Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 1 of 80 PAGEID #: 656

UNITED STATES DISTRICT COURT

SOUTHERNDISTRICTOF OHIO
WESTERNDF^ISION

BERT DAMIANLEWIS
769 Rue Center Ct. # 1
Cincinnati, Ohio 45245 1l25CV481
Plaintiff,
vs.
J.COLE
CLERMONT COUNTY, OHIO
ioi E. Main Street
Batavia, OH 45103 -^u.:

and

CHRISTOPHERSTRATTON
In his official and individual capacity RECEIVED
4470 OH-222
Batavia, Ohio 45103 JUL 1 1 2025
and RICHAKUW.NAGEL
Clerk Of Court
CINCINNATI,OHIO
MICHAELJ. ROSS
In his official and individual capacity
4470 OH-222
Batavia, Ohio 45103

and

CHRISTOPHER BAARLAER
In his official and individual capacity
76 S. Riverside Drive, 2nd Floor
Batavia, Ohio 45103

and

STEPHANIE ROSS
In her official and individual capacity
76 S. Riverside Drive, 2nd Floor
Batavia, Ohio 45103

Defendants.

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COMPLAINTFORDECLARATORYAND
INJUNCTF^E RELIEF AND DAMAGES UNDER 42 U. S. C. § 1983
This is a civil rights action under 42 U. S. C. § 1983 seeking to remedy the repeated,

coordinated violations of Plaintiff Bert Damian Lewis's constitutional rights under the

First, Fourth, and Fourteenth Amendments by Defendants acting under color of state

law in Clermont County, Ohio. At its core, this case challenges a pattern of official

misconduct and retaliation orchestrated by Deputy Michael J. Ross, his spouse

Stephanie Ross, Clermont County Prosecutor Mark Tekulve, and senior officers within

the Clermont County Sheriffs Office and Prosecutor's Office.

In March 2020, Deputy Ross knowingly filed a false sworn statement - the BMV

Form 2255 - falsely attesting that Mr. Lewis had been arrested for operating a vehicle

under the influence ("OVI"), despite no arrest ever occurring. This perjured statement

triggered an invalid Administrative License Suspension ("ALS"), wrongfully restricting

Mr. Lewis's driving privileges for five years and forming the sole probable cause for later

felony charges.

In February 2025, Mr. Lewis exercised his fundamental First Amendment right to

petition the government when he formally reported Ross's misconduct to the Clermont

County Prosecutor's Office - unaware that Ross's own spouse, Stephanie Ross, held a

senior administrative post in the same office responsible for managing felony

indictments and grand jury oversight.

In direct retaliation, Defendants conspired to protect Deputy Ross by suppressing

exculpatory evidence, intimidating witnesses, orchestrating false statements, and

securing a secret six-count felony indictment predicated entirely on the same fabricated

2255. Prosecutors and deputies then used the invalid indictment and concealed

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evidence to trap Mr. Lewis under threat of arrest, detention, and ruinous reputational

harm - all to silence his exposure of Deputy Ross's pattern of misconduct and protect

the institutional interests of the Prosecutor's Office.

Defendants' misconduct, individually and collectively, deprived Mr. Lewis of his

liberty without due process, subjected him to malicious prosecution based on fabricated

evidence, retaliated against his constitutionally protected speech, and obstructed his

access to the courts and public records.

Mr. Lewis now seeks declaratory relief, injunctive relief, compensatory and

punitive damages, and all other remedies available under § 1983 to ensure that state

officials cannot misuse their authority to fabricate charges, silence whistleblowers, or

protect a corrupt officer from accountability.

UNCONTESTEDFACTS

i. This is a civil rights action under 42 U. S. C. § 1983 seeking declaratory, injunctive,

and monetary relief to redress ongoing and irreparable violations of Plaintiff Bert

Damian Lewis's rights under the First, Fourth, and Fourteenth Amendments to the

United States Constitution.

2. Mr. Lewis brings this action pursuant to 42 U. S. C. § 1983 for violations of his

constitutional rights to due process under the Fourteenth Amendment, to be free from

malicious prosecution and unlawful seizure under the Fourth Amendment, and to be

free from retaliation for exercising protected speech under the First Amendment. These

rights prohibit law enforcement officials and prosecutors from fabricating evidence,

concealing exculpatory information, and using knowingly false statements to deprive a

citizen of liberty or property under color of state law.

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3. Mr. Lewis seeks compensatory damages for the economic and non-economic

injuries he suffered as a direct and proximate result of Defendants' actions, together

with punitive damages, costs, and reasonable attorney's fees pursuant to 42 U. S. C.

§ 1988.
JURISDICTIONANDVENUE
4. This Court has jurisdiction over Mr. Lewis's claims pursuant to 28 U. S. C. § 1331,

which confers original jurisdiction over civil actions arising under the Constitution and

laws of the United States, including civil rights claims brought under 42 U. S. C. § 1983.

5. Venue is proper in this Court pursuant to 28 U. S. C. § i39i(b) because all or a

substantial part of the events and omissions giving rise to Mr. Lewis's claims occurred

within the Southern District of Ohio.

PARTIES
6. Plaintiff Bert Damian Lewis is a United States citizen who, at all times relevant

hereto, resided in the State of Florida and was engaged in lawful work and residence

there while being subjected to acts and omissions occurring in Clermont County, Ohio.

7. Defendant Michael J. Ross, at all times relevant hereto, was a Deputy Sheriff

employed by the Clermont County Sheriffs Office, acting under color of state law.
Defendant Ross is sued in both his individual and official capacities.

8. Defendant Christopher Baarlaer, at all times relevant hereto, was an Investigator

employed by the Clermont County Prosecutor's Office, acting under color of state law.
DefendantBaarlaer is sued in both his individual and official capacities.

9. Defendant Stephanie Ross, at all times relevant hereto, was an Administrator

employed by the Clermont County Prosecutor's Office, acting under color of state law.
Defendant Stephanie Ross is sued in both her individual and official capacities.

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IV. STATEMENT OF THE CASE

10. On February 11, 2025, Mr. Lewis contacted the Clermont County Prosecutor's

Office to report and seek clarification regarding a 2020 Administrative License

Suspension ("ALS") imposed through the Ohio Bureau of Motor Vehicles, which had

suspended his driving privileges in Ohio.

ii. At that time, Mr. Lewis did not know who was responsible for filing the ALS

against him and therefore contacted the Prosecutor's Office through the official email

address listed on the Clermont County government website.

12. On or about March 14, 2.02. 0, despite never having arrested Mr. Lewis, Deputy

Ross filed paperwork to impose an ALS against him after responding to a vehicle

accident in which Mr. Lewis's car was involved.

13. Under Ohio law, a valid arrest is a necessary condition to trigger the state's

"implied consent" statute, which requires a driver to submit to a breath or blood test

when an officer has probable cause to detain the driver for operating a vehicle under the

influence.

14. For an officer to lawfully impose an ALS in Ohio, he must first attest under

penalty of perjury that he has lawfully arrested the individual, which then triggers the
legal obligation for the arrestee to submit to chemical testing.

15. Refusal to submit to an implied consent test results in the immediate, automatic

suspension of all driving privileges, which under Ohio law is mandatory for at least one

year as a statutory penalty and deterrent.

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16. Deputy Ross did not arrest Mr. Lewis on March 14, 2020, nor at any time before

or after that date. Despite this, Deputy Ross knowingly swore under penalty of perjury

that he had effected an arrest, thereby exposing himself to potential criminal liability for

perjury under Ohio law.

17. By contacting the Clermont County Prosecutor's Office ("CCPO") on February 11,

2025, Plaintiff unknowingly implicated Deputy Ross for submitting a false sworn

statement under penalty of perjury.

i8. Additionally, at that time, Plaintiff was unaware that Deputy Ross's spouse,

Stephanie Ross, was employed by the CCPO and, upon information and belief, was

responsible for managing the same email account through which Mr. Lewis's report

implicating Deputy Ross for perjury was submitted.

19. In 2003, Deputy Ross faced national scrutiny for failing to advise a triple

homicide suspect of his right to counsel during an interrogation. Additionally, after the

suspect invoked the right to counsel, Deputy Ross disregarded his legal duty to cease

questioning and continued to elicit a confession, which was later suppressed and nearly

cost the prosecution its conviction.

20. Before and after this Miranda violation, Deputy Ross worked in the Narcotics

Division of the Clermont County Sheriffs Office ("CCSO") and was responsible for

numerous high-profile arrests in which he also served as a key witness for then-
Assistant Prosecutor M:arkTekulve.

21. Following the Miranda violations in 2023, along with other less severe prior

misconduct, Deputy Ross's career and arrest record were already at risk. The renewed

perjury allegations regarding the 2020 ALS created a clear pattern of misconduct that

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threatened his livelihood, reputation, and extensive arrest history - and could place

him on a Brady list within the CCSO.

22. This pattern threatened to undermine potentially hundreds of prior convictions

that Mr. Tekulve had prosecuted using Deputy Ross as a lead witness for many years.

Exposure of Ross's misconduct could implicate Tekulve for pursuing cases without

probable cause and would likely subject the Prosecutor's Office to extensive appeals

litigation, jeopardizing both the office's conviction rate and Mr. Tekulve's re-election

prospects.

23. Immediately after Mr. Lewis's February 11 exercise of his protected right to

petition the government for redress, he was subjected to severe adverse actions directly

connected to that same protected activity.

24. On February 18, Deputy Ross began harassing and intimidating Mr. Lewis's

friends and family living in Clermont County, spreading material falsehoods in an

attempt to coerce false statements against him.

25. This harassment continued through Febmary 23. After Mr. Lewis questioned

why Deputy Ross was permitted to pursue a criminal investigation against him only

days after he filed a misconduct complaint, Investigator Chris Baarlaer informed Mr.

Lewis that Deputy Ross had been directed not to engage with him further. This

instruction was intended to prevent Deputy Ross from further implicating himself in

misconduct. Meanwhile, Investigator Baarlaer began attempting to coerce false

admissions of criminal activity from Mr. Lewis.

26. Immediately after Mr. Lewis formally reported the retaliation to Investigator

Chris Baarlaer - expressly identifying all four elements of a retaliation claim -

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Prosecutor Tekulve, just two days later, authorized Deputy Michael J. Ross to conduct a

state-sponsored search of all Mr. Lewis's private online data, including accounts from

Google to Facebook. This was done despite the fact that no new evidence had emerged

since 2020, when the underlying matter was administratively closed.

27. From March through late April, the CCPO systematically cut off communications

with Mr. Lewis despite his continued good faith attempts to engage and resolve the

matter.

28. On April 30, 2025, Mr. Lewis sent an email to the CCPO requesting all

exculpatory evidence in its possession, including the original BMV Form 2255. He also

served Prosecutor Tekulve's office with a formal written request by USPS first-class

mail.

29. After another month of being ignored and having his document requests

unlawfully withheld in violation of Ohio law and the Rules of Professional Conduct, Mr.

Lewis, beginning on or around June 6, 2025, intensified his efforts to demand records

from the CCPO, the CCSO, and other municipal entities. This culminated in his formal

Notice of Intent to Litigate for Civil Rights Violations served on June 11, 2025.

30. On June 11, Mr. Lewis formally demanded additional records and documents

from the CCPO and notified Prosecutor Tekulve of his legal duty to preserve all key

evidence and prevent spoliation. Mr. Lewis's Notice of Intent to Litigate specifically

cited 42 U. S. C. § 1983 as the statutory basis for his claims.

31. After receiving no response, Mr. Lewis continued to make daily requests for

exculpatory evidence from Prosecutor Tekulve, who repeatedly stonewalled him by

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withholding numerous exculpatory documents and refusing to dismiss the charges,

despite having received clear exculpatory proof from Mr. Lewis months earlier.

32. On June 19, 2025, without prior notice, Assistant Prosecutor Brian Shrive, from

Tekulve's Civil Division, emailed Mr. Lewis and stated that despite nearly 50 days of

repeated requests, the Prosecutor's Office would not disclose any of the exculpatory

materials Mr. Lewis had demanded. Instead, Mr. Shrive told Mr. Lewis that if he wanted

the documents, he would have to travel 1, 100 miles to Clermont County, Ohio, and turn

himself in. Unaware of any pending charges, Mr. Lewis made it clear to Mr. Shrive that

he had no knowledge of any open proceedings against him. Mr. Shrive then insulted Mr.

Lewis, after which the CCPO ceased all further communication.

33. Days later, still without the critical exculpatory evidence he hadbeen demanding

for months, M:r. Lewis learned that on June 12, 2025 - just one day after he served his

Notice of Intent to Litigate - Prosecutor Tekulve's office had quietly secured a grand

jury indictment against him, secretly charging him with six aggravated felonies for

alleged criminal misconduct based entirely on Deputy Ross's perjured testimony used to

impose the 2020 ALS.

34. Mr. Lewis would later learn that Deputy Ross's wife, Stephanie Ross, was the

first person to receive his complaint implicating Deputy Ross for perjury, and that she

and Deputy Ross immediately took coordinated action against Mr. Lewis to protect

Deputy Ross's career and their fragile social standing, which had already been damaged

by Ross's Miranda scandal less than two years earlier.

35. Deputy Ross had also served as a key prosecution witness in numerous cases

involving critical chains of custody, with histestimony helping to secure convictions that

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bolstered Tekulve's conviction rate and, in turn, supported Tekulve's uncontested 2020

election as Prosecutor. Mr. Lewis's perjury allegations against Deputy Ross now

threatened to unravel that record and undermine everything that had come before.

36. Knowing that Mr. Lewis was unrepresented and lacked formal higher education,

the CCPO made no effort to conceal the obvious conflict of interest between Deputy

Ross - whom Mr. Lewis was accusing of serious misconduct - and Prosecutor

Tekulve's hand-picked "day-to-day administrative operations [director] for the

Prosecutor's Office, " who could "be contacted at the felony office. " Mrs. Ross's official

job description on the Clermont County Government Website further stated, without

qualification, that "shewill assist with Grand Jury

37- This is the same felony office that presented Deputy Ross's evidence to the grand

jury on June 12, 2025, which returned six aggravated fourth-degree felony charges

against Mr. Lewis, even though the alleged conduct had initially been classified as third-

degree misdemeanors.

38. In an effort to orchestrate a "surprise arrest, " the CCPO deliberately concealed

the indictment from Mr. Lewis in order to portray him as a "fugitive" and seek his

extradition from Miami, Florida back to Clermont County, Ohio, where he would be

detained without the possibility of bail in the Clermont County Correctional Facility.

There, as with others before him, Deputy Ross and the officials Mr. Lewis had

implicated in misconduct could coerce him into submission through intimidation and
force until he agreed to plead guilty to any charges brought against him - thereby

eliminating any challenge to the fraudulent ALS that Ross had falsely sworn in 2020.

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39- Unbeknownst to the CCPO, Mr. Lewis was at that time engaged in civil litigation

in the United States District Court for the Southern District of Florida, where, ironically,

Deputy Ross's fraudulent charges from the 2020 ALS had been used in 2024 as a basis

to file a civil suit against Mr. Lewis during a Department of Labor retaliation proceeding

brought by the same parties now accused of retaliation. As a result, Mr. Lewis had

acquired a basic, working familiarity with drafting and filing motions in federal court.

40. On June 30, 2025, Mr. Lewis filed several motions in the criminal case that he

believed was being used to permanently silence him. These included a motion for

remote appearance to allow him to be arraigned safely, a motion for bond to permit his

participation in the proceedings, multiple supporting affidavits (including one from a

third-party witness), and a detailed memorandum outlining the extreme danger he

would face if forced to surrender immediately in Ohio. That memorandum also

documented the egregious civil rights violations he had already suffered at the hands of

the CCPO and the Ross family. Mr. Lewis further filed a motion for a protective order

should he be required to return, while making clear that he fully intended to engage in

the proceedings and had presented a prima facie showing that the charges were

retaliatory and baseless.

41. On the afternoon before the long Fourth of July weekend, Judge Victor Haddad,

in less than 36 hours, unequivocally denied all relief Mr. Lewis had requested, without

providing any explanation. Judge Haddad ordered that Mr. Lewis must appear in

person and be remanded, despite Mr. Lewis having demonstrated no flight risk or
danger andhaving clearly described the imminent threat to his life, liberty, andproperty
if forced to surrender under those conditions. Most concerning, although Mr. Lewis held

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indigent status in the District Court, Judge Haddad disregarded this and denied him

even a public defender to advise him at that stage - while the prosecution continued to

concealthe indictment and benefit from a three-weektactical advantage.

42. Additional to this, despite working alongside both Stephanie and Michael Ross

for close to twenty years, Judge Haddad made no exceptions nor found any impropriety

in the clear conflict of interest that the Grand Jury indictment brought back against her

husband's accuser meant for his well-being, or the institutional stakes Tekulve had in

silencing Mr. Lewis' perjury allegations. This was to say nothing of the potential for

millions of dollars in appeals and over-turned convictions a perjury charge would cause

his office to have to litigate.

43. Still undeterred, Mr. Lewis spent that weekend drafting two motions: a Motion

for Judicial Notice to have Deputy Ross's perjured statement formally recognized in the

record to protect himself, and a Motion for Recusal requesting that Judge Haddad

appoint a neutral prosecutor due to the clear and egregious conflict of interest involving

the Rosses and Prosecutor Tekulve. Given that the CCPO had routinely appointed

special prosecutors for far less significant matters in the past, Mr. Lewis believed this

was a logical and fair request to present first thing Monday morning.

44. On Monday morning, when Mr. Lewis faxed his motions to the Clermont County

Clerk of Courts, he received a phone call immediately after the last page was sent. Mr.

Lewis allowed the call to go to voicemail to ensure that the communication would be

documented.

45. A staff member in the Common Pleas Division - the same division overseen by

Stephanie Ross - then left Mr. Lewis a voicemail stating: "Hi Bert, this is [Name]

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calling from Common Pleas Court in Clermont County. We keep receiving faxes from

you and unfortunately you can just stop sending them because your entry was denied. If

you need a copy ofthe entry, we would be more than happy to provide you with that, but

on January 2nd - that's when the entry was filed denying - July 2nd, excuse me - so

please stop faxing and have a great day.

46. Mr. Lewis now seeks relief from this Honorable Court for ongoing civil rights

violations committed under color of law in Clermont County, Ohio.

COUNTI: FOURTEENTHAMENDMENT
DUE PROCESSVIOLATION
(42 U. S. C. § 1983 - All Defendants, Individually and Officially)
47- Mr. Lewis incorporates paragraphs 6 through 46 as if fully rewritten herein.

48. Defendants Deputy Michael J. Ross, the Clermont County Sheriffs Office, and

the other named Defendants fabricated material false evidence - specifically the sworn

BMV Form 2255 - falsely asserting that Mr. Lewis had been lawfully arrested, when in

fact no such arrest ever occurred. This fabricated statement was used as the sole

probable cause to impose an invalid Administrative License Suspension ("ALS"), sustain

the related OVI charge, and secure the June 2025 felony indictment.

49. Defendants' deliberate fabrication, use, and concealment of this known false

evidence deprived Mr. Lewis of liberty and property without due process of law, in

violation ofthe Fourteenth Amendment to the United States Constitution.

COUNT II: FOURTHAMENDMENT

MALICIOUSPROSECUTION
(42 U. S.C. § 1983 - Ross, Tekulve, Baarlaer, Stratton)
50. M:r. Lewis incorporates paragraphs 6 through 46 as if fully rewritten herein.

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51. Defendants knowingly advanced, approved, and supported a criminal

prosecution preinised on false, fabricated evidence with no probable cause, in retaliation

for Plaintiff exercising his right to petition the government.

52. The June 12, 2025 grand jury indictment was secured through perjured

testimony and concealed conflicts of interest, causing a wrongful seizure of Plaintiffs

liberty interest under the Fourth and Fourteenth Amendments.

COUNT III: FIRSTAMENDMENT

RETALIATION FOR PROTECTED SPEECH & PETITION
(42 U. S. C. § 1983 - Ross, Stephanie Ross, Stratton, Baarlaer)
53. Mr. Lewis incorporates paragraphs 6 through 46 as if fully rewritten herein.

54. Defendant Clermont County and Defendant Sheriff Christopher Stratton had a

duty to exercise due and adequate supendsion over Deputy Michael J. Ross, Investigator

Christopher Baarlaer, and Chief Prosecutorial Administrator Stephanie Ross under

circumstances in which they knew, or in the exercise of reasonable diligence should have

known, that these individuals posed an unreasonable risk of fabricating evidence,

concealing exculpatory material, and retaliating under color of state law against

unrepresented litigants such as Mr. Lewis.

COUNT TV: FOURTEENTH AMENDMENT

FAILURE TO DISCLOSE EXCULPATORY EVIDENCE
(42 U. S. C. § 1983 - Stratton, Baarlaer, Ross)
55. Mr. Lewis incorporates paragraphs 6 through 46 as if fully rewritten herein.

56. Defendants intentionally withheld exculpatory documents, including the original

BMV Form 2255 and other records that disproved probable cause for the ALS and

subsequent indictment, in violation of their constitutional duty under Brady v.

Maryland, 373 U. S. 83 (1963).

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57. This deliberate concealment deprived Mr. Lewis of fair process and withheld

material facts necessary for his defense, constituting an independent violation of the

Fourteenth Amendment Due Process Clause.

COUNT V: CFVIL CONSPIRACY UNDER COLOR OF LAW

(42 U. S. C. § 1983 - Ross, Stephanie Ross, Stratton, Baarlaer)
58. Mr. Lewis incorporates paragraphs 4 through 46 as if fully rewritten herein.

59. Defendants acted in concert and entered into an agreement to protect Deputy

Michael J. Ross from accountability for prior perjury and Miranda violations by

unlawfully suppressing exculpatory evidence, manipulating grand jury testimony,

coordinating false statements, and manufacturing criminal charges against Mr. Lewis.

6o. This agreement and the overt acts taken in furtherance of the conspiracy

deprived Mr. Lewis of his constitutional rights guaranteed by the First, Fourth, and

Fourteenth Amendments to the United States Constitution.

COUNT VI: SUPERVISORY LIABILITY

FAILURE TO TRAIN AND SUPERVISE
(42 U. S. C. § 1983 - Clermont County, CCPO, Stratton)

6l. Mr. Lewis incorporates paragraphs 4 through 46 as if fully rewritten herein.

62. Defendants Clermont County, the Clermont County Prosecutor's Office and

Sheriff Chris Stratton, with knowledge of Deputy Ross's documented prior misconduct

- including the 2023 Miranda violations - failed to properly train, supervise, or

discipline Deputy Ross. This deliberate indifference created and maintained an

environment that enabled repeated constitutional abuses under color of state law.

63. This failure and deliberate indifference proximately caused Mr. Lewis's injuries

and resulting deprivations ofhis constitutional rights.

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COUNTVII: DECLARATORYAND INJUNCTWERELIEF

(42 U. S. C. § 1983 - Clermont County, CCPO, Stratton)

64. Plaintiff seeks a declaratory judgment that the Administrative License

Suspension and the indictment are invalid because they are predicated on perjured

evidence, and further seeks an injunction prohibiting any continued use of that false

evidence in any proceeding, along with an order directing the immediate correction of

all related state records.

PRAYERFORRELIEF

WBEREFORE, Plaintiff Bert Damian Lewis respectfully demands judgment against

Defendants Clermont County, Sheriff Christopher Stratton, Deputy Michael J. Ross,

Investigator Christopher Baarlaer, Chief Prosecutorial Administrator Stephanie Ross,

and each of them, jointly and severally, as follows:

a) Compensatory damages, including both economic and non-economic

losses, in an amount to be determined at trial;
b) Punitive damages to punish and deter Defendants' malicious, willful,
and reckless misconduct;
c) A declaratory judgment that the Administrative License Suspension
and the indictment are invalid because they were predicated on
perjured evidence;
d) A permanent injunction prohibiting Defendants from using or relying
on the perjured BMV Form 2255 or any derivative evidence in any
current or future proceeding;
e) An order compelling the immediate production of all exculpatory
evidence improperly withheld from Plaintiff;

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f) An order directing the immediate correction of all related BMV and

court records to remove any reference to the invalid ALS and
fabricated arrest;
g) Reasonable attorney's fees and costs pursuant to 42 U. S. C. § 1988;
h) Such other and further relief in law or equity as this Court deems just
and proper under the circumstances.
Dated: July 8, 2025 Respectfully submitted,

BERT DAMIAN LEWIS

chefdamianlewis@gmail. com
769 Rue Center Ct. #i,
Cincinnati, Ohio 45245
Tel: (754) 200-1970

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From: Chef Damian Lewis chefdamianlewis@gmail. com <^

Subject: NOTICEOF INTENTTO INITIATELITIGATION
Date: June11, 2025at10:34AM
To: Baarlaer, Christopher S. csbaarlaer@clermontcountyohio. gov, prosecutor@clermontcountyohio. gov,
prosoffice@clermontcountyohio.gov

NOTICE OF INTENTTO INITIATELITIGATION

Pursuant to 42 U. S. C. § 1983 and Related Statutes

June 11, 2025

Investigator Christopher S. Baarlaer

Clermont County Prosecutor's Office
76 S. Riverside Drive
Batavia, OH 45103
csbaa,rlaer@clermontaoyntyQ hio, goy

Investigator Baarlaer,

When I initially contacted Prosecutor Tekulve in February 2025, I did so in good faith-believing that
both he and his staff, yourself included, were upholding the constitutional obligations required of your
office. However, the record now reflects a pattern of omissions, misconduct, and procedural violations
that undermine that assumption.

Your office had access to the Ohio Automated Rx Reporting System (OARRS) at the time of charging
me in April 2020 and again in 2025. Despite that, you pursued an unlawful drug possession charge
without verifying that I had a valid buprenorphine prescription-documentation that I later submitted.
Under Ohio Rules of Professional Conduct 3. 8, prosecutors must refrain from charging individuals in
the absence of probable cause. Once exculpatory evidence under R. C. 2925. 11(B)(1)(d) was provided,
your officewas further obligatedto correct the record and dismissthe charge. You did not.
Accordingly, I request all documentation of OARRSaccess concerning my records by you, Deputy
Ross, or anyone under your direction.

I have also attached legal process notices from Google (Ref No. 25000950) and Meta (Case No.
9333878) confirmingthat search warrants for my digital records were issued by the Clermont County
Sheriff's Office in March 2025-after you stated Deputy Ross was no longer involved in my matter.
These warrants raise serious Fourth Amendment concerns, particularly given that the associated case
appears to have been previously administratively closed. Please provide all probable cause affidavits
and authorizations for these searches.

I am also submitting evidencefiled in U. S. District Court (Southern District of Florida)that contains

materially false statements by Deputy Michael Ross, whichappearto have been repeated or
supported by Deputies Curliss and Rudd. These statements were used to fabricate probable cause in
April 2020 and later cited by TSA, LLC-ownedby Sanford Satullo II-in a retaliatory civil suit filed
against me in October 2024. That suit followed my whistleblower complaint to OSHA filed on February
6, 2024, under 46 U. S. C. § 2114 (Seaman's Protection Act), and relied on the Clermont County
warrant to undermine my standing.

When I raised these facts with your office, rather than taking corrective action, you attempted to
extract admissions from me, solicited access to private medical information without legal justification,
and delayed adjudicationofthis matter unlawfully. This conductviolates both state and federal law.
This letter constitutes formal notice of my intent to initiate legal action in the United States District
Court for the Southern District of Ohio, Western Division, under 42 U. S. C. § 1983 and related civil
rights statutes. You will be named personally. Complaints with the Ohio Bar and the U. S. Department
of Justice are also forthcoming.

\A^ i i f^ yr\ V>f^y <^1;^<->^+^^I +^ r^ir^^^»-i/^ nil i'-nl^i»^>^+ I^I^+/M^;^I«^ ^^l^+;n<^ +^ 0+^+n tf I ^r«^ /^^^/^ M^
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 21 of 80 PAGEID #: 676

1 uu ai o iioiok^y UIIC;V^LCU LU [^icoovc; ail ici^vaiiL 1110, 10110, 10 icnciLiiiy LU OLQLU v. i-cvvio, ^yaocF i\'u.
2020TRC03599, and any communications, warrants, subpoenas, or investigative activity originating
from your office or affiliated agencies. Spoliation of evidence will be pursued to the fullest extent of
the law (see Silvestri v. GM, Zubulakev. UBS Warburg).

Anticipated claims include, but are not limited to:

1. FalsifiedALS affidavit and lack of probable cause (R. C. 4511. 191; State v. Whitt)
2. Improper BMVwarrant block affecting MMC credential
3. Enforcement of a warrant without timely judicial oversight {State v. Brooke)
4. Absence of signed Form 2255 or refusal advisement (R. C. 4511. 191(B))
5. Procedural defects in OVI citation/service (Crim. R. 3 & 4)
6. Failure to meet Brandenburg compliance for OVI arrest
7. Drug charge unsupported despite valid prescription (R. C. 2925. 11(B)(1)(d))
8. Invalid or unexecuted ALS paperwork (R. C. 4511. 1 92)
9. No evidence of use or possession of paraphernalia{State v. Codeluppi)
10. Overbroad and unconstitutional geofence warrant
11. Post hoc probable cause attempts (Franks v. Delaware)
12. Hearsay-based affidavits lacking first-hand observation {State v. Carlson)
13. Malicious prosecution and unlawful surveillance (42 U. S. C. § 1983)
14. Abuse of authority under color of law (42 U. S. C. § 1983)
15, Retaliation violating R. C. 2744. 03(A)(6)(b)
16. Harassment and menacing (R. C. 2917. 21, 2903. 21 1 -. 22)
17. Witness retaliation and obstruction (18 U. S.C. §§ 1513, 1514)
18. Speedy trial violations under Ohio law (R. C. 2945. 71)
19. Violations of due process under Albright v. Oliver
20. Additional statutory and constitutional claims to be identified in discovery

Moreover, Deputy Ross's procedural conduct in my case mirrors his actions in State v. Chad Doerman,
where evidence was suppressed due to constitutional violations. Your continued endorsement of
Pass's involvement despite this record creates exposure for Monell and supervisory liability claims.

Because Clermont County lacks a meaningful civilian oversight body for law enforcement misconduct,
I will also be circulating this matter to national press outlets and civil rights organizations. A draft
summary of the case is being prepared for distribution.
If your office wishesto discuss resolution or mitigation, I am availabletoday. Otherwise, formal service
will follow. Attached are my preliminary damages calculations.

Sincerely,

s/Bert Damian Lewis

BERT DAMIAN LEWIS
(954)357-2814
chefdamianlewis@gmalLcOTn

Exhibit l. pdf
 Case: 1:25-cv-00481-DRC-KLL
EXHIBIT E Doc #: 6 Filed: 08/21/25 Page: 22 of 80 PAGEID #: 677

From: Chef Damian Lewis chefdamianlewis@gmail. com

Subject: Final Demand for Public Records Production - April 30 Request(Expanded Scope)
Date: June 14, 2025 at 5:53AM
To: prosoffice@clermontaountyohio.gov, prosecutor@clermonteountyohio.gov, Baariaer, Christopher S.
csbaarlaer@clermontcountyohio. gov, mross@clermontcountyohio. gov

Subject: Final Demand for Public Records Production - April 30 Request

(Expanded Scope)

Dear Clermont County Prosecutor's Office,

This email concerns my public records request lawfully submitted on April 30,
2025, via first-class U. S. Mail and email, pursuant to Ohio Revised Code §
149. 43. The request sought all records from a closed criminal case involving
minor drug possession and OVI charges in which I am the subject.

As of today, more than 40 days have passed without any response,

production, or explanation as required under R. C. § 149. 43(B)(1). This delay
exceeds the legally permissible "reasonable period of time" and violates
Ohio's Public Records Act.

I am now expanding the scope of this request to specifically include:

All notes, inventory logs, and written documentation created by Deputy

Michael Ross regarding the search of the vehicle involved in the incident;

(With due consideration for the fact that the probable cause cited by Deputy
Ross was based on observable disorientation and unconsciousness, which are
symptoms more consistent with traumatic brain injury than intoxication; any
documentation Deputy Ross relied upon or submitted to justify the
warrantless search of the vehicle and its contents must now be produced
under your obligations to preserve and disclose exculpatory and procedural
material.)

Failure to comply with this request constitutes:

- A direct violation of R. C. § 149. 43;
- Grounds for a mandamus action in the Court of Claims or Common Pleas
Court;
- Exposure to statutory damages of $100 per business day (up to $1, 000),
court costs, and attorney's fees under R. C. § 149. 43(C).

Unless I receive the full responsive records-or a legal justification for any
withholdings-within 5 business days, I will escalate the matter with The Ohio
Attorney General's Public Records Division and file a formal lawsuit for
 Case: 1:25-cv-00481-DRC-KLL
EXHIBIT E Doc #: 6 Filed: 08/21/25 Page: 23 of 80 PAGEID #: 678

enforcement and damages.

I continue to request that records be sent electronically to this email address.

Please confirm receipt of this demand and advise of the immediate steps being
taken to comply.

Respectfully,
BERT DAMIAN LEWIS
chefdamianlewis@gmail. com
(Contact information on file with your office)
EXHIBIT ^\
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 24 of 80 PAGEID #: 679

»»»

Bi

Assistant Prosecutors Assistant Common Pleas

Prosecutors
Betsy Henninger
Capol A. Rowe Assistant Prosecutors
Jeannette Nichols Debbie Smith
Nick Norton
Zachary Lotspeich Jason Fountain Melissa McElfresh
Katherine Terpstra
Jacqueline O'Hara Joseph T. Mooney
Zachary A. Zipperer
Katelyn Mollet Julia B. Carney
Dorothy K. Smith
Christian Erhardt Daniel Startsman III
Christina Dattilo Municipal & Juvenile

Robert Barbate Lois List

Jesse J. Taylor Marie Sydnor

Jacob Sieber Michelle Sutler
^ .y
Clay Tharp Melissa Vetter

David Taylor
Assistant Prosecutors Victim Advocates
Lisa Vetter QM
Thomas H. Flessa
Investigations Allyson Ware Angela Kennedy
Thomas W. Scovanner
Michael J. Malott Suzanne Bullock Amy Irwin
Kara Bailey Jackie Hill
Chris Baarlaer

^
 Case: 1:25-cv-00481-DRC-KLL
EXHIBITS [ Doc #: 6 Filed: 08/21/25 Page: 25 of 80 PAGEID #: 680
Q. ome My Network Jobs Messaging Notificatkius Me .» For E'liS'ness-' Retry Prem

Stephanie Ross

GteiTnORt County PEaseGUting Attorney

University of Cincinnati

Clrcrinati Metropolitan Area . Contact info

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Experience

Clerrttont Gounty Proseeuting Attorney

Full-tifne . 21 yrs 13 nios

Executive Office Admimstrator

Jan 'WZ^ - Ptssent . 4 .,'rs 7 ffios

<? Grant Administration, Leadership and +1 skill

Victim Advocate
Sep 2003 - Present . 2'i yrs T! ")i:is

^ Communication. Crisis Intervention and +1 skill

Program Director
Ctenricftit County Proseei-itor's Office
Jai'i 2913 - Present. 12 vs 7 mas
BaiSBia, Oftio

^ Grant Writing, Grant Administration and +1 skill

Education

University of Cincinnati
Bachelor of Arts (B. A. ), Political Science and Government
1998 - 2003

UC Clermont College
Post-Baccalaureate Professional Certificate in Paralegal Studies, Law

Skills
EXHIBIT
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 26 of 80 PAGEID #: 681

Stephanie Nichole
506 friends

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Intro

^S>ij^:
Works at Clermont County

Studied Political science at University of Cincinnati

Married to Michael Ross

Simplystyiishsteph.etsy. com

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 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 27 of 80 PAGEID #: 682

(https://clermontcountyohio. gov/)

Tekulve marks first 100 days as Prosecutor

(https://clermontcountyohio. gov/2021, 04/13/tekulve-
marks-first-100-days-as-prosecutor/)
(https://clermontcountyohio. gov/2021/04/13/tekulve-marks-first-100-days-as-prosecutor/)

(https://clermontcountyohio.gov/wp-
content/UDloads/sites/4/2021/04/tekulve. jpg)From Mark Tekulve:

As the newly elected prosecutor for Clermont County, I want to first thank the voters
of Clermont County for the opportunity to serve as the Prosecutor. It is the highest
honor of my career.

Thejob of the prosecutor isn't simply about putting awaythe bad guys, prosecutors
have a duty to do justice. Additionally, the Civil Division of my office provides many varied legal services for all
Clermont County elected officials and their departments. We also provide legal services for other County offices
such as the Board of Elections, Public Health, the Public Library Board, the Veterans Service Commission, the
County Park District, and alt Non-Home Rule Township Trustees and their departments.

Fortunately, I have a talented team of attorneys, paralegals, and administrative staff who come to work every day
focused on serving the people of Clermont County. I could not be prouder to work with these great professionals.

Additionally, I've brought in a few new members to the office. David Gast is the chief of our misdemeanor criminal
division; Lara Baron-Allen is our new felony chief; Brian Shrive and Joe Mooneyjoin the civil division; and
Stephanie Ross is my chief administrator.

Nowfor some sobering numbers. In just the first few months of 2021, we havefiled 1, 253 new misdemeanor
criminal cases and 296 felony cases. Aggravated possession of drugs is the primary charge on approximately
one-third of the felony cases. The opioid epidemic has not ended here in Clermont County and more must be
done.

Our office has reinstituted the misdemeanor diversion program. This program allows first-time low level offenders
to participate in education and community service programs in lieu of a conviction. This will allow the offender to
understand the consequences of his or her actions without a permanent criminal record that may later interfere
with job opportunities. Our goal is to improve the community. Sometimes that means jail time, but other times
that means an approach that allows people to learn and grow and move on toward being a productive member of
the community. In every case, our prosecutors have the resources and ability to determine the appropriate course
of action.
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 28 of 80 PAGEID #: 683

My office also provides victim advocates to help comfort victims of crime and explain their rights. Our victim
advocate program is going strong. Stephanie Ross continues to shine, finding grants and other resources to
allow us to provide services to victims of crime at their critical time of need. We are proud to partner with the
YWCA in those efforts.

In the coming months you will see me and my team out engaging in educational and outreach efforts. If your
school, church, or other organizationwould like to hear from me or my team, please contact the Prosecutor's
Office at 732-7313 or via email at prosoffice@clermQntoountyohio.gov.

On behalf of myself and the entire prosecutor's office, thank you for the opportunity to serve.

New county prosecutor announces personnel

assignments
(https://clermontcountyohio. gov/2021,01,21/new-
county-prosecutor-announces-personnel-
assignments/)
(https://clermontcountyohio. gov/2021/01/21/new-county-prosecutor-announces-personnel-assignments/)

BATAVIA, OH - Mark J. Tekulve took office as the newly elected Clermont County Prosecutor on Jan. 4. To
implement an office structure dedicated to the effective and thorough pursuit of justice on behalf of the citizens
of Clermont County, and to continue to provide excellent legal representation to the Board of County
Commissioners, county elected officialsand townships, Tekulve announcesthese new personnel assignments
within the Clermont County Prosecutor's Office.

Lara Baron Alien has been named the First Assistant in the Common Pleas Division. Alien will assist with the
operation of the felony division, supervise the prosecution of our felony cases, will act as Lead Prosecutor on
major felony cases, and will serve as the initial point of contact for law enforcement with any questions on felony
crimes, investigations, searches, etc.

David M. Cast has been named the First Assistant in the Municipal Division. Gast will be responsible for the
operation of the Municipal Division of the Prosecutor's Office, will train all new Assistant Prosecutors, and will
serve as the initial point of contact for law enforcement with charging questions on misdemeanorcases, vehicular
fatalities, K-9 issues, etc.
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 29 of 80 PAGEID #: 684

Carol A. Rowe has been assigned responsibility for the day to day operations of the Grand Jury. Rowe will be
responsible for reviewing all cases submitted to the Prosecutor's Office for indictment consideration, and
scheduling and presenting potential felony cases to the Grand Jury.

Brian C. Shrive and Joseph Mooney have Joined the Civil Division. Both Shrive and Mooney are talented,
experienced and valued attorneys who will assist Ernie Ramos, First Assistant in the Civil Division, in continuing
to provide outstanding legal representation to the County Commissioners, county elected officials, townships,
etc.

Stephanie Ross has been named the First Assistant in charge of Administrative & Fiscal Operations. Ross will be
responsible for the day to day administrative operations for the Prosecutor's Office, and can be contacted at the
felony office. Additionally, she will assist with Grand Jury and will continue her role as Director of the Victim
Advocate Program.

Clermont County courts, other offices to close Friday

for detective's services
(https://clermontcountyohio. gov/2019/02/06/clermont
-county-courts-other-offices-to-close-friday-for-
detectives-services/)
(https://clermontcountyohio. gov/2019/02/06/clermont-county-courts-other-offices-to-close-friday-for-detectives-
services/)

BATAVIA, Ohio (Feb. 6, 2019) -All Clermont County courts and many county offices will be closed Friday, Feb. 8,
to allow employees to attend, view or participate in services for Sheriff's Detective Bill Brewer, who lost his life in
the line of duty on Feb. 2.

CLOSED

Sheriff's Office: Administrative offices close at noon Thursday and all day Friday.

Common Pleas Court: Closes at 2 p. m. Thursday and all day Friday. This also includes Probation, Law Library,
and Court Services.
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 30 of 80 PAGEID #: 685

EXHIBIT B
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 31 of 80 PAGEID #: 686

From: Chef Damian Lewis chefdamianlewis@gmail.com ^

Subject: Attn. Hon. Mark J. Tekulve re: 2020TRC03599; State v. Lewis
Date: February 11, 2025 at 7:58AM
To: piEQSiaffteeOGletmontGQuntyohiQ.gov
Ccj Chef Damian Lewis damoncalifornia@gmail.com

The Honorable Mark J. Tekulve

Clermont County Prosecuting Attorney
76 S. Riverside Dr. 2nd floor. Batavia, Ohio 45103
prQSoftice@clermQntcoyntyohiagQy

Dear Prosecutor Tekulve,

Please see the attached request regarding 2020TRC03599; State v. Lewis. Thank you in advance for
your time and I look forward to hearing from you soon.

Sincerely,

Bert Damian Lewis

chefdamianlewis@gmail. com
(415)937-2149

2020TRC03599_STATE_V_LE
WIS_DROP_REQUESTone2. pdf
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 32 of 80 PAGEID #: 687

From: Baarlaer, Christopher S. csbaarlaer@clermontcountyohio. gov f

Subject: Release
Date: February 12, 2025 at 11:30AM
To: chefdamianlewis@gmail. com

Mr. Lewis,

My name is Chris Baarlaer, one of Mr. Tekulve's Investigators. He asked that I look into the
matter you brought to our attention. In my initial review, I see the driver involved in this
crash was transported by squad to UC Medical for treatment. As a measure to verify the
accuracy of your complaint, I would like your cooperation and grant access to the medical
records for that treatment. I have attached a medical release form for your convenience.
Please fill this form out, date and sign and return a copy to me.

Regards

Christopher Baarlaer
Investigator
Mark J. Tekulve, Clermont County Prosecutor
76 S. Riverside Drive 2nd Floor Batavia, Ohio 45103
P: 513-732-7595
csb,am:laejj@^ermontcgunty^hLQ,goY
.

Confidentiality Notice: This message is intended for use only by the individual or
entity to whom or which it is addressed and may contain information that is
privileged, confidential and/or otherwise exempt from disclosure under applicable
law. If the reader of this message is not the intended recipient, or the employee or
agent responsible for delivering the message to the intended recipient, you are
hereby notified that any dissemination, distribution or copying of this
communication is strictly prohibited. If you have received this communication in
error, please notify me immediately by telephone.

UC. pdf
234 KB
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 33 of 80 PAGEID #: 688

From: Chef Damian Lewis chefdamianlewis@gmail.com

Subject: Re: Release
Date: February 12, 2025 at 2:36 PM
To: Baarlaer, Christopher S. csbaarlaer@clermontcountyohio. gov
Cc: Leslie Christy lesliechristy81 ©yahoo.corn, Daman Lewis damoncalifornia@gmail. com

Mr. Baarlaer,
I thank you and Mr. Tekulve for your prompt attention to my letter. As stated, I am committed to providing full
cooperation for the speedy resolution of this matter. Unfortunately, I would not have authority to release any
medical records for anyone involved in the accident. Nor did my insurance company provide that information to
me at the time. However, they did cover all medical expenses for those involved if this information helps.
Warm Regards,

Bert D Lewis

re; "My name /'s Chr/'s Baarlaer, one of Mr. Tekulve's Investigators. He asked that I look into the matter you
brought to our attention. In my initial review, I see the driver involved in this crash was transported by squad to
UC Medical for treatment. As a measure to verify the accuracy of your complaint, I would like your cooperation
and grant access to the medical records for that treatment. I have attached a medical release form for your
convenience. Please fill this form out, date and sign and return a copy to me. "
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 34 of 80 PAGEID #: 689

From: Chef Damian Lewis chefdamianlewis@gmail.com

Subject: Follow Up
Date: February 13, 2025 at 1:17AM
To: Christopher S. Baarlaer csbaariaer@clermontcountyohio.gov
Cc: Leslie Christy lesliechristy81@yahoo.com, Chef Damian Lewis damoncalifornia@gmail.com

Mr Baarlaer,

Following up on yesterday's discussion; am I mistaken that fora violation ofORC 4511. 191, Ohio's Implied
Consent law, to have occurred an individual must first have been arrested following probable cause for OVI?
From what I understand of Ohio's Revised Code and what is stated on websites for OVI attorneys, one must
first be arrested for any Implied Consent Testing to be mandatory, which is then violated by refusal. As
mentioned, my license was suspended for violating Ohio's Implied Consent law despite never being arrested for
OVI at anytime, anywhere, in my life. Could you help me make sense of this contradiction? Or better still,
explain what it is I'm misunderstanding? Apologies for the frivolous questions, however, I am still playing catch-
up with this matter. I would like to say, respectfully, this investigation seems to be working backwards from a
presumption of guilt lacking probable cause rather than having began with a presumption of innocence and the
burden for proving guilt residing solely upon the State. Thank you in advance for your response.

Kind Regards,
Bert Damian Lewis
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 35 of 80 PAGEID #: 690

The Honorable Mark J, Tekulve two months later. I now currently have an arrest warrant in Ohio for OVI and drug charges
Clermont County Frosecutor'B Office that I discovered by attempting to get a Merchant Mariner Crecieatial,
76 S. Riverside Dr, 2nd floor.
Batavia, OH 45103 Upon closer scrutiny of these charges, it become appnrsnt that Deputy ROHB, Deputy
prosoffice@clermontcountyohio. gov Ciirle88, and Deputy Rudd gave aworn teBtimony in affida\rits which aUestRd probable cauBe
exiated for my arreet for these charpes. A miraory glance at theu- police work ahows Aey
February 13, 2025
absolutely did not have probable cause to issue an arrest warrant against me, begiiiiiing
mth not. stating why they came to suspect I was personally of the driver at the time other
Mr. Tekulve,
than my name being listed on the title of the vehicle,
I write to you today to urgently request an official mvestigation be uiidertaken for
On February 11, 2025, I contacted the Clermont Coimty Proaemtor'a Office uid
misconduct under the color of law and egregioue violations of my and my family's Civil
explained the aforeinentioned facta; I provided documentary evidence supporting my
Rights. The reffirecced misconduct concernB Deputy Sheriffs of the Clermont County
complaint and requested prosecution drop their charges for lack of probable cause. I
Sheriffs Department m Clermont County, Ohio; namely Detective Michael Roas [Badge No,
additionally asked for an explanation as to why an administrative block prevented my MMC
123693), Deputy Jeffery S. Rudd (Badge No, 131699) and Deputy Cody Curiess (Badge No.
and Drivera License renewal considering I had never been arrested for OVI anywhere, or at
211424). Upon information and belief, ''the three stated Deputies violated my Civil Rights by
anytime, in my life. No answci was
-
forthcoming at that time. DayB later an investigator
misconduct in office, misfeasaiice, malfeasance and nonfeaaance beginnu-ig on or around
contacted me to request access to the medical records of those involved in the accident
March 14, 2020 and continuing until FeLniary 18, 2025 (ongoing at time of writing). In
deapite not having the authority to approve other individuals medical records release. I Eilso
concert, these three Deputies violated my Fourth, Fifth, Eighth and Fourteenth Amendment
asked the Inveetigator why my license had been suspendert despite never having been placed
Rights under Color of the Law and without ju8t cause. Upon knowledge and belief, tJ-ieae
under arreat for OVI aiid therefore never implied consent (nevermind not being placed
three violated their sworn duties as Deputy Sheriffs by interfering with civil rights,
false with
anywhere near the scene or hospital at the time). Again, no information was fortficoming.
fabricating evldB nce, filL&g maliciyus proeecution, filing reports, tampering
witnesses, tampering with evidence, denying medical care, abusing authority, failing to The Implied Consent statute for Uhio, 4611, 191, unequivocaUy gtatea that:

properly identify a suspect, providing improper testiinony, lacking probable cause to charge "Any person who operates a vehicle, streetcar, or trackless trolley upjm_&J^iBiorax_0£
a.cycvblic or private., property used by the public for vehicular travel or parking
for a crime, obstructing justice, dereliction of duty, obstructing official buaineaB and Beveral
within this atate or who is in physical control of a vehicle, atreetcar, or tracklef
other violationa of profesBional conduct; all of which amount to willfal, wanton and recklesB troUey shall be d_e@n^_jto liave eiven consent to a chemiciLl test or tests of the
miflconduct involving varioue instanceB of outright fraud, conimitted under Color of the Law. peFBon'B_wbole blood, blood senun or olasina. breath, or urine to determine the
alcohol, drug of abuse, controlled substance, metabolitt; of a controlled Bubstance, or
On March 14, 2020 my Drivers License was placed under an admmistrative Buspension
combination content of the perBOn'a whole blood, blood aeru-n or plasma, breatit, or
by the State of Ohio Bureau of Motor Vehicles tor violatinfi Ohio Revised Code Section urine jf__^,rre8t,ed for a YJolation_Qf division (A) w (B) of section 45U, 19 of the
4511.191(BX1), utherwiBft known as the 'Implied Cunsent Statute'. This was related to an Revised Code, section 4611. 194 of fhs Revised Code or a aubstantiaUy equivalent
automobile collision which a vehicle I owned and kept regristered in Ohio at my Mother'? municipal ordinance, or a municipal PVTorfii^.flgcje."

home was involved ui. Honever I have personally benn a resident of the State of California Once again, I have never been arrested for OVI in ray entu-e life, This iuiplieB that one of

since 2013, having left Ohio permaner. tly in 2003. Yet despite never being placed under tJ-ieae Deputies faiuified e\-'dence to the Ohio BMV to state 1 had been arrested and refussd

arreat at any time, aiiywhere, for OVI, DUI, D'\VI, or any other operating motor vehicle to submit to a chemical test, or some combinatioi] of t^ie three. Two of the Deputies then

wbUe intoxicated acronynis, my license was nevertheleas suspended two years for refusing swore under oath that probable cause eicisted to warrant my arreyi when it denriy did not.

to subinit to chemical teating following my arrest for OVI m the State of Ohio. Additionally, This matter haa complicated my life terribly. Despite this, I stated to the Prosecutor

chargps of drug posseRBion and drug paraphernalia were added to a baaeleas OVI charge my belief that mistakes wi'U hspren and only requested the cnatter be cleared up to permit
my ATC from being denied. However, on February 18, 2025, Deputy Roaa (Now Detective

Ross) began contacting members of my immediate family and relentlesaly haraasing them
including my disabled 66 year-old mother, contacting my close friends in Clermont County,
Ohio and making blatantly falBe atetements to them about me and naaking horribly baeelesa
claimp against my character, and furt-her intimidated several of tiioae close me, but atUl too
day has never attempted to contact me. Thia is a major, major concern that I now request
anyone from the Department of Justice down through the oversight ranks to the Clermont
County Courts to mvestigate and promptly put ft stop to this harassment before further acts
of misconduct and falsified police reports are made against myself or those clo8e to me. I
would also like some kind of explanation of why roy license was suspended without cause
and what probable cause evidence that was not stated exists to warrant my arrest.

Thank you in advance for your immediate attention to my very concerning matter,

^^y-
Bert Damian Lewis
(Addresa withheld for reasons of safety)
+1 (416) 937-2149
chBfdamianlBwuiaemaU.ciim
EXHIBIT i Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 36 of 80 PAGEID #: 691
DEPUTER.

February 19. 2025

Why are you contacting people ^fho bad no involvement with the accident on
Detective R.OSS, 3/14/2020 associated with Bert D. Lewis?
Answer:
It has come to my attention that after five years you have taken a renewed, vigorous
interest in theju?t resolution of the matter against me in Clermont County. Ohio; and that these Why weren't these people contacted prior to a warrant being issued despite
actions include harassmeiU of my immediate family membeK, cold-calling obscurely associated affidavits swearing probable cause for the arrest of Bert D. Lewis for OV^ existed?
individuals artempting to coerce statements against me, and in all instances makiiig false Answer:
statements regarding ti'. e charges which you had filed against me without probable cause in an
attempt to falsely drum up that probable cause. What probable cause would lead a reasonable person to believe on 3/14/2020 Bert D
1 expect you will not answer these questions, nor would any attorney advise you to do so. Lewis was the operator of the vehicle or the person at the scene of the accident?
However, perhaps insteadyou might askyourselfthese questions andjuxtaposethe answerswith Answer:

your swornduty as an Officerofthe Peacefor the State ofOhio,

I have contacted both State and Federal Agencies who conduct oversight of police What probable cause would lead a reasonable person to believe the operator of the
misconduct concerning your actions againstme in 2020 and the your current intimidation tactics vefaitle was under the iafluence of alcohol or drugs at the time of the accident?
now being employed to find any conceivable probable cause you did not have when charges Answer:

were fiied against me five years ago.

As I have officially indicated you as a perpetrator of gross misconduct against me, Who reported Bert D. Lewis had been arrested for OVI on 3/14/2020 to the BMV?
including falsifying a police report to the State Bureau of Motor Vehicles as well as having Answer:

Deputies sign off that probable cause existed to arrest me when it absolutely did not, I question if
it is ethical that Ae saire officer be conducting an investigation against me to find the missing If Bert D. Lewis was nit reported to have been arrested for OVI to the BMV, why
probable cause fnrough any means necessary. We will have to allow an oversight committee was his license placed under an administrative suspension for violation of Ohio's
decide that ;.n the end I suppose. Implied Consent law beginning on the day of the accident 3/I4/2020?
Please answer the following questions to me or ask yourselfthe same if you do not feel Answer:

youranswersare legally competent to standscrutiny in fatureproceedings.To wit:

How did you identify the operator of the vehicle in the accident on 3/14/2020?
Why haveyou net contacted Bert D. Lewisdespite havingbeinga professional Answer:
Detective and his contact information being public record?
Ans^Mer: Why was the operator not arrested at the scene yf the accident on 3/14/2020?
Answer:

Why, after S years, are you so now taking such a renewed interested in this case?
Answer: In your opinion as q Law Enforcement Professional, does making false statements
to, or attempting to coerce false statements from, individuals tangentially associated
Why wasthe inveitigationyou are now conducting nut conductedpreviously? with Bert D. Lewis in the interest of justice?
Answer: Answer:

Would au attempt to fiiid probable cause to arrest Bert D. Lewis not have been more In your opinion as a Law Enforcement Professional, would the methods used to
appropriate prior to hs^ing a warrant issued for his arrest? issiie a warrant for the arrcsl of Bert D. Lewis fit within the scope of procedural due
Answer: process and the presumption of innocence outlined in the U. S. Constitution?
Answer

Why are you contacting people who had no involvement in the accidentwho are
related to Bert D. Lewis?
Answer:

If Bert D. Lewis was arrested for OV1 on March 14, 2020; why was he nut Deputy ROBS,
processed, Hngerpriiited, or cited at the time? Upon closer inspection of the charges filed against me in May 2020, many
answer: inconBistencies stand out. Additionally, I am quite confused a.s to why The Ohio Bureau of
Motor Vehicles euspended my licenae for two years for violation of the ImpUed Consent Law,
Do you believe you havebeen boaesland impartial professionally regardingyour
when that law mandates an individual must fu-st be arrested for violation to have occurred.
prior and current investigation into charges filed againstBert D. I.,ewis?
Answer: I look at my record in Clermont County; no arrest for OVI. Perhaps it was in anticipation of
the sham OVI charge your co-Deputiea made against me at Uiat time, hopeful that their false
Are your current actions and investigation meant to serve and protect the public's atatementB aUesting probable cause would find me arrested and cloud the issue.
safety andwelfare? If not, please explain who they are meant to serve? As an initial matter, it would eeem that you, Deputy Michael Rosa (123693), and your
Answer:
coUea&uea, Deputy Cody Curiesa (211424] and Deputy Jeffery S. Rudd (131699), paid no
Did the warrant whichlacked probable causeto arrest ofBert D. Lewissupport the heed to the strict procedural rules that are in place for to protect citizens againBt police
Constiturina of the United States and the Constitutiou oflhe state of Ohio? misconduct. You did not arreat the operator of the vehicle at the scene apparently because
Answer: under the irJluence at the time. Had been under the influence,
tiiat, pB rson was not they you

wo'ild have had probable cause bo arrest them. Instead, for unknown reasons. Deputies
Are your current or prior actions against Bert D. Lewis respectful of his rights?
Answer; Rudd and Curleea sijETiied aworn affidavils that probable cause existed to warrant my arrest
for OVI despite nut identi^-ing me as the operator of the vehicle, or even as being preaent at
Are your current or prior actions againstBert D. Lewisan exampleofdefendingthe the scene of the accident. These are very clear-cut violations of my Civil Rights for which no
principles of liberty? excuse can be made. Unfortunutely, I beleve you'U find it gets worse...
Answer:
Upon closer scrutiny of your police work, it appfiars that a charge for illegal drug
Are your current or prior actions againstBert D. Lewisan exampleof stability, possession was added by you and your Deputies in April 2020; swearing under oath that
Fidelity and mornlity? probable cause existed to identify me BB the vehicle operator, thus making me the person in
Answer: posseaaion of the illegal controlled Bubstance. Thia charge HRB stained my record for five
yeara, unknown to me moBt of that tun&, most likely prohibiting icveral key career
Have you been expeditiousin the performance ofyour duty?
opporhmitiea, and therefor e, untold amounts of lost future earningB potential.
Answer:
As auch, I understand that for the past several days you have been aggicssively
Are your current or prior actions againstBert D. Lewisoieant to xdministcrthe law contactmy my family and friendo, who inform me Uiat you have been contacting any and
iu a just, impartial manner; affording him the same reasonabletreatment as all every person who may have over known me ill Clermont County, Bpreading injurious
other cases?
falsehoods about me uiid therefore stainuig my reputation arid good name. I imagine there
Answer:
probably Ie also an untold amount of others I am not aware of that you have contacted as
Are your current or prior actionscoacemmgBert D."Lewisin recognition ofthe weU. One of the many false Btatements you have recently made about me to uninvolved
limitations ofyour authority and not meant for your own personal advantage? third parties, is that at the time of the accident I illegally po88e8sed a prescription drug,
Answer:
buprenorphine, without havir. g a prescription. And r&gardless of whether or not I was the
vehicle's operator, this would be a charge you could definitely 'make stick' regardless of who
Thank you for your attention to this matter.
the actual operator was, a.s it was my vehicle, and thua, my responaibUity for posseeaion of
K-ind regards, any controlled substancea discovered within. That ia an undisputed fact. Another undisputed
Bert D. Lev'is
EXHIBIT^ljCase: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 37 of 80 PAGEID #: 692
DEPLTYR.

fact is ti^i&t at the time of the accident, and for nearly four years prior to the accident, I had I am by no means a mathematician, however, a quick back of the envelope calculation
a valid preiicription for buprenorphine issued, where I lived, by my Primary Care Physician puts four years worth of prescriptionB at 90 pills per month up to roughly 4, 320 each 8mg
and Uceiised health profeasional in LOB Angeles, Califcrnia, qnd therefore any charge for tablets of Buprenorphine, legally prescribed by my primary care physician from 2015 until
illegrally possessing a controUed aubstance would not, m fact, stick. on or about 2020. That would be 34, 660 mg of Buprenorphine one could legally account as
Ohio Revised Code Secti on - 2925. 11 PossesBJon of ControUed SubB tances being in my possession, It does not state how much you found in the vehicle, but I wiU
(A) No person shall knowingly obtain, possesy, or use a controlled substance guess it was uiider the 36, 000 mg fhreshold. But lilce I said, I'm no math genius.
or a controlled substance analog.
Dr. Darren Nea} was an Lieutenant Commander in the United States Navy and
CB) (1) This section does not apply to any of the following;
(d) Any person who obtained the controlled BubB tance pursuant to a additionally, like a father to me when I lived in Los Angeles. I cannot, say enough great
prescription iBBued by a licensed health profeBsionaI authorized to things about this man because he embodied every aspect that one might hope to find in a
prescribe drugs if tfie prescnption was iBgued for a legitimate medical human being and in an Officer, under color of law or not. AH such, I would suggest a much
purpose and not altered, forged, or obtained through deception or
commisaion of a theft offense.
softer approach when contacting him for he's unU^ely to be intimidated by a Clermont

The attached prescription, dated March 9, 2018, with detailed as follows, were almost County Sheriffs Deputy unlike my 66 yearold disabled mother or my 70 year-old aunt; who

exclusively filled by Walereens at 1747 N. Cthuenga Blvd, Lol AnBelea, CA 90028 near informed nae you of your relentless and menacing telephone contacts over the past several

where I resided for five years at 6726 Yucca Street, Los Angeles, CA 90028. days. Retired Officers of the United States Armed Forcea are far less easily to cower as are
disabled old ladies.
Dr, Darren M, Neal NPIt: 12151560859
I expect you will perform due diligence and quickly verify this prescription. Moreover,
Achieve Medical Group LIC»; 20A7202
23000 CrenBhaw Blvd. DBA* BN1484106 if nothing else, I presume your charge against me for illegal drug possession without a
Torrance, CA 90505 Buprenorphine 8mb Tablet prescription will be eliminated iinmediately from my record, as sworn probable cause no
*1 (310) 326-1147 90 each x 30 days
longer exuita to warrant my arrest. Had you used your detective akUls and found my very
public contact information at any time over the past five years to inquire about this matter,
I would have immediately cleared everything up for the both of us. ConBequently, none of
tfie untold damages to both my present and future earnings potential would have occurred,
for which your inaction was the proximate cause. As such, despite a history for not following
strict procedures in proceeaing auspecta, I trust your commitment to tfie just admiiiktration
of law wUl guide you to an expeditious performance of the duty to clear this charge.
I have contacted the FBI, Department of Justice Civil Rights Division, Ohio Office of
Inspector General, Ohio Auditor of State Special lovesiigations Unit, Ohio Attorney General
OCIC and ttie Clermont County ProBecutor's Office regarding your conduct against me and
my family and the violation of niy Constitution ally-gruaranteed Civil Rights. However, as
mentioned, I trust the prescription vesrification to your capable hands rather than going over
your head once again. As a United States Mariner with a similar command structure aa
yourself, I have no Gods before the chain of command, as I'm sure you can respect.
Thaiik you for your tun3 and your service.
an SQfS February 20, 2025
^^:^..-r^ s/Bert Damian Lewia

Gmail - Follow upto evidenet lutnnittedon1/19/2025 Gmail - Followupto evidencesubmittalun Ifl9/2025

Gmail

Follow up to evidence submitted on 2/19/2025

ChofDamtan Lewis <chefdamlanl8wts@gmall. com> Fri. Feb 21, 2025 at 12:00 PM

To: mross@clemiontcoLjntyohici.gf3V

Good morning,
I ani followingup on theexoneratingevidence I provided you on February 20 at 12:36am via text message.
This included a valid prescription for the medication that I havebeenchargedfor possessingwithout a valid
prescription. This also included ali of the pertinent information required to verify the authenticity of Lhal
prescription including the prescribing doctor and the location of the pharmacy where almost all of the
prescriptions were filled over a fouryearperiod. I would ap.prec.iateyour speedy attention to resolving thii
error ajid can be contactedby this email or by the phonenumber whichI textedyou from.

Thank you in advance for your attention to this matter and I look fora'ard to the speedy resolution as such.

Kind Regards,
Bert Damian Lewis

http* ://mu) .goo^ Ie£om/m iiI/u/0/Ti ka859c21i09fc& vicw=pl&sc arch==all & pcrmlh] d=thn*d-l: r-77S6lW8715690g94S5&iimpl=mtE-l:r-89)8HZ36a91B9S6232 iM]/uW?ili=es4c2E»fc&vicw=pl&t<: ill &pcroithid=thre»d-l;r-77861906715690894S5<k>impl=miE-*:r-891i 14-2368918956232
 y"
EXHIBIT(^Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 38 of 80 PAGEID #: 693
DEPUTYR.

Deputy ROBB, 17, In your opinioii as a Law Enforcement Officer, do the methoda used to iBSue a
Respectfully, could you please take a few moments and provide brief, concise anBwera warrant for the arrest of Bert D, Lewis fit within the acope of procedural due
to the foUowing tiuestiona regarding the Ohio BMV'a suspension of my drivuig privUeges process guaranteed within the U. S. ConBtitution?
and th>i issuance of an arrest warrant, both of which seem to be in violation of the United 18. If Bert D. Lewie was, in fact, arreatoci for OVT on March 14, 2020, why was he
States Constitution's 4th Amendment provisions and Article I, Section 14, of the Ohio not processed, fingerprinted, or cited with any documentation at the time?
Constitution? I would prefer to understand your methods to clear up any misunderstanding 19, If Bert D, Lewv. was informed of the consequences of refusal to Rubmlt to a
I might have prior io thy involvement of third parties for Aia matter. Thank you in advance chemical test via Form 2255 aa stated in the Complaint, where is his
far clarifying things aud T am ftvailable to help clarify any queatlona you have at any time. endorsement as such?
1. Why have you never cor-tacted Bert D. Lewis despite his contact information 20. Do you believe you have been honest and imparti.al m^A regards zo prior and
being a matter of public record for the entirety of your investigation? current investigati&R methoda concerning charges filed against Bert D. Lewis?
2. Why, after five years, have you taken such n renewed interest in the matter? 21. IB your current inveatigatioi) meant to serve and protect the public's safety and
3, Why was the investigation you are now conducting not conducted in the previous welfare? If so, please elaborate on bow they serve the public Lntereat or welfare.
five years? 22. Was the warrant isaued for the arrtist of Bert D. Lewis supported by the
4. Would an attempt to fmd probable cause to arrest Bert D. Lewis not have been Conetitution of the United States and the Constitution of the state of Ohio?
more appropriate prior to issuing a warrant for his arrest? 23. Are your current and prior actions toward Bert D. Lems reBpectful of his rights?
6. Wliy are you contacting relatives of Bart D, Lewis who had no involvement, or in 24. Are your current or prior actiona toward Bert D. Lewis an example of a Sworn
many instances prior knowledge, of the 3/14/202P accident? Officer actively defending the principlee of liberty?
6, Why are you contacting acquaintances of Bert D. Lewis who had no involvement, 25. A"e your current or prior actions toward Bert D. Lewia an example of a Sworn
or in m&ny mstances prior knowledge, of the 3/14/2020 accident? Officer exemplifying stability, fidelity and/or moraUty?
7. Why weren't these indmduals contacted prior to Issuing the warrant for t-he 26. Have you been expeditious in the performance of duties concernmg Bert D.
arrest of Bert D, Lewis tor OVI and illegaUy poBeessu-ig a controlled subatance? Lewis?
8. What probable cause would lead a reasonable person to believe that Bert D 27. Are your current or prior actions toward Bert D. Lewis meant to adiniaister the
Lewii operated the vehicle or ws even a peraon at the icene on 3/14/2020? law in a just, impttrtial manner with the same reasonable treatment as other
9. What probable cauae 7?ovld lead a reasonable person to believe the operator of CELSCB?
the veliicle was under the influence of alcohol or drugs at. that time? 28. Are your current or prior actions towards Bert D. Lewis respectful of the
10. Which Deputy reported to the Ohio BMV that Bert D. Lewis had been arrested limitationa of your authority and not meant for the benefit of your own personal
for OVI un 3/14/2020 and how was this reported? advantage?
11. Wa« Bert D. Lewil arreited far OV1 m 3/14/2020? 29. Waa violating Bert D. Lewis' HIPAA R'ghtg meant to serve the interest of justice
and if ao, how?
12. If Bert D. Lewis was not reported to the B^FV as being arreBted for OVI, why
was hia license placed under an adminiBtrative suspension for violation of Ohio's Thank you for your prompt attention to this matter, I look forward to cooperation between
Implied Cosiest law beEinnillE on tlie day of the accident 3/14/2020? the two of us for apeedy clarification of the referenced errorB; further quickly, respectfully
13, When did Bert D. Lewie refuse to give conaoDt to chemical testing upon being and expeditiously resolving the charges m the interest of preventing mamfest injustice,
arrested for OVI on 3/14/2020 and who was the arresting officer?
14. What method or metiiods were used to identify Bert D. Lewis as the operator of
February 21, 2026
the vnhicle on 3/14/2020?
15. Why was tiie operator of Qie vehicle not arrested at the scene of the accident or
at any time afterwards on 3/14/2020?
16. In yow opinion as a Law Enforcement Officer, would making false statements to,
or attpmpting to coerce false statements from, individuals roarginaUy aBBoeiated
with Bert D. Lewis represent actions that are in the interest of justice?

Page I of 2 Pa|?e 2 of 2

L.._

From-. Chaf Damlan Luwla chefd an-. lanlewis ®flmail, corn ^ From: FntditBtn, Howard Howard. Faldslein@OhicAGO. g3v #
Subject: Exonaratins Evkience f-oftow-up Subjact: OhioAflomey Gensral Inqui-y Po&ponse COaA:01043fl7
Uaf: February ?2, 20'ri pl 73BAM Oaf: FBbFU-ry 24, 2025 at9:54AM
To: mroaalBclBrmontcounty'ohlc'. BOv
To; Lowtn, Sort D che(damianlewiE®gma'l.con>

Fobruary 22, ZQ25 Dear Bert,

Deputy Ross,
Thank you for contactingthe Ohio Attorney General's Officeregarding a complaint you
Goodmorning, 1 am writing tofo;]owup on the vehRcatlon ofthe proscriptionwhichI sentto you at l2:3Bam on have against a County Sheriffs Office and County Prosecutorconcerning a potentiaj
ThursdayFebnjary20, 2035andthe dropping ofthe chargefor passassionof a controlled aubstance, forwhich a unjustified arrest.
warrant now exists. I would also like to follow "up on soma kind of answer as to why t had an administrative license
suspenBionforviolating Ohio'? ImptledConsentiawwithdue considarationfornaver having baen arrestedfor OVI In
my life; The Chlo Ravlsed Cue's stipulates that tc violata the impliod consent \SM an individual must first bo amsted for Ohio is a home rule state; meaning no state-elected official has the authority to oversee the
OV1. If I am misunderetandtny that law pleasB ccrrBct me. If I am not nilsundsfstanding that 'aw I axpgct you aro no day-to-day operations oflocally-clected officials. Consequently, the Ohic Attorney
doubt hardatwork rewovlng both ofthese unjustly filedcharyesfrom my pennansntrocord.
General's Officedoes not haveauthority over a law enforcement official such as a county
Haveyou hada chanceto answerthe qusstlony I ser-1yesterday? I'm vary curiouswhatprobablacausenowex'sts to
sheriffor prosecutor.d
maintain the warrant f'v OVI and how that probable CSUSB was/is determlnBd. I tiope that It Is not my name alone bsing
onthetitlaofthevehlda. I am not yn anomey, noram ! a police officer, howovor, it seems unlltoty that a rBasonabls Compiaints ofthis natiu-e againsta local law enforcementagency must follow a specific
person sat asjuror wouldfind:hatownershipof a vohiclebyItset/mBetatha burdenof proof beyond dearand
convindngwhichla mardatoryfortha issuanceof s warrantfor arrest. chain of command. Therefore, I recominendthat you first contact the SherifT;in addition,
you may wish to contact the internal affairsbureau, within the sheriff's department, if one
cannot Imagine with oil of fia controlled substancs chacics and balances It can take more than a day to authenticate exists.
>ie pr ascriptlon I gavo to you.Again, an additional sourco for vertflca'. lon /outcf ba e prBscriptlons balng filled at the
Valgreens IP Hollywood, CAwherg I filled 90CA-T oF alt the prescilptiRns. I irtalnly hops you're not sitting on my
conpratlng BVldense and somehow stiil trying to drum up pro'iabls cau; for my guilt because that Is not Justice. That Ifyou would like to file a complain*, againsta prosecutor, I recommend that you contactthe
inanifast injuatlco and ^ ia not a yood look for a Deputy Dotective, Ohio SupremeCourt's Disciplinary Counsel. The DisciplinaryCoiinsel is responsible for
ensuringthatjudges and atiomc>s abideby the Code ofPTofessional Responsibility, Should
Aa ycu can tal! I'm quite frustratBd with this matter. Addlticnallr, iderstnnd you have bean informing my frlBnds end
family that you know ms personally as wal! as many uthar fa!s-i ttamsnts. I do not In any way ramember aver you wish to file a grievancewith this counsel, you may reach them by using the contact
ing you, howuver, I must hava mads quite an Impre&sion 01 'ou. Please verify my prBscription and have Uis information below:
charge for possession of a controllad substance rBmovad from vaco'-d. Pleasa alao explain why my llcensa waB
suspended for failure to submtt to a chemical teat whan I was not istod for OV1. (f It Is fBquired that an Individual ba
arrested for OVI to violate the Implied consent taw, please romove that charge from my re ill. Do 1 Office ofDisciplinaryCounsel
mlaunderEtand thai arrest ia a prerequisfB dgment for violation of the impiled sonssnt law? As a concerned and The SupremeCourt ofOhio
wronged cit!7-en ) do not believe t am out of ordar far axpectlnQ sorr. g kind of explanation for why this is preventl", g my
Merchant Mariner Credantlaf from p'ucessing and tha ramwgl of my Drtvars Llcanas. I believe, in fact. I have an actual 65 East State Street, Suite 1510
Right to Know. Columbus, Ohio 43215
800-589-5256
Thankyouforyourtimeancf I wish you a good weekend. ] will bR in touch untit this nator is resulved. Be safe
and thank you tor your ssrvica.
tl^CS://'fV^'w.pdc .ohio.g(3y/

Very respectfully yours,

Howard FeJdstein
Constituent Liaison - Constituent Services and Outreach Section
Office of Ohio Attorney General Dave Yoat
»ub)M<: Halp RiiiadltlnaO-aip'naFitsr^ ^ Direct Dial: 419-245-2551
Toll Free: 800-282-0515
Deputy Chiri Ac><efTnaii
Ho^^. Fsl dstcin@ObloAGO. Gov

fithout her oefmission and

EXHIBIT^|Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 39 of 80 PAGEID #: 694
DEPLTYR.

, GonS8erin8-ypur{i]irtgs:wlBi the FBI and BCI, it is inappropriate for Del. Rossto reapond
toyou directly.3Asa.lF&tft*iie hasbeendirectednottot^pond byouroffice,the same ^
AppliiBsto the two, a(idttlonal named Gteputies. ? I will b9 point of contact on your matter here'

|Ttie issues^youhavepresentedarebeingreviewed.jAddiflonally,I havamadeinqulnes

;tb outside entities) am awaiting response from them, I eannotdtetats the speed in whicti ^
thosegntitles respond^ me. Oni?&I havereceived their responses, everything i«ill be ^^S
^^^j

'MarkJ'TekutvsiClsimontCountyPros^e^or^^^^g
76 & RwersidB b(ive2na Ftoor Batavla. Ohio 4S1CS
?P:513'732^59S A.. ».i«i:mm. «Ma :A
ysbaariaerSasmonteiBuntyphiff. gBiS'. ^^^^B

ConfldentialtfyNotlte:ThismwsageIsIntanttodfor usao'nl»!bytteIndMdual?!'entity »
wftpm or whl<?i a to Bihfressed and may contain InfonndUon thatto prMlBgedT"SSisl£ SS
S oni&JiteAddantUM'otJietwtsaexemptfromdtseloiunB'underappllcablelaw.ttthereader'
. ragem reBponsiDia n>r tiBst
g dellveriiigthsmessse®?°<heIntBndedroclplent, youareher^iy "otlfledthMWy; ""'S
K d(asemlnatloni distri&utlon pr cppytng of this communication l6stttetly_Rrohlbfted. It you'
S haverecehedthla.cominunlcatlon In error, Rleas»noUfymeImmediatelybytelephone.||
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 40 of 80 PAGEID #: 695

From: Chef Damian Lewis chefdamianlewis@gmail. com ^

Subject: Follow up to evidence submitted on 2/19/2025
Date: February21, 2025 at 12:00PM
To: mross@clermontcountyohio.gov

Good morning,
I am following up on the exonerating evidence I provided you on February 20 at
12:36 am via text message. This included a valid prescription for the medication
that I have been charged for possessing without a valid prescription. This also
included all of the pertinent information required to verify the authenticity of that
prescription including the prescribing doctor and the location of the pharmacy
where almost all of the prescriptions were filled over a four year period. I would
appreciate your speedy attention to resolving this error and can be contacted by
this email or by the phone number which I texted you from.

Thank you in advance for your attention to this matter and I look forward to the
speedy resolution as such.

Kind Regards,
Bert Damian Lewis

Achieve Medical Group

23000 Crenshaw Blvd.
Torrancg. CA 90S05
Phone: 310-326-1147 Fax: 310-326-1148

Patient: Bert D Lewis DOB-1/27/1980 Phone: 41 &-741-4048

Address: NA Sex: Male MRN: 59137183
NA, CA 90505

8 MGTABLETSL
SIG:Take 1 tabletsublingualy3 timesa day
DispenseAmt:90(Ninety)Tablet(30DaysSupply) Brand Necessary: No
Refill: 1
325-49 360-74 17S-100 D 101-150 D 151 S Over
Quantfty: D 1-2-i

Rx Notes: Suboxone "X* Number: XN14&4106

Signature: . . fzix-.^<?e>

Prescribed 8y; Darren M Neal, DO

NPI#: 1215150859
LIC#:20A7202
DEA#: BN14S4108
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 41 of 80 PAGEID #: 696

From: Chef Damian Lewis chefdamianlewis@gmail. com ^

Subject: Exonerating Evidence Follow-up
Date: February22, 2025 at 7:36AM
To: mross@clermontcountyohio. gov

February 22, 2025

Deputy Ross,

Good morning; I am writing to follow up on the verification of the prescription which I sent to you at 12:36 am on
Thursday February 20, 2025 and the dropping of the charge for possession of a controlled substance, for which a
warrant now exists. I would also like to follow up on some kind of answer as to why I had an administrative license
suspension for violating Ohio's Implied Consent law with due consideration for never having been arrested for OVI in
my life; The Ohio Revised Code stipulates that to violate the implied consent law an individual must first be arrested for
OVI. If I am misunderstanding that law please correct me. If I am not misunderstanding that law I expect you are no
doubt hard at work removing both of these unjustly filed charges from my permanent record.

Have you had a chance to answerthe questions I sent yesterday? I'm very curious what probable cause now exists to
maintain the warrant for OVI and how that probable cause was/is determined. I hope that it is not my name alone being
on the title of the vehicle. I am not an attorney, nor am I a police officer, however, it seems unlikely that a reasonable
person sat asjuror would find that ownership of a vehicle by itself meets the burden of proof beyond clear and
convincing which is mandatory for the issuance of a warrant for arrest.

I cannot imagine with all of the controlled substance checks and balances it can take more than a day to authenticate
the prescription I gave to you. Again, an additional source for verification would be the prescriptions being filled at the
Walgreens in Hollywood, CA where I filled 90%+ of all the prescriptions. I certainly hope you're not sitting on my
exonerating evidence and somehow still trying to drum up probable cause for my guilt because that is not justice. That
is manifest injustice and it is not a good look for a Deputy Detective.

As you can tell I'm quite frustrated with this matter. Additionally, I understand you have been informing my friends and
family that you know me personally as well as many other false statements. I do not in any way remember ever
meeting you, however, I must have made quite an impression on you. Please verify my prescription and have the
chargefor possession of a controlled substance removed from my record. Please also explain why my license was
suspended for failure to submit to a chemical test when I was not arrested for OVI. If it is required that an individual be
arrested for OVI to violate the implied consent law, please remove that charge from my record as well. Do I
misunderstand that arrest is a prerequisite element for violation of the implied consent law? As a concerned and
wronged citizen I do not believe I am out of orderfor expecting some kind of explanationfor whythis is preventing my
Merchant Mariner Credential from processing and the renewal of my Drivers License. I believe, in fact, I have an actual
Right to Know.

Thank you for your time and I wish you a good weekend. I will be in touch soon until this matter is resolved. Be safe
and thank you for your service.

Kind Regards,
Bert D. Lewis

From: Chef Damlan Lewis chefdamianlewis@gmail. com

Subject: Help Expediting Dropping False Charges
Date: February 21, 2025 at 5:15 PM
To: Sarah. Ackman@goV8rnor. ohio. gov

Deputy ChiefAckerman,

I humbly request you to inquire into a matter I can't seem to get traction with. In 2020, a vehicle I
purchased for my disabled mother's use was taken without her permission and was subseouently
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 42 of 80 PAGEID #: 697

Deputy Ross,
Respectfully, could you please take a few moments and provide brief, concise answers
to the following questions regarding the Ohio BMV s suspension of niy driving privileges
and the issuance of an arrest warrant, both of which seem to be in violation of the United
States Constitution's 4th Amendment provisions and Article I, Section 14, of the Ohio
Constitution? I would prefer to understand your methods to clear up any misunderstanding
I might have prior to the involvement of third parties for this niatter. Thank you in advance
for clarifying things and I am available to help clarify any questions you have at any time.
1. Why have you never contacted Bert D. Lewis despite his contact information
being a matter of public record for the entirety of your investigation?
2. Why, after five years, have you taken such a renewed interest in the matter?
3. Why was the investigation you are now conducting not conducted in the previous
five years?
4. Would an attempt to find probable cause to arrest Bert D. Lewis not have been
more appropriate prior to issuing a warrant for his arrest?
5. Why are you contacting relatives of Bert D. Lewis who had no involvement, or in
many instances prior knowledge, of the 3/14/2020 accident?
6. Why are you contacting acquaintances of Bert D. Lewis who had no involvement,
or in many instances prior knowledge, of the 3/14/2020 accident?
7. Why weren't these individuals contacted prior to issuing the warrant for the
arrest of Bert D. Lewis for OVI and illegally possessing a controlled substance?
8. WTiat probable cause would lead a reasonable person to believe that Bert D
Lewis operated the vehicle or was even a person at the scene on 3/14/2020?
9. What probable cause would lead a reasonable person to believe the operator of
the vehicle was under the influence of alcohol or drugs at that time?
10. Which Deputy reported to the Ohio BMV that Bert D. Lewis had been arrested
for OVI on 3/14/2020 and how was this reported?
11. Was Bert D. Lewis arrested for OVI on 3/14/2020?
12. If Bert D. Lewis was not reported to the BMV as being arrested for OVI, why
was his license placed under an administrative suspension for violation of Ohio's
Implied Consent law beginning on the day of the accident 3/14/2020?
13. When did Bert D. Lewis refuse to give consent to chemical testing upon being
arrested for OVI on 3/14/2020 and who was the arresting officer?
14. What method or methods were used to identify Bert D. Lewis as the operator of
the vehicle on 3/14/2020?
15. Why was the operator of the vehicle not arrested at the scene of the accident or
at any time afterwards on 3/14/2020?
16. In your opinion as a Law Enforcement Officer, would making false statements to,
or attempting to coerce false statements from, individuals marginally associated
with Bert D. Lewis represent actions that are in the interest of justice?

Page 1 of 2
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 43 of 80 PAGEID #: 698

17. In your opinion as a Law Enforcement Officer, do the methods used to issue a
warrant for the arrest of Bert D. Lewis fit within the scope of procedural due
process guaranteed within the U. S. Constitution?
18. If Bert D. Lewis was, in fact, arrested for OVI on March 14, 2020, why was he
not processed, fingerprinted, or cited with any documentation at the time?
19. If Bert D. Lewis was informed of the consequences of refusal to submit to a
chemical test via Form 2255 as stated in the Complaint, where is his
endorsement as such?
20. Do you believe you have been honest and impartial with regards to prior and
current investigation methods concerning charges fUed against Bert D. Lewis?
21. Is your current investigation meant to serve and protect the public's safety and
welfare? If so, please elaborate on how they serve the public interest or welfare.
22. Was the warrant issued for the arrest of Bert D. Lewis supported by the
Constitution of the United States and the Constitution of the state of Ohio?
23. Are your current and prior actions toward Bert D. Lewis respectful of his rights?
24. Are your current or prior actions toward Bert D. Lewis an example of a Sworn
Officer actively defending the principles of liberty?
25. Are your current or prior actions toward Bert D. Lewis an example of a Sworn
Officer exemplifying stability, fidelity and/or morality?
26. Have you been expeditious in the performance of duties concerning Bert D.
Lewis?

27. Are your current or prior actions toward Bert D. Lewis meant to administer the
law in a just, impartial manner with the same reasonable treatment as other
cases?
28. Are your current or prior actions towards Bert D. Lewis respectful of the
limitations of your authority and not meant for the benefit of your own personal
advantage?
29. Was violating Bert D. Lewis' HIPAA Rights meant to serve the interest of justice
and if so, how?
Thank you for your prompt attention to tMs matter. I look forward to cooperation between
the two of us for speedy clarification of the referenced errors; further quickly, respectfully
and expeditiously resolving the charges in the interest of preventing manifest injustice.

s/Bert D. Lewis
February 21, 2025

Page 2 of 2
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 44 of 80 PAGEID #: 699

Deputy Ross,
Upon closer inspection of the charges filed against me in M.ay 2020, many
inconsistencies stand out. Additionally, I am quite confused as to why The Ohio Bureau of
Motor Vehicles suspended niy license for two years for violation of the Implied Consent Law,
when that law mandates an individual must first be arrested for violation to have occurred.
I look at my record in Clermont County; no arrest for OVI. Perhaps it was in anticipation of
the sham OVI charge your co-Deputies made against me at that time, hopeful that their false
statements attesting probable cause would find me arrested and cloud the issue.
As an initial matter, it would seem that you, Deputy Michael Ross (123693), and your
colleagues, Deputy Cody Curless (211424) and Deputy Jeffery S. Rudd (131699), paid no
heed to the strict procedural rules that are in place for to protect citizens against police
misconduct. You did not arrest the operator of the vehicle at the scene apparently because
that person was not under the influence at the time. Had they been under the influence, you
would have had probable cause to arrest them. Instead, for unknown reasons, Deputies
Rudd and Curless signed sworn affidavits that probable cause existed to warrant my arrest
for OVI despite not identifying me as the operator of the vehicle, or even as being present at
the scene of the accident. These are very clear-cut violations of iny CivU Rights for which no
excuse can be made. Unfortunately, I believe you'll find it gets worse...
Upon closer scrutiny of your police work, it appears that a charge for illegal drug
possession was added by you and your Deputies in April 2020; swearing under oath that
probable cause existed to identify me as the vehicle operator, thus making me the person in
possession of the iUegal controlled substance. This charge has stained my record for five
years, unknown to me most of that time, most likely prohibiting several key career
opportunities, and therefore, untold amounts of lost future earnings potential.
As such, I understand that for the past several days you have been aggressively
contacting my family and friends, who inform, me that you have been contacting any and
every person who may have ever known me in Clermont County, spreading injurious
falsehoods about me and therefore staining my reputation and good name. I imagine there
probably is also an untold amount of others I am not aware of that you have contacted as
weU. One of the many false statements you have recently made about me to uninvolved
third parties, is that at the time of the accident I illegally possessed a prescription drug,
buprenorphine, without having a prescription. And regardless of whether or not I was the
vehicle's operator, this would be a charge you could definitely 'make stick' regardless of who
the actual operator was, as it was my vehicle, and thus, my responsibility for possession of
any controlled substances discovered within. That is an undisputed fact. Another undisputed
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 45 of 80 PAGEID #: 700

fact is that at the time of the accident, and for nearly four years prior to the accident, I had
a valid prescription for buprenorphine issued, where I lived, by my Primary Care Physician
and licensed health professional in Los Angeles, California, and therefore any charge for
illegally possessing a controlled substance would not, in fact, stick.
Ohio Revised Code Section - 2925. 11 Possession of Controlled Substances
(A) No person shall knowingly obtain, possess, or use a controlled substance
or a controlled substance analog.
(B) (1) This section does not apply to any of the following:
(d) Any person who obtained the controlled substance pursuant to a
prescription issued by a licensed health professional authorized to
prescribe drugs if the prescription was issued for a legitiinate medical
purpose and not altered, forged, or obtained through deception or
commission of a theft offense.
The attached prescription, dated March 9, 2018, with detailed as follows, were almost
exclusively filled by Walgreens at 1747 N. Cahuenga Blvd. Los Angeles, CA 90028 near
where I resided for five years at 6725 Yucca Street, Los Angeles, CA 90028.
Dr. Darren M. Neal NPI#: 12151550859
Achieve Medical Group LIC#: 20A7202
23000 Crenshaw Blvd. DEA# BN1484106
Torrance, CA 90505 Buprenorphine 8mb Tablet
+1 (310) 326-1147 90 each x 30 days

a Madical Group Z3WM Crenshraw B^d.

Tofrance. CA 90505
Phone: 310-326-'!147 Fnx: 31 0-325~1148

Patient: Bsrt D Lew^s

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MA. CA 90505
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Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 46 of 80 PAGEID #: 701

I am by no means a mathematician, however, a quick back of the envelope calculation

puts four years worth of prescriptions at 90 pills per month up to roughly 4, 320 each 8mg
tablets of Buprenorphine, legally prescribed by my primary care physician from 2015 until
on or about 2020. That would be 34, 560 mg of Buprenorphine one could legally account as
being in my possession. It does not state how much you found in the vehicle, but I will
guess it was under the 35, 000 mg threshold. But like I said, I'm no math genius.
Dr. Barren Neal was an Lieutenant Commander in the United States Navy and
additionally, like a father to me when I lived in Los Angeles. I cannot say enough great
things about this man because he embodied every aspect that one might hope to find in a
human being and in an Officer, under color of law or not. As such, I would suggest a much
softer approach when contacting him for he's unlikely to be intimidated by a Clermont
County Sheriff's Deputy unlike my 66 year-old disabled mother or my 70 year-old aunt; who
informed me you of your relentless and menacing telephone contacts over the past several
days. Retired Officers of the United States Armed Forces are far less easily to cower as are
disabled old ladies.
I expect you wiU perform due diligence and quickly verify this prescription. Moreover,
if nothing else, I presume your charge against me for illegal drug possession without a
prescription will be eliminated iinmediately from my record, as sworn probable cause no
longer exists to warrant my arrest. Had you used your detective skills and found my very
public contact information at any time over the past five years to inquire about this matter,
I would have immediately cleared everything up for the both of us. Consequently, none of
the untold damages to both my present and future earnings potential would have occurred,
for which your inaction was the proximate cause. As such, despite a history for not following
strict procedures in processing suspects, I trust your commitment to the just administration
of law will guide you to an expeditious performance of the duty to clear this charge.
I have contacted the FBI, Departnient of Justice Civil Rights Division, Ohio Office of
Inspector General, Ohio Auditor of State Special Investigations Unit, Ohio Attorney General
OCIC and the Clermont County Prosecutor's Office regarding your conduct against me and
my family and the violation of my Constitutionally-guaranteed CivU Rights. However, as
mentioned, I trust the prescription verification to your capable hands rather than going over
your head once again. As a United States Mariner with a similar command structure as
yourself, I have no Gods before the chain of conimand, as I'm sure you can respect.
Thank you for your time and your service.
February 20, 2025
s/Bert Damian Lewis
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 47 of 80 PAGEID #: 702

From: Chef Damian Lewis chefdamianlewis@gmail. com

Subject: Response
Date: February 24, 2025 at 11:49 AM
To: Christopher S. Baarlaer csbaarlaer@clermontcountyohio.gov

Thank you for your prompt reply. I appreciate that you are now looking into this matter and I look
forward to a speedy resolution. I do have one quick question; when I initially contacted your office to
inquire about why my license was suspended despite never being arrested for OVI, why was the same
deputy named in that email allowed to contact my friends and family, making false statements about
me and trying to coerce false statements from them? That seems to fit within the standards of
retaliation which are as follows:

A.) Engagement in a protected activity (emailing your office)

B. ) Deputy knowledge (Why after 5 years did he contact my family?)
C.) Adverse Action (harassment of my friends and family)
D.) Protected activity was contributing factor (why else would he be doing this?)

Also, late on February 19 (12:26 am on February20) I provided Deputy Ross exonerating evidence
that would preclude charges for possession of a controlled substance from being filed. This was a
prescription in my name for the substance which was apparently found in the vehicle, which again
was my vehicle. Was that evidence passed along? Thank you in advance.
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 48 of 80 PAGEID #: 703

From: requestrecords-noreply@google.com
Subject: [Time Sensitive] Notification from Google
Date: February 27, 2025 at 6:49PM
To: bdlcatichef@gmail.com

^'

Dear bdlcalichef@gmail-com,

Google has received legal process from a Law Enforcement authority compelling the

release of information related to your Google Account.

Request information

Legal request type Search Warrant

Jurisdiction Ohio (State)

Agency Clermont County Sheriffs Office (OH)

Reference number 25000950

Date of issuance February 25, 2025

To view more information about this release, please use the following link:

https://regyestrecords, gQogle_com_/yser_notice2

encodeJYej:LfiedWebTokeH5AbM_niWoZp^932z]vfrUb9RQ81VKnTKOa2yiPta|:

3EOQyS s_CTS4Dciw7jygSfrt:^egPb!2cfniCQ^JIm5Y18WX m^^^^^^

nPQG2_1NvJn59My9LK%SNgbniawg5s32oaAOKlZGBx!ZgQ8^^

For a copy of the legal demand, please contact the issuing authority using the information

provided above.

Regards,

Google Legal Investigations Support

 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 49 of 80 PAGEID #: 704

From: Records records@records. facebook. com

Subject: [Case #9333878]
Date: March 3, 2025 at 3:44 PM
To: bdlcalichef@gmail. com

Hello,

We have received legal process from law enforcement seeking information about
your Facebook account. If we do not receive a copy of documentation that you
have filed in court challenging this legal process within ten (10) days, we will
respond to the requesting agency with information about the requested Facebook
account. We may need to respond to this legal request within less than ten (10)
days if we have a reasonable belief that we are legally required to do so. Please
respond to this message with a copy of any documents you file with the court. If
you would like additional information about the legal process, please let us know as
soon as possible.

Thank you,
Law Enforcement Response Team

NOTICE: This email (including any attachments) may contain information that is
private, confidential, or protected by attorney-client or other privilege. Unless you
are the intended recipient, you may not use, copy, or retransmit the email or its
contents.

For information please visit:

https://www. facebook. com/safety/groups/law/guidelines/
and http://help. instagram. com/494561080557017,
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 50 of 80 PAGEID #: 705

From: Chef Damian Lewis chefdamianlewis@gmail.com ,

Subject: Follow Up
Date: March 23, 2025 at 3:48PM
To: csbaarlaer@clermontcountyohio.go

Mr. Baarlaer,

I am reaching out to you in good faith, once again, to inquire into the matter we first spoke about last
month. As you recall, this concerned charges filed against me by the Clermont County Sheriff's
Department which have little or no standing or probable cause. There are a few elements I would like
to address and respectfully ask for a follow-up at your earliest convenience.

By now you have no doubt verified that I was legitimately prescribed the medication which was found
in my vehicle on or around March 14, 2020. Why is the charge for possession of a controlled
substance still pending on my record despite the RC 2925. 1 1 stipulation that "Any person who
obtained the controlled substance pursuant to a prescription issued by a licensed health professional
authorized to prescribe drugs if the prescription was issued for a legitimate medical purpose and not
altered, forged, or obtained through deception or commission of a theft offense" does not apply? The
prescription was issued by my primary care physician who was a licensed health professional
authorized to prescribe drugs and was issued for a legitimate medical purpose and was not altered,
forged, or obtained through deception or commission of a theft offense. Is there something I am
missing i can further clarify to the Prosecutor's Office?

I very recently received notification from both Facebook and Google that Clermont County had
subpoenaed my data from them, to which both companies complied. I am assuming this was, in
essence, a "geofence" warrant and that Clermont County is attempting to determine the location of
my phone at the time of the accident. I would encourage Clermont County to additionally contact
Apple to verify if or not I was logged into the phone associated with those accounts at the time of the
accident.

Who witnessed the arresting officer advise me about the consequences of taking or refusing a
chemical test, using a form (BMV form 2255) and what method was used to identify me as the
operator of the vehicle? How did the arresting officer know that the person who signed the form was
me and not someone else? As I've never seen the form in question, where on the form does it state
the arresting officer's reasonable grounds to believe I was the individual who was under the influence
and operating the vehicle? When, approximately, did the arresting officer request I submit to a
chemical test? When did the arresting officer inform me of the consequences of taking or refusing the
test? When did the arresting officer notify me of the administrative suspension and right to appeal the
suspension? When did I refuse the test or test 'over the limit'? Why did the arresting officer not give to
me, personally, a sworn copy of the BMVform 22557 When and how were copies of the form sent to
the BMV and the court by the arresting officer and was it within 48 hours of me being arrested?
Finally, when exactly was I arrested for OVI in the State of Ohio?

As I'm sure you know already, the Fifth District Court of Appeals ruled in State v. Whitt that an "arrest"
is necessary before an A. L. S. can be imposed. Can you, or anyone in your office, help reconcile this
contradiction? And why was the officer I implicated in misconduct allowed to head the investigation
when it was restarted last month? Whywere none of my records subpoenaed five years ago, and why
was the diligence now being thrown at this matter not done prior to issuance of the warrants?

Ifyou can clarify any of this confusion it would go a long wayto repairing our prior contention and
would be greatly appreciated. I want to emphasize that I'm not looking to cause trouble for anyone.
I'm merely trying to clear up some confusion on my permanent record which is preventing me from
obtaining my MMC. From there I can get back to sea where I belong. Thank you in advance.

Kind Regards,
Bert Damian Lewis
March 23, 2025
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 51 of 80 PAGEID #: 706

Bert Damian Lewis

333 Las Olas Way, CU4 Suite 429
Fort Lauderdale, Florida 33301
chefdamianlewis@gmail . corn
April 30, 2025
Via Email And Certified Mail
Hon. Mark J. Tekulve, Prosecuting Attorney
Clemiont County Prosecutor's Office
76 S. Riverside Dr. 2nd floor. Batavia, Ohio 45103
prosoffice(|)clermontco'untyohio. gov
RE: Demand for Production of Evidence Supporting OVI and Related Charges - Case No. 2020TRC03599
Dear Prosecutor Tekulve:
This correspondenceis submitted in good faith, but withfirm intent to hold your officeto the very same
constitutional standards your office holds the citizenry of Clermont County, Ohio. As the Defendant in Case
No. 2020TRC03599, 1 hereby respectfully demand immediate disclosure of any and all documentary evidence
your office claims supports standing for the charges of OVI, possession of a controlled substance, or any
related statutory violations currently reflected on my permanent criminal record which prevent my Merchant
Mariner Credentialing.
Despite several months of good-faith cooperation with your office, including providing to your office
irrefutably exonerating evidence in my defense; I have received no legally sufficient proof that the remaining
allegedviolations are grounded m actual evidence, probable cause, or fact. If suchproof exists, you are legally
and ethically obligatedto disclose it. In particular, I demandproduction of:
1. The sworn affidavit of probable cause wed to jusfify issTiance of a .warrant;
2. Any evidence that I was physically present st the scene of the alleged ofFense;
3. Any field sobriety, chemical, or toxicology test results that wcmld establish impau-meDt;
4. Any completed and personally served BMV Form 2255, as required by B-,C. 4511. 192;
5. Any sworn report submitted to the BMV or the court indicating I refused chemical testing;
6. Any ofBeer statemeiit for wfaythey believed I operated a motor vehide under theiiifluence;
7. All identificationevidenceusedto conneetme, UQtthevehicle, wifethe allegedQffense.
If your officeis in possessionof any exculpatory or contradictory information, I herebyinvoke my right
it be disclosed immediately pursuant to Brady v. Maryland, 373 U. S. 83 (1963). If such material does not exist,
I request a written acknowledgment from your office confirming my right to quash these proceedings. Absent
any suchevidence, the record as it standsreflects as follows::
. No arrest m ALS suspension (State v. Whitt, 2012-0hio-3934 (5th Dist. }: arrest req. for valid ALS)
. No chemical or field sobriety test administered or refused (State v. Brandenburg, 146 Ohio App.
3d221 (2dDist. 2001) (Officersmust substantially comply withALSprocedures);
. No witness or physicalevidencelinks me asthe allegedoperatorof a vehicleunderthe influence;
. No Form 2255 exists (Andrews v. Turner, 52 Ohio App. 3d 69 (1988): ALS invalid w/o Form 2255);
. The vehicle involved was lawfully left in the custody of a third party;
. Theacddentscene(sharp curve on Amelia Olive Branch)ishighlyproneto vehicleacddents;
. Historicalweatherdatashows at the time of the accidentwassleeting andvisibilitywaslow;
. The reasonablegroundsusedto determine impairment is the sameto determine traumaticbram
injuries (officer(s) owedvehicle operator a duty ofcareforwhichtheywereculpably negligent).
. Controlled substancewaslegallyprescribedby legitimateproviderwithoutfraudor theft;
. No witnesshasin anywaytiedme to use or possessionof anydrugparaphernalia;
. ALSdespiteno advisementof rightto appeal(R.C. 4511. 197(C)(mandatory arrestandadvisement
. Paraphernaliachargelacks standingon legallyprescribedmedicationalone.
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 52 of 80 PAGEID #: 707

This matter has already caused substantial reputational harm both professionally and personally, is
currently preventing my right to obtain federal credentials, has been used against me in a civil lawsuit to
question my credibility, has caused a severe negative impact on my busmess, has and is currently violating my
HIPAA privacy rights, and may still rise to the level of malicious prosecution under 42 U. S. C. § 1983. I am
preserving all claims. In spite of the substantial impact this has caused to me, I have not yet retained counsel
hopeful to avoid lengthy litigation.
I humblyrequest your office'sresponseby May 14, 2025 to mutually preclude any furtherlegal actions.
Dated:AprU 30, 2025 Respectfully submitted,

--<"-:

Bert Damian Lewis

Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 53 of 80 PAGEID #: 708

zs^s
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Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 54 of 80 PAGEID #: 709

Clennont County Sheriff's Office

4470 State Route 222
Batavia, OH45103
Email: sheriff@clermontcountyohio. gov

Clermont County Prosecutor's Office

76 S. Riverside Drive
Batavia, OH45103
Email: prosecutor@clermontcountyohio.gov
Subject: Public Records Request Case No. 2020TRC03599/Deputy Ross Communications
June 8, 2025

To Whom It May Concern:

Pursuantto the OhioPublicRecordsAct, R.C. § 149.43, I herebyrequest accessto andcopies
of all public records in the possession of your offices relating to the investigation, arrest, and
prosecution of Bert Damian Lewis, specifically concerning Case No. 2020TRC03599, and/or
adminisb-ativeactions linked to the March 14, 2020 incident.
Please include, but do not limit the scope to:
1. All incident and supplemental reports authored by Deputies Ross, Rudd, Curless, or
any other CCSO personnel;
2. All affidavits of probable cause, warrant applications, and communications with the
Clermont County Prosecutor;
3. Bodycam footage, dashcam, or audio recordings from March 14, 2020, and from any
follow-up investigation;
4. Internal communications, emails, or memoranda between CCSO and Clermont County
Prosecutor's Office discussingBert DamianLewis;
5. Records or notes documenting interactions with third parties (family, friends,
employers) in 2025 related to this case;
6. Any documents or correspondence related to the re-opening or continuation of
prosecution after February 2025;
7. Copies of any public complaints, memos, or use-of-force reports associated with
DeputyMichael Ross.
Please provide electronic copies (PDF, MP4, etc. ) where possible. If any part of this request is
denied, please identify the specific exemption relied upon and written explanation. Please assure
compliance to this request on or before June 26, 2025 (14 business days). Thank you in advance.
Sincerely,
s/Bert Damian Lewis
BERT DAMIAN LEWIS
chefdamianlewis@gmail. com
(954)357-2813
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 55 of 80 PAGEID #: 710

MARKJ. TEKULVE
CLERMONTCOUNTY PROSECUTINGATTORNEY
76 S. RIVERSIDE DRIVE, 2N° FLOOR
BATAVIA, OHIO 45103
PHONE: (513) 732-7313
FAX: (513) 732-7592
WWW. CLERMONTPROSECUTOR. ORG

REQUEST FOR PUBLIC RECORDS

DateofRequest: JUNE 10, 2025

Name of Requester (only if voluntarily provided; requests can be under a pseudonym or made
anonymously): BERT DAMIAN LEWIS
Address of Requester (required for mail)

City: FT. LAUDERDALE State: FL Zip Code: 33316

Telephone Number of Requester (optional): 954-357-2813

EmailAddress ofRequester (optional): CHEFDAMIANLEWIS@GMAIL. COM

Description of records requested:
1. ALL NCCEm- AND SUPPLEMENTAL REPORTS AUTHORED BY DEPUTES ROSS, RUDD, CURLESS, OR ANY OTffiR CCSO PERSONNEL;
2. ^7T"AmroFpBOUB;E~CAU57(ORC1NALE7ND~iNV'EUpTLEMENTS)"AFn^^^^ BV DEPUTY BOSS OR ANY OTHER OmCEBWARBANT APPLUTCNS, AND COMMUNCiTCNSWrTH THE CLERMONT

COUNTY PaOSECUTOR; ALL CNABGNG IfBTBUMENTS, CRIMINAL COMPLAINTS, WOICTMENTS, IF ANY, ANY OTHEBMEICMENTS 08 DEM]SSALS_
i.'BODVCAMFOOnGE, DAsficAIUI^On AUDIO BECOBDIHGS FBOM MABCH 14, 2021, AND FBOM ANY FOL10W-UPWUESTJGATIONSHOW»«5TWE»IC LOCATION OF RECORDINGS
4.iilTEniui-COUMUNCATIONS,EMAIS,OBMEMORANDABETWEENCCSOANDCL£RMONTCOUNTVPROSECUTOR'SOmCEDBCUSSINGBE8TDAMIANLEWIS;
5: BECOBDS OB NOTES DOCUMENTWG NTERACTONS Wn-H TORD PARTIES (FAMLV, raENDS, EMPLOYERS) N 2D25 RELATED TO THIS CASE;
6. ANY DOCUMENTS 0« COMESPONDENCE RELATED TO TK BE-OPEMNG OB CONTIKUATBN OF PBOSECUTION AFTER FEaBUARY 2B28;
7. COPES OF ANY PUBLC COMPLANTS, MEMOS, OR USE-OF-FORCE REPORTS ASSOCIATED Wn-H DEPUTY MICHAEL BOSS.
°SF;^^^1^% »MSO^S^RU?ERO"S"^^^^^^
8. ALL LOGS, At "^CTN»T"X,^ STATEOFOH»V.LEW.,BE»TD.
~B3519J7wHETHEBAi;YONE'AT~ANYTWEACCESSEDTHEOMOAUTOMATEDRXREPOBTNGSYSTEMUNDEnj<Y_NAME,WHOACCESSEDIT,WHEN,ANDUNDERWHATAUTHORITY.
;risS^zSrS^^^
5. "L^BTS^^Tc^ETpsOESE°SETSEG"M^^^^^^^^^^
U:MY'ANDA^COimUNICATONS- lMU^EMO~s7l/EETG7aTis/PHONE"L6lS,VTCyBETWEENPROSECUTORMARKTCKULYE,_]NVESTCAJO^CHBBBAARLAE^D_EJ.UT^MICHAEL_ROS^ANYOTHE^DEPUTIESWrTH
T'HE'^E;Som'CO'UN'?V"S RIFF'S'OFF'ICE'TIUT'REFElTENCE'MY'CASE (STATE~OFO'H]0'V:IEWB, BE8T D. (202B TR C 035il», OtStRS, THE OHIO BMU, ANY PRESCmi-TlOKS BELATED TO ME, ANY WARRANTS SENT
CONCERNINGME OR MY PROPEBTY,ANY GEOFENCEWARRANTS;
14. BECOBDS 0« NOTES DOCUMENTING NTERACTIONS WITH THBD PARTES (FANl. Y, RIENDS,
S'ftLN7^CUMENTSOBCORBESPOIIDENCERELATEDTOTHEBE-OPENWGOnCONTINUATIONOFPROSECUTIONAFTEBJANUABY2025;
i ^^^SS^^i^Slp^^S^S^^^S? SI^^S'S^cSScTED OU,.0 THEPROCEEDSS^E0.OXO ..LEW.,B»T0.P..T,C .3S»)
PLEASEPBOVCEELECTBONCCOPES(PDF,MP4,ETC.) WHEREPOSSBLE.IFANYPABTOFTKSREQUESTB DEUED,PLEASECEIfTFYTHESPECTOEXEMPTIONRELEDUPONAIDWRFTTENEXPLANATION.PLEASEASSUBE
COMPLIANCE TO TUB REQUEST ON OB BEFORE JUNE 30, 2D25 (U BUSWESS DAYS). THANK YOU W ADVANCE.

Desiredformat (paper, electronic, etc. ):

Method of delivery (in person or via email, standard mail, elecfa-onic media, etc. ):
EMAIL

Form Created October 7, 2021

EXHIBIT I»lCase:
I 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 56 of 80 PAGEID #: 711
pRoxiMiryl

Baarlacr, Christopher S. logically deduce that it was your mate Deputy Detective Micheal Ross who somehow got a
Clennont County Prosecutor's Office warrant to rifle through my private afFairs, though for what reason I'm a tad bit befuddled. You
76 S. Riverside Drive see, from what I can tell, that fraudulent OVI mess you've now played a tremendous part in
Batavia. OH45103 perpetuating has been administratively closed for quite some time. [n fact, to my knowledge
csbaarl aer®ciermontcountvohio , fiov there is nu reason that the Clermont County SheriflT's Department would or should have an open
investigation in against me unless it was opened for an improper purpose, and for which you
Subject: Supplementalto PublicRecordsRequestCaseNo. 2020TRC03599 would have been duty-bound to disclose to me. Is it legal for a Deputy to have warrants issued
for retaliatory purposes? Get your law book out and you get back to me on that one because I
Investigator Ba&rfaer, don't believe that dog'll hunt. Let's keep moving...
When I first wrote Proseciitor Tekutve in February 2025, I was under the impression that From there, you'll find attached several court filings, specifically from the United States
both the Prosecutor and his staflF-includingyourself-had swom to support the Constihition of Distnct Court for the Southern District of Florida, The first documenK you will no doubt find
the United States and the Constiturion of the State of Ohio; and to farther faithfully discharge the famiiiar, like a comfortablepair ofwoolensocks on that first chilly autumn evening(just kidding
duties of the Prosecutor of Clermont County, Ohio, to the best of your abilities. However, that I moved away from that amateur-hour weather 25 years ago). All jokes aside you'll see the
that clearly has not been the case... fraudulent affidavitsandmanufacturedevidencecourtesy of Deputy R-oss,which he and his pals
Indeed, at the time in question (February 2025), you willfully concealed from me that you drummed up against me in April 2020 when they pulled probable cause out of thin air for their
had full access to the Ohio Automated Rx Reporting System (OARRS), a too! used to track the malicious prosecution 2020TRC03599 State v. Lewis. Well, that wu, weaponized as rettliation
dispensing and personal famishingof conlToIled substances.Additionally, you further concealed by a Yacht owner who I reported violating maritime safety laws and regulations to th° United
that the Clennont County Prosecutor's Office has had access to this system for some time now, Stag es Coast Guard and OSHA pursuant to 46 USC 2114 The Seaman's Protection Act in 2023.
including when charges were originally filed against me five years prior in April 2020, I now ask During that Department of Labor proceeding they literally filed a fraudulent lawsuit against me
you: Is this the concept ofjustice which inspired you to pursue a career in law enforcement? by using a perjured statement for standing to file. Their perjured statement and your Deputies
Your actions-and the similar conduct of Deputy Sheriffs clearly mnning amok among the perjured statements were the only probative exhibits submitted for standing to file suit. I'm not
Corridors of Justice in Clennont County, Ohio-directly contradicts U. S. Supreme Court rulings sure if you have been awareof those proceedings ail this time or not. But that is concrete harm
in both firadyv. Maryland, 373 U. S. 83 (1963), Mid Ofcft'cv. Umled Stales, A05 US. 150(1972) and actual damages as a result of actions you are currently part of perpetuating. I have
prohibiting suppression of excuipatory and/or impeachment evidence. The Clennont County additionally included some of my filings in that case and the OSHAcase which was eventually
Prosecutor's Office has lung knowti-well beyond just the prior five months-that it lacked legal removed to District Court via the 46 CFR 1986 "kick-out" provision (I'd "exhausted my
standing to pursue charges for possession of a controlled substance against me. And yet your administrative remedies" and therefore a statutory right to 3eek relief via jury in Federal Court
office acted cohesively as a unit to perpetuate injustice against a citizen rather than uphold the aroseaftertolling 210 dayswithouta fina! decision). Whichbringsme to my nextpoint:
oath of office to which you all were sworn. Now we both know I don't need to tell you this. And There'sno needto go over whathashappenedhere.Although, it seems that ever/ time I go
yet, here I am telling you, looking into Deputy R. OSS' or your conduct, I find some new underhanded gamesmanship outside
Please consider this my official supplemental request for all logs, access records, or reports the bpunds of appropriate conduct. I stay fairly busy with those two District Court cases (as one
evidencing the use of OARRS by yourself, Deputy Ross, or any agent acting on behalf of does) and therefore, I had no interest in pursuing yet another Federal Court action against a
Clemiont County in connection with Case no. 2020TRC03599, State of Ohio v. Bert D. Lewis. In group of morally bankrupt halftvits and so I came to Prosecutor Tkoivey and explained my rights
the event no such records docs exist, I ask: why don't they? Why wasn't this information cross" and your lack of standing, hoping you all would just do not what was right, but what was legal.
checked before charges, were filed against me? Why was I asked to provide records for my Instead, you (when I say "you" I am referring to Christopher S. Baarlaer) made numerous
prescription history when you had access at the time? And most importantly-why, five months attempts ro trick me into admitting to things I did not do, to allow you access to private Tnedical
later, is your meritless and fraudulent charge still pending? records you did not have a legal need for, and colluded with against me with the very person you
I have attuchsd two documents which are emails I received several months ago that I have were tasked to objectively investigate. Shame on you. I mean that You are a disgrace. Consider
previously brought to your annntion, The first ifi the F'ebruary 27, 2025 email I received from this my official notice ofiiitent to file a complaint in the United States District Court Southern
Google informing me that The Clemiont County Sheriff's Department had issued a search District of Ohio Western Division for violation of 42 U. S.C. § 1983. That will not be the only
warrant nvo days earlier on February 25 to "toss" my very private and very personal google count I'm afraid,but for brevity's sake I'll keep moving. Rest assiiredthough, you will be named
profile (Ref#25000950). Next is the March 3, 2025 notice t received from Facebook (Case No. personally in that Complaint.
9333878) infoiming me that it too was being "tossed. " Now I'm guessing that you lot down at
the Proseciitor's Office do not need to go through the Sheriff's Office for a warrant. One might

No evidenceofrefusal, or ofreceivingandunderstandingthe consequenceson Form 2255 if

I had refused pursuant to R. C. § 4511. 191 (B) and State v. Whitt, 201 2-0hio-3934;
No evidence paraphernalia was used in drug consiimption, or that it was directly linked to
me or legal standing for constructive possession pursuant to Statev. Codeluppi, 139 Ohio
As you shoiiid be aware, pursuant to the Ohio Rule of Professional Conduct 3, 8 (Special St. 3d 165 (2014);
Responsibilitiesof ^ Prosecutor), a prosecutor is obligated to ensure suflficient evidence exists to Issuance of illegal geofence warrants targeting Meta and Alphabet platforms in violation of
support a criminal charge before initiating prosecution. The Prosecutor's office would have been Brandenburg, 146 Ohio App. 3d 221 (2001), and HAnou u Gale;, 462 U. S. 213 (1983);
obiigatedto checkthe OAR-RSdatabaseprior to pursuingcharges.I will need all recordsofthose Post hoc robabie cause attempted five years after the investigation and while case is
references by yourself. Deputy Ross, the whole squad, ya dig? Rule 3. 8 goes on to stipulate a administratively closed in violarion of Fronfav. Delaware, 4'3S U. S. 154(1978);
prosecutor is additionally required to disclose to the defense any evidence that may tend to Probable cause affidavits relying on uncorroborated hearsay/lacking direct observation for
negate the guilt of the accused or mitigate the alleged ofFense. Nonetheless, it has been 45 days issuanceofwarrantin violation ofAafev. Carbon, 102 OhioApp,3d 585 (1995)
since I first requested your office provide documentation for which no response has been Malicious prosecution and retaliatory surveillance occurred via invalidly issued warrants
forthcoming. This correspondence serves as a formal notice of my intent of litigation and the in violation of 42 U. S. C. § 1983;
demandyour officepresen'e evidencerelated to the above-referencedcriminal matterandrelated Abuseofinvestigatory authority in violation of civil rights pursuant to 42 U. S. C. § 1983;
actions end investigations undertaken by yo'ir office, law enforcement agents, or affiliated Retaliatory actions under color of law taken ttwith malicious purpose, in bad faith, and in a
agencies. This notice is provided in accordance with your obiigaiioni;under Ohio common law, wanton or reckless manner" in violation ofR.C. § 2744. 03(A)(6)(b).
Ohio Rules of Civil Procedure, and federal preservation standards (see Silvestri v. General Violations of Ohio's anli-harassment laws, R. C. §2917. 21,
Motors Corp., 271 F. 3d 583 (4th dr. 2001), lind Zubulate v. UBS Warburs. 220 F. R. D. 212 Violation of federal witr. css tampering statutes, 18 U. S. C. § 1512.
(S. D. N. Y. 2003)). You are hereby placed on notice that you must take immediate steps to Violation of speedy trial rights guaranteed by R. C. g 2945. 71.
preserve all materials that may be relevant to the anticipated litigation involving uniawfu! Failure to reinstate or document is without a citation or ATN number, in violation of
prosecution, deprivation of civil rights under 42 U. S.C. § 1983, retaliatory surveiilance, and Cnm. R. 3 and R. C. §2935. 17.
violations of due process in connection with the events giving rise lo Case no. 2020TRC03599, The totality of'condiict demonolrates further due process violations under color of law, as
Stateof Ohiov. Ber. D. Le\vis andall events which followed. This wouldnot preclude your legal set forth mAlbrishl v. Oliver, 510 U. S. 266 (1994);
requiremenl for thedisclosutcs alreadyfiled with your office29 daysago and 3 daysago. And further misconduct pending investigation and discovery
With that in mind, Investigator Baarlaer, to apprise you of my intent and provide you
sufficient notice unlike tlie concealment of pending litigation like cur man Deputy Ross; in "Due process is violated where a defendant is not afforded timely notice and an opportunity to be
addition to. several Clemiont County Deputies submitting sworn affidavits supporting an invalid heard on outstanding criminal charges" see State v, McDaniei, 44 Ohio App. 3d 27 (1988); see
Administrative License Suspension (ALS) under R. C. 4511. 191-contrary to controlling also Ohio Crim.R. 4(E)(1), which requires the prompt execution and retuni of arrest warrants,
precedent in State v, Wkitt, 2012-which was itself based on the fabricated allegation I haci Despite this requirement, no such prompt execution occun-ed^even though Deputy Ross had
refused to submit to a chemical test in March 2024. Not to be outdone, upon infonnation and knowledge of my mother's address within Clemiont County at the time. Additionally, Detective
belief, I allege following misconduct has either occurred-or is at present occurring-in Statev. Ross's misconduct in State v, Lewis parallels misconduct seen in the Chad Doerman case, in
Lewis (2020TKC03599): la wit: which a Clennont County judge suppressed evidence due to procedural violations. In both
The warrant block still preventing renewal ot'niy California driver's license and issuance instances. Detective Ross disregarded clearly established legal protections, acted with reckless
of MMC credentials m violation of Fed. R. Crim. P. 4 and the Fourth Amendment; disregard for constitutional safeguards, and persisted in misconduct even after being placed on
The prolonged imposition of said warrant block preventing said license lacking any formal notice. This pattern of behaviornot only reflects individual misconduct but also supports
judicial oversight contrary to State v. Brooke, 113 Ohio St. 3^ 199 (2007). the basis for a Monell claim or a supervisory liability theory under42 U. S.C. § 1983 againstthe
Absence of valid service for OVT and absence of a citation for OVI in violation of Crim.R. Cleimont County Sheriff's Office. It further implies complicity-or at minimum, deliberate
3 and 4, and the Fourth and Fourteenth Amendments; indifference-on the part of the Clement County Prosecutor's Office and yourself specifically.
Total failure to nieet the 'substantial compliance' standard required for an OVI arrest as Finally, given the total absence of meaningful prosecutorial oversight to protect victims of
outlined in 5'fafe v. Brandenburg, 146 Ohio App. 3ii 221 (2001); malicious prosecutions in Clennont County, I have started \vriting an article to be shopped upon
The ALS remaining despite a verified prescription presented 4 months prior for the completion with media outlets and civil rights organizations highlighting the egregious
charged controlled substance contruy to R. C, 2925. 11(B)(l)(d) and Brady/Glglio. misconduct I've suffered as a proximate cause of your actions and the others to be named an the
Form 2255 unsigned, not rimestamped, nor is it referenced in violation of R. C. g 4511. 192. forthcoming verified Complaint. This is should deter any ftirther retaliation against my friendi
EXHIBIT Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 57 of 80 PAGEID #: 712
PROXIMITY
[TV \ yi2^5, 10:53AM Omail. FollowUp

Grnail Chef Damlan Lewla <chafdaml»t

and family who continue to reside ill Clennont County, Ohio. Should anyone at either The
Sheriff's Department or Prosecutor's Oflfice wish to further harass and menace my 65 year-oid Follow Up
disabled mother as Deputy Ross did in Febmary, I ask that you contact me instead at (.254)
13 orchefdamianlewis@gmail. coni ChefDamlqn Lewis <chBfdamlanlBwis@9rT,,itl. com> Thu. F8b13. 2025at1:17AM
To: "Christophsr S. Saariaer" <csbaarla6r@dBrmontcoLjntychio. gov>
As always, I remain open to communication. You have no reason to question my integnty Cc-. LeslieChristy <losilechristy81@yahou.com>. ChefCamian Lewis cdamoncallfomia@gmail.com>
as I have done all I said 1 would and did not misrepresent or conceal any material facts. I
Mr Baarlacr.
welcome the opportiuiity to speak withyou; today if you'd be so kind as to email meback with a
preferred time, and of coiirse at your convenience. I have cleared my schedule and have made Following up on yesterday's discussion; s:n I mistaken that for a violnUon of ORC 4511, 191, Ohio's Implied Consent law, to have
myself available for the remainder of the day to discuss things further. Upon retainer of Counsel, occurred an individuQl must first have been an-ested following probable cause for OV17 From what I understsncf of Ohio's Revisod
your office will be infornied as such. Codeandwhetis stated on websilesfor OVIottomeys, one must first be arrested 'or any ImpliedConsentTestjng to bB mandatory,
which is then violated by refusa!. As nenUoned, my iicenss was suspended for violating Ohio's Implied Consent law despitf never
being errested for OVI at anytime, anywhere, in my fife. Could you he!p me mako sense of this contradiction? Or beaer still, explain
Respectfully Submitted, whatit is f'm miaunderstanding7 Apologies farthe frivGlous questions. however, I am still playing catch-jp with fhis matter, f iwauld
like to say, respectfully, this invesUgatian seems to be working backwards from s presumption of guitt lackins pro&able cause rather
s/Bert Par than havins began with e presumption of innocenco and the burden for p-^vinp Ruilt residing solely upon the Stete. Thank you in
BERT DAMIANLEWIS advance for youf response.
chefdamianlewis@gmail. com
Kind Regards,

fm>il/uAU?ilK8Sge2i(WcA.viBW=ptAscin;h=»ll&pc'TTmif<lam'E-f:ia"921908'*03445.
1122&iimpl=mse-f;1i2392)90&403445322

'minute clinic
From:
Subject:
Chef Uamlan Lewii
Responso
Authorizationfor Release of Protected Health Information (PHI)
Daf; FBbruery24, 3025at1' Bert Damian Lewis
To: Chrtstophcr S. Baarlaoi lyohio.gov Patient Name (Records to bo released):

Thank you for your prompt reply, I appreciate that you are now looking into this matter and I look
Sirggt 6725YuccaStreetApt 14B
forwardto a speedyresolution, I do haveone quickquestion; when I initiallycontacted yourofficeto City, State, ZIP code: Los Angeles. CA 90028
inquire about why my license was suspended despite never being arrested for OV1, why was the same
deputynamed ifi thatemsi) allowedto contact myfriendsandfamily, makingfalsestatements about Date of Birth: 01/27/1980
me and trying to coerce faise statements from them? That seems to fit within the standards of
retaliation which are as foilows; 1. Records to be disciosed:

A. ) Engagement in a protected activity (emaiting your office) Complete medical history x Lab reports Immunization history Xttemized billing
B. ) Deputy knowledge (Why after 5 years did he contact my family?)
C.) AdverseAction (harassment of my friends and family)
2, Sensitive Records to be disclosed (must select at least one option);
D.) Protectedactivitywascontributingfactof(whyelse would he be doingthis?) Sexually Transmitted Diseases/Infections iab reports x Behavioral Health
Also, late on February19(12:26am on February20) I provided DeputyRossexoneratingevidence Request excludes sensitive records
that would preclude charges for possession of a controlled substance from being fifed. This was a
3. Oatesof Service to be disclosed: :: ALL Dates of Sen/ice
prescription in my nameiorthe substancewhichwas apparentlyfoundin the vehicle, whichagain
was rr. y vehicle. Was that evidence passed along? Thank you in advance. X Specific Dates of Senflce: Jan 01, 2015 -Jan 01, 2019
4. My Records may be disclosed to the following person or company:
Person or Company Name: ChrlstophBr Baarlaer
F/ailing Address/Email Address: 76S.RiversideDrive2ndFloorBatavia,Ohio45103
5. i authorize MinuteClinic to disclose my Records for the purpose of;

fit the request of Patient or Patient's Personal Representati\'e [no specffic purpose)
Varification of all buprenorph'ne preacriptiont preacribed and fiNBd by Cr. Darren
X Specific Purpose: Neai wth Achiev Madical Group^n TorraiicB, Olifornr
6. This Authorization will expire 6 months from the date I sign it as shown beiow unless I
enter a different expiration date here-. _Mar/ 01 / 2025
7. By signing below. I undffrstand and agree that:
. My Records may indudssRnsitiwinformation relatedlo the treatment ofmental health conditions, alcohol or
substance abuse, sexually transmiUed diseases like HIV/AIDSor othercominunicable and non-Rommunicable
diseases, and geneticmarkerinfomiation.
* I may rewkethis authorizationatanytime by writingto MinLjteClinicat the address,emailor fax numberlisted at
the bottom ofthis farm, excepttcthsextentthat MnuteCI'nichas taken action in rcfianceon this authorization,
. I understand that signinQthis a.rthorization is wluntary andthai this>authorizatcnwill not affect my abilityto
obtain treatment, paymentfor treatment orenrollment or eligibilityfarbenefits far MinuteClinic. A photocopy or
facsimile ofttiis signedAuthorization is asvalid as tho originalaid will be accopteci.
. Whoeser gets my PHI may share it with others. T^at means federal or state privacy laws may no longer protect
my PHI.
. I imderstand that I haw the right to receiw a copy ofthis Authonzaton,
February 25, 2025
Signature of PatienVPersonal Representative* Date

Ifsigned by someone othei than the patient, pleese pnnt yourfull name, explain your authority to act on behalf
of this patient, andprovide us papGmork eviaencingthis authority(e. g. Powerof Attorneyor Guardianship form^'

MinutoCllnic
One CVSDrive
Wooniockat. RI 02895
Fax: 401 -652-9093 Email: M CRBCoirislgCVSHealth. com
EXHIBIT Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 58 of 80 PAGEID #: 713
PROXIMITY ^
From: Ba«r)<i»r, Chrl«tapnTS. wbanriaor^clermon From: Chat Oam'un Lnwla.chofoamianiswisagmail.uom
SubjBi-t: RE:Re]ea;i& SubJBct: Re: Reloase
Data: FBb^try25,.'?e25at^^9Ay D«f: t:ebai8rv25, 2025at11:49AM
To: ChofDamiai. LewiswofdamianlawiaaomaJli To: ChriatopherS. Baarlaef csliaarlaerSci enmontcountyohb. gDv

Will you please change the date range Jan 01, 2015-Jan 01, 2019 to Jan 01, 2015-April, With all due respect, I will not do anything of the sort. There is no relation to my
30, 2020 as wo will nsed to encompass the date of the alleged offenso. medical history of being prescribed Buprenorphine to the false charges for OVI
now pending against me. Similar to how no relation exists for the administrative
suspension of my license with my medical history of being prescribed
Buprenorphine. In the course of four years I was prescribed nearly 4, 500 8mg
Christopher Baarlaer tablets legally by my primary care physician. A reasonable person could easily
Investigator
Mark J. Tekulve, Clermont County Prosecutor assume one or two would be lost in the vehicle I drove during that timeframe
76 S. Riverside Drive 2"1 Floor Balavia, Ohio 45103 while I was living in California. I have, in good faith, provided you with
P: 513-732-7595 I C: 513-535-7150 irrefutable, authenticated evidence that the charge for illegal possession of a
csbaarSaer®c!er7nontGoynlyoii!'a. gQV
controlled substance Is a false charge, as was the administrative license
suspension.

Section 4511. 191 Implied consent

Any person who operates a vehicle, streetcar, or trackless trolley upon a
highwayor any public or private property used by the publicfor vehiculartravel
or parking withinthis state or who is in physical control of a vehicle, streetcar,
or trackless trolley shall b.e deemed to have given consent to a chemical test or
tests of the person's whole blood, blood serum or plasma, breath, or urine to
determine the alcohol, drug of abuse, controlled substance, metabolite of a
From: Chef Damian Lewis <chefdamianlewis@gmail. com> controlled substance, or combination content of the person's whoie blood,
Sent: Tuesday, Fsbruar/ 25, 2025 9:15 AM blood sorum or plasma, breath, or urins if arrested for a violation of division
To: Baariaer, Christopher S. <csbaarlaer@clBrmontcountyohio.gov>
Subject: Re: Release (A)^L(B) of section 4511. 19 of the Revised Code. section 4511. 194 of the
Revised Code or a substantially equivalent municipal ordinance, or a
Is this suitable to get the records from the location at 1747 N Cahuenga Blvd municipal OVI ordinance.
Hollywood, CA900287 If not Im happyto fill out whicheveris necessary.
(b) ... A !awenforcement officerwho acts pursuant to this division to ensure that
£^£tiaiiaaB.aL1Z47.NcrftP?huenga a person submits to a chemical test of the person's whole blood or blood serum
Bniltovni HDllTood CASOC.28 I CVS or plasma is immune from criminal and civil liability bassd upon a claim for
Pharmacy.
assault and battery or any other claim for the acts, unless the officer so acted
wlthjna. liclous purpose. In bad faith. or In a wanton or reckless manner.

(B).(l)_Upon receipt of th« sworn report of a law enforcement officer wba

assstedjLperson for a violation of division (A) or (B) of section 4511.19 of
On Feb 25, 2025, at 8:35AM, Baarlaer, Christopher S, the Revised Code. section 4511.194 of the Revised Code or a
<csbaarlaer®clermontcountyohio.qov> wrote: Ually-eauivalent municipal ordinance, or a municinal OVI
ordinance that ivas completed and sent to the registrar of motor vehicles.
Thank You,
and a court pursuant to section 4511.192 of th° Revised Code in regard to a
I have; aaachedWalgreens Release Form. We would ask for Prescription person who refused to take the designated chemical test, the registrar sha!l
issuance, History (submission/filled/pickup) inEtructicns for use and medical enter into the registrar's records the fact that the person's driver's or
warninos from Marnh 9. 2018 friatfi issuRdl throuah Anrit 30. 2020 friate aftsr

L^

commercial anver's license or permii or nonresiaeni operaiing privilege was From: roquost. -ecofds-norBpfy@800Bls. oom
Subject: fHme Sensitive) Notification from Goofl'e
suspended by the arresting officer under this division and that section and the QatB: F8bruarvS7, 2025at6:49PM
To: bdlcalich6(®gfnafl.com
period of the suspension, as determined under this section. The suspension
shall be subject to appeal as provided in section 4511. 197 of the Revised
Code.

