was the moving force behind the violation of

MS. WHITE’s Constitutional rights as the practices promoted by Defendant METRO left MS.

WHITE, who was doing no wrong, scarred for life and wondering what she could have done

differently.

72. As such, Defendant METRO is liable under § 1983. Leach v. Shelby Cty. Sheriff,

891 F.2d 1241 (6th Cir. 1989). Said conduct makes Defendant METRO liable for MS. WHITE’s

damages.

WHEREFORE, the Plaintiff, SHANNYN WHITE, demands judgment against Defendant

METRO, for all damages, including costs, reasonable attorneys’ fees pursuant to 42 U.S.C. § 1988,

and any other relief this Court deems just and proper.

PRAYER FOR RELIEF

WHEREFORE, the Plaintiff now respectfully demands this Honorable Court grant them

the following relief from the Defendants:

1. Individual judgments against all Defendants in an amount calculated to

fairly and reasonably compensate the Plaintiff for the damages she has sustained;

2. Nominal, compensatory and punitive damages against each Defendant in an

amount to be shown at trial;

16
 3. Pre-judgement and post-judgement interest;

4. Her costs and expenses herein expended, including reasonable attorney fees

pursuant to 42 USC § 1988 and KRS 411.130;

5. Trial by jury on any and all issues so triable; and

6. Any and all other relief to which the Plaintiff may otherwise be properly

and rightfully entitled.

Respectfully submitted,

___/s/ Ashlea N. Hellmann_________________

___/s/ Maria A. Fernandez_________________
Ashlea N. Hellmann
María A. Fernández
FERNANDEZ HAYNES & MOLONEY PLLC
401 West Main Street, Suite 1807
Louisville, Kentucky 40202
Phone: (502) 589-1001
Fax: (502) 589-7333
ahellmann@fhmlegal.com
mfernandez@fhmlegal.com

17
 CERTIFICATE

This is to certify that a copy of the foregoing motion was sent via certified mail to the following
parties, on this the 28th day of September 2020:

Louisville-Jefferson County Metro Government

Serve: Mayor, Greg Fischer
527 W. Jefferson Street, 4th Floor
Louisville, Kentucky 40202

C/c : Hon. Mike O’Connell

Jefferson Hall of Justice
600 West Jefferson Street
Louisville, Kentucky 40202

Officer #1
Serve: Louisville Metro Police Department
633 W. Jefferson Street
Louisville, KY 40202

Officer #2
Serve: Louisville Metro Police Department
633 W. Jefferson Street
Louisville, KY 40202

_/s/ Ashlea N. Hellmann______________

Ashlea N. Hellmann

18