REQUIRE AN UNBIASED POLICE REVIEW PROCESS

SUMMARY BRIEF

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF WISCONSIN

ESTATE OF MICHAEL EDWARD BELL, by
Special Administrator Michael Martin Bell,
KIM MARIE BELL, MICHAEL MARTIN BELL, and SHANTAE BELL,
Plaintiffs,
Case No.: 02:05-CV-01176-CNC
v.
OFFICER ERICH R. STRAUSBAUGH,
OFFICER ERICH S. WEIDNER,
LIEUTENANT DAVID H. KRUEGER,
OFFICER ALBERT B. GONZALES,
KENOSHA POLICE DEPARTMENT,
CITY OF KENOSHA,
Defendants.

PLAINTIFFS’ PROPOSED FINDINGS OF FACT AND BRIEF IN OPPOSITION TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

INTRODUCTION

The defendants’ motion for summary judgment ignores every single disputed issue of material fact on every single one of the plaintiffs’ claims. The plaintiffs respectfully request that this Court summarily deny the defendants’ motion for summary judgment for the following reasons:

For these reasons, the plaintiffs respectfully request that this Court deny the defendants motion for summary judgment.