You are clearly attempting lo conjure up probable cause five years after
issuance of a warrant which attested probable cause existed. The prescription I
had for Buprenorphine in no way has any relationship to the charge for OVI. It
is proof that yet another of the charges Clermont County has filed against me
was done so in violation of my Constitutional Right to Due Process. You are
welcome to sit on this evidence and not amend the charge. However, this has
nowmovedvery clearlywithinthe scope of MaliciousProsecutionunderColor Qsa; boii:aiicnef®g--'iE
of Law.

Gcusie has >Bcei'/wJ Itsisi yr..->u«ai> ko'n y l. if-i. Cnforcei

u your U. ^ogie Acuoun;.

fUiIfLifi . infi

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Jurisdiction Ohio (State)

Agency Clemont County 3herifTa Office (OH)
Referencd number 25000950

Date of iasuanco February25, 2025

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EXHIBIT^:]
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 59 of 80 PAGEID #: 714
PROXIMITY r Omul-rC uw N3338781

Gmai! Damon Lewis <bdlcallchBf@gmall. com>

Clennont County Sheriff's Office

4470 State Route 222
[Case #9333878] Batavil, OH45103
i message
Email; sheriflF@clemiontcountyohio. gov
Records <record3@rcco. -ds. facebcok. com> Man. Mar 3. 2025 at 3:44 PM
Reply-To-Rocords<records+EGWUJ3V4TMBQAE5CVH6HED7EMF32G@rBCords. fac8book. com> Clennont County Prosecutor's Office
To: bdlcalichef@gmail. com 76 S. Riverside Drive
Batavia, OH45103
Email; prosecutor@clermontoountyohio. gov

Subject: Public Records Request Case No, 2020TRC03599/Deputy Ross Communications

Hello,
June8, 2025
We have received legal process from law enforcement seeking information about your
To Whom It May Concern:
Facebook account. If we do not receive a copy of documentation that you have filed in court Pursuant to the Ohio Public Records Act, R. C. § 149. 43, 1 hereby request access to and copies
challenging this legal process within ten (10) days, we will respond to the requesting agency of all public records in the possession of your offices relating to the investigation, arrest, and
with information about the requested Facebook account. We may need to respond to this prosecution of Bert Damian Lev/is, specifically concerning Case No. 2020TP^C03599, and/or
legal request within less thanten (10) days it weharea reasonablebeliefthat we arelegally administrative actions linked to the March 14, 2020 incident.
required to do so. Please respond to this message with a copy of any documents you file with
Please include, but do not limit the scope to:
the court. If you v/ould like additional information about the legal process, please let us know
1. All incident and supplemental reports autliored by Deputies P.oss, Rudd, Curless, or
as soon as possible.
any otherCCSOpersonnel;
Thank you, 2. All affidavits of probable cause, warrant applications, and communications with the
Law Enforcement Response Team Clermont County Prosecutor;
3. Bodycam footage, dashcam, or audio recordings from March 14, 2020, and from any
follow-up investigation;
NOTICE: This email (inciuding any attachments) may contain information that is private, 4. Internal communications, emails, or memoranda between CCSO and dennont County
confidential, or protected by attorney-client or other privilege. Unless you are the intended Prosecutor's Office discussing Bert Damian Lewis;
recipient, you may not use, copy, or retransmit the emaii or its contents. 5. Records or notes dociimenting interactions with third parties (family. friends,
employers) in 2025 related to this case;
For information please visit: https'./A'vww.facebook.com/safety/groups/isw/guideiines/ 6. Any documents or correspondence related to the re-opening or continuation of
and hnp:/./he!p. instagram,oom/-i!94561060557017/ prosecution after February 2025;
7. Copies of any public complaints, memos, or use-of-force reports associated with
Deputy Michael Ross.
Please provide electronic copies (PDF, MP4, etc. ) where possible. If any part of this request is
denied, pSease ident-ify the specific exemption relied iipon and written explanation. Please assure
complianceto thisrequeston or beforeJune26, 2025(14 businessdays).Thaiikyou in advance,
Sincerely,
s/BertDamian Lewis
BERT DAMIANLEWIS
chefdami anlewis@gmail. com
(954)357-2813

httpf:/'n1 »iI .goog'c jcom/mli I/u ;579c4<:836&Yiew=pt&iUT<:h=t)l&ix;rmthi(t=thnid-f:]825 7176970139454&<impl=nug. f:182i60i71769r70139454

onymouily):__ __UfcKI UAMIAn LtWIS _____. ___"_""_, __

From: Ch»f Damlan L»w(» che'c.amianlswlaaB^all-
Jut)]»ct: Docuir. Btil Rt. qucflta
Addreaa uf Re(;UMter (required for iTiail)
3af: JunBlO, 20Z5at2:15AM
To; Baarlaer, Cnrialophor S. csbaarlaeiOclerfTwr jntyohto.flov, prosecut0f®cli
City FT. LAUDERDALE Stau;: R. .. ZipCade: 33316
The Documente requested oi>this form are as follows^
1, All incidentand supplemental reports authored by Deputies Ross, Rudd, Curiess, or any other CCSOpersonnel;
2. All affidavitsof probablecause(Origlnais and eny supplements}, Affidautt(s) signed by Deputy Ross or any ottier Em»l Addnu of Raiualcr (aptioni);; CHEFDAMI»NLEWIS@GMAILCOM
offlcemarrant appllcatkins, and communlcaUonsw!th the C!ermont County Prosecutor; All charging instruments,
Criminal complaints. Indictments, If any, any othermendmGnts or dismissals
3. Bodycam footage, dashcam, or audto recortlngs from March 14. 2020, and from any follow-up investigation
showingtime and tocaHonof recordings
4, Internal communlcaUons, emails, or memoranda between CCSOand Clef-montCounty Pmsecutor's
discussing Bert Damian Lewis;
5. Records or notes documenting interadjons with third parties (family, Mends, employers) In 2025 related to this
6. Any documents or correspondence related to e reopening pr ccntlnuatjon of proseaiyon after_Febnjar/ 2025;
7. Copies of any public comptai"t5, memos, or use-of-force reports associated wlfri Deputy Michael Ross.
B.A^logs," accessrecords,o-reportsevidencingtheuseofUARRSbyyourself.DeputyRoss,oranyagentif
Ctemiont County in cannecdon with my case, Stateof Ohiov. Lewis, Bert D. (2020 TR C 03599}, whetheran^-one at
anytime accessed»ie OhioAutomated Rx Reporting System under my name, whoaccessedit, when, and under
what auLhority.
9, Executed,signedcopyofBMVPom2255andtheglevmndate/tlmeofsewlceandnameofseeing
officer/deputy.
10. A!l'Fi£'kJ sobriety / c'lemlcal test records 'nduding, but not limited to, Test logs (BAC, urine, blood), Refuszi
forms. CertificaUon and callbratton logs for any testlny devices used.
11. Any Brady/Glgllo materia!in posession of the aei-montCounty Prosecutor.
12. Al!'Internal memos or con-espondencere93rdin9whetherto pursue trie drug possession chargesagainstBert
Damlan Lewisand any discussionsof the status of my presa-lptiQn,
13, Any and all communlcaUons (emails, memos, me-etlng notes, phone logs. etc. ) between Prosecutor Mark
Tekulve,"InvestigatorChnsBaartaer,DeputyMichaelRoss,anyotherDeputieswith eaennpntCountySheriff's
Office at reference my case (State of Ohio v. Lewis, Bert D. (2020 TR C 03599)), OARRS, The Ohio 8MV, any
prescriptionsrelatedto me, anywarrantssentconcerningrreormyproperty,anygeofencewarrants;
14. Recordsoc notes documenting interactionswiththird parties (family, friends,
employers] in 2025 related to this case;
IS. 'An'y documents or corresponder. ce reloted to the re-openinfj or continuation of prusecutton after .tanuarY 2025;
16. Coplfcs of any public complaints, memos, or use^f-foroe reports assodated with Deputy Oetective Michael Ross.
17. Any and ail communteations between Deputy Detective Michael Ross and any witmesses or family members
rontarted during t;ie proceeding State of Ohio v, Lewis, Bert 0, (2D20 TK C 03599)
Pleaseprovdeelectroiiiccopies(PDF,MM,etc.) wherepossible.Ifanypartofthisrequestisdenied,pleaseidentify
thespeciftcexemptionreliedu?onandwnttenexptanaUon,PlSEiseasiurecomplianceto isrequestonof-before
June 30. 2&25 fl4 business days). Thank you in advance.

W.'/W.Cl^H^SNTTilOSECUTOll.ORG
REQUESTTORPUBLICRECORDS

D«. ofp^. u:._JUNE_'°^°»_

Name of Requester (only if vol'uitanly pro V]ded;"iqi be under a paeudonym or made
 Case:
EXHIBIT|» I 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 60 of 80 PAGEID #: 715
pROxiMiryi

Fnm: ChBfDamitinL«t;l«cftB((?amiafiifwit®flmaJI, com ^

Subi'nct: NOVICEOF irfl-ENTTO INITIATE LITIGATION
Data; Juno11, 2025at10:34AM ~ ....
To: Baanaer, ChriatophefS. csbaariaor®ciermontROuntyohto.
BCv, pi csecyforlSclermontcountychlo.
uov,
prooofflccSclarmontcountyohio.flov

NOTICE OF INTENT TO INITIATE LITIGATION

MARKJ. TEKULVE Pursuant to 42 U. S. C. § 1983 and Reiat^d Statutes
CLERMONTCOUNTSPROSECUTINGATTORNEY
7G ^. RIVERSIDEDRIVE,2NOFLOOR June 11, 2025
BATAVIA, OH104S103
PHONE:(513) 732-7313 Investigator Christopher S. Baariasr
FAX:(513)73?-75g2 Clerrnont Cou. nty Prosecutof's Offics
WW\V. Ct£aMONTPROS£CUTO)l.ORG
76 S. Rivereide Drive
Batavia. OH 45103
REQUESTFORPUBLICRECORDS csbyariayrii^FT'e^^o^ntywiio^sv

DateofRequest: JUNE10,2025 Investigator Baariaer,

When i initially contacted Prosecutor Tekutve in February2025, 1 did SD in good farth-believing that
NameofRequester(onIyif voluntarily provided; requests canbe undera pseudonymor made both he and his staff, yourself included, were upholding the constitutionai obligations required of your
anor. ymously): BERT DAMIAN LEWIS office. However, the record now reflects a pattern of omissions, misconduct, and procedural violations
that undermine that assumption,
Address of Requester (required for mail)
Your office had access to the Ohio /^jtomated Rx Reporting System (OARRS) at the time of charging
me in April 2020 and again in 2025 Despite that, you pursued an unlawful drug possession charge
without verifying that I had a valid buprenorphine prescription-documentation that I later submitted.
City; FT. LAUDERDALE State:. JL_ Zip Code: 33316
Under Ohio Rules of Professional Conduct 3,8, prosecutors must refrain from charging individuals in
the absence of probable cause. Once exculpatory evidence under R,C, 2925. 11(B)(1)(d) was provided,
TelephoneNumberofRequester(optional): 954-357-2813 your office was further obligated to corfect the record and dismiss the charge. You did not.
Accordingly, I request all documentation of OARRS access concerning my records by you. Deputy
EmailAddressofRequester(optional):__ CHEFDAMIANLEWIS@GMAIL.COM Ross, or anyone under your direction.

Description of records requested: I have also attached legal process notices from Google (Ref No. 25000950) and Meta (Case No.
9333878) confirming that search warrants for my digital records were issued by the Clemont County
Sheriff's Office in March 2025-after you stated Deputy Ross was no longer involved in my matter.
These warrants raise serious Fourth Amendment concerns, particularly given that the associated cass
appears to have been previously administrativefyclosed. Please provide afl probable cause affidavits
and authorizations for these searches.

I am also submitting evidence filed in U.S. District Court (Southern District of Florida) that contains
materially false statements by Deputy Michael Ross, which appear to have been repeated or
supported by Deputies Curtiss and Rudd. These statements were used to fabricate probable cause in
Apr;] 2020 and later cited by TSA, LLC-ownedby Sanford Sqtulio li-in a retaliatory civil suit filed
againstme in October 2024. That suit followsd my whistiebiowercomplaint to OSHAfiled on February
Desiredformat(paper,Blectronlc,etc. ): __."____, _ ELECTRONIC P, 2024. under 46 U. S.C. § 2114 (Seaman's Protection Act), and refied on the CIermont County
warrant to undermine my standing,
Method of delivery (in person or via email, standard mail, electronic media, etc. ):
When I raised these facts with your office, rather than taking corrective action, you attempted to
extract admissions fron me, solicited access to private medical info.nnation without legal justification,
__. _EMAIL __ and delayed adjudication of this matter unlawfully. This conduct violales both state and federal law.

This latter constitutes fonnai notice of my intent to initiate Ifc'gal action in the United States District
Court for the Southern Oistrict of Ohio, Wsstern Division, under 42 U.£.C. § 1983 and related civil
{..arm Created October ^, 202J rights statutes. You will be named personally. Complaints with the Ohio Bar and the U. S. Oepanment
of Justice are also forthcoming.

2020TRC03599, and any communications, warrants, subpoenas, or investigative activity originating

fromyourofficeor affiliatedagencies. SpoliationofevidencewJlfbe pursued to the fullest extent of hivestigator Christopher S, Baarlasr
the law (see Silvestnv. GM, Zubu!akev. UBS Warbufy}. Clermont County Prosecutor's Office
76 S, Riverside Drive
Anticipated claims include, but are not limited to:
Batavia, OH45I03
1. Falsified ALSaffidavit and lack of probable cause (R. C, 4511. 191; State v. Whitt) csbaarl aer@cl ennontcountyohio. go v
2. Improper BMV warrant block affecting MMC credential
3. Enforcement of a warrant without timeiy judicial oversight (State v. Brooks)
4. Absence of signed Form 2255 or refusal advisement (R. C. 4511. 191{B)) June 1!. 2025
5. Procedural dafects in OVt citation/semce (Crim. R. 3 & 4}
6. Failureto meet Brandenburg compliance for OVI arrest Subject; Supplemental demand to Public Records Request in Case N3. 2020TR. C03599 State v
7. Drug charge unsupported despite valid prescription (R. C. 2925, 11(B](1)(d)) Le^is; Notice of Intent to Initiate Litigation pursuant to 42 U. S, Code g 1983; et cetera
8. Invalid or unexecuted ALS paperwork (R, C. 4511. 192}
9. No evidence of use or possession of paraphernalia(State v. Codeluppi)
10. Overbroad and unconstitutional geofence warrant Investigator Baariaer,
Post hoc probable cause attempts (Frante v. Oe/awa/R)
12. Heareay-based affidavits lacking first-hand observation {State v. Carlson] When I first wrote Prosecutor Tekulve in Febiuary 2025, I was under the impression that
13. Malicious prosecution and unlawful sur^/E-illance (42 U. S. C. § 1983) both the Prosecutor and his staff-including yourself-1'ad swom to support the Constitution of
14. Abuseof authority under color of law (42 U. S. C. § 1983)
15. Retaliation violating R.C. 2744.03(A)(6){b) the United States and the Constitution of the State of Ohio; and to further faithfully discharge the
16, Harassment and m8iiacing(R.C. 2917. 21, 2S03.211-.22} duties of the Prosecutor of Clermont County, Ohio, to the best of your abilities. However, that
17. Witness retaliation and obstruction (18 U.S.C. §§ 1513, 1514)
18. Speedy trial violations under Ohio law (R. C. 2945. 71; that clearly has not been tl-iu case...
relations of due processunder Albright v. Oliver
20. Additional statutory and constitutional claims to be identified in discovery Indeed, at the time in question (Febmary 2025), you willfully concealed from me that you
had access to the Ohio Automated Rx Reporting System (OARRS), a tool used to track the
Moreover, DeputyRoss'sprocedural conductin my casemirrors hisactions in Statev. ChadDoerman, dispensingand personal,furnishingof controlled substances.Additionally, you further concealed
where evidence was suppressed due to constitutional violations. Your continued endorsement of
Pass's invoivementdespite this reco'xl creates exposurefci r Monell and supan/isory liability claims. that the Clermont County Pioseciitor's Office has had access to this system tor some time now,
mcliiding when charges were filed against me five years prior in Apnl 2020. Therefore, I now
Because Clermont County lacks a msaningful civilian oversight body for law enforcement misconduct,
I will also be circulatingthis maHerto nationaipnBSSoutlets andcivil rightsorganizations.A draft ask: Is this the concept of justice which inspired you to pursue a career in law enforcement?
summary of the case is being prepared for distribution,
Your actions-and the similar conduct of multiple Depi. ty SherifiTs mnning amok among
if yourofficewishesto discussresofutionor mitigation, I am availabletcday. Otherwise, formal sen/ice
will follow. Attachod are my preliminary damages calcuiations. the Corridors of Justice in Clennont County, Ohio-directly contradicts U. S. Supreme Court

Sincerety, rulings ill both Braily v. Maryland, 373 U. S. S3 (1963). andGiglio-. UnitedStales,405 U. S. 150
(1972) prohibiting suppression of exculpatory and/or impeachment evidence. The Clermonl
s/Bert Damlan Lev/is
BERT DAMIAN LEWIS County Prosecutor's Office has long known-well beyond just the prior five months- it lacked
(954)357-281-1
£fe^^nl5im^js^;ml. sim legal standing to pursue and maintain charges for possession of a controlled substance or OVI
against me. And yet your oflTice acted cohesively, as a unit, to perpeiuate injustice against a
citizen ratfierthan simply uphold the oath of ofFice to which all of you were sworn. Now we both
know that I don't need to tell you this. And yet, here I am telling you this.
Please considerthis an official supplemental request for all logs, accessrecords, or rqions
evidencing the use of OARRS by you. Deputy Detective Michael Ross, or any such agents acting
on behalf of Clemiont County in conneclion with Case no. 2020TRC03599, State of Ohio v. Ben
D. Lewis. In the event that no such record does exist, I now ask: why don't they? Why wasn't

Page 1 of 6
 Case:
EXHIBIT^) 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 61 of 80 PAGEID #: 716
PROXIMITY I

this information cross-checked before charges were filed against me? Why was I asked to thousands of dollars). I'm not sure if you were aware of those proceedings, but that is a showing of
provide records for my prescription history when you had access at the time? And most acnial damages proximate to the actions you are now helping to perpetuate. I additionally included
importantly-why, five months laier, are yourmeritless and fraufiulentchargesstill pending? some of my filings in that proceeding as well as the aforementioned OSHA case, now removed to
r have attached two documents which were emails I received several months ago that I District Court parsuant to 46 CFR § 1986's "kick-out" provision (where I'd "exhausted my
previously brought to your attention. The first is a February 27, 2025 email I received from administi-ative remedies" and a statutory right to seek reliefbyjury in District Court arose after 210
Googls informing me The Clermont County Sheriff's Department had issued a search warraiit daystolled withouta final decisionor showingofbadfaith); whichbringsmeto my nextpoint;
two days prior on February 25, 2025 to "toss" my very private and very personal google profile There's not much need to rehash what occurred here; although, it seems iike every time I
(Ref No. 25000950). Next is the March 3, 2025 notice I received from Facebook (Case No. go looking into Deputy R. OS;)' or your conduct since February, I uncover some new, underhanded
9333878) informing me thai it too was being "tossed. " I'm guessing that you folks dow-n at the gamesