HomeMy WebLinkAbout2019-cv-901 - Surat v. City of Fort Collins, et al. - 094A - DECLARATION OF MICHAELA SURATIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. ______
MICHAELLA LYNN SURAT,
Plaintiff,
v.
RANDALL KLAMSER, in his individual capacity, and
CITY OF FORT COLLINS, a municipality,
Defendants.
DECLARATION OF MICHAELLA SURAT
I, Michaella Surat, declare under penalty of perjury under the law of Colorado
that the following is true and correct to the best of my knowledge and information:
1. My name is Michaella Surat. I am over the age of twenty-one and am
otherwise competent to testify. I make the following statements based upon my personal
knowledge.
2. On March 26, 2019, attorneys at KILLMER, LANE & NEWMAN, LLP, filed a
Complaint and Jury Demand in the U.S. District Court for the District of Colorado as my
counsel for my claim of Fourth Amendment Excessive Force against Officer Randall
Klamser and the City of Fort Collins.
3. The subject of the lawsuit pertains to an incident that occurred on April 6,
2017. Officer Klamser slammed me face-first to the ground outside of a bar in front of a
crowd of people where I was there celebrating my twenty-second birthday. The
experience was extremely painful, degrading, humiliating, and traumatizing.
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4. On March 12, 2020, I am being deposed in this matter for a full day.
5. I have requested that my parents be allowed to attend my deposition for
emotional support.
6. I have a close relationship with my parents and they have been my
backbone, encouragement, and source of validation throughout my entire criminal case
and my ongoing civil case.
7. My parents’ attendance is really important to me because my experience
with Officer Klamser and his use of force continues to cause me severe emotional
distress. As I will be forced to recount my experience of pain and trauma, the presence of
my parents will provide me with comfort, strength, and reassurance during a stressful and
emotional all-day deposition.
I, Michaella Surat, declare under the penalty of perjury under the law of Colorado
that the foregoing is true and correct.
Respectfully submitted on this 9
th
day of March, 2020.
/s Michaella Surat___________
Michaella Surat
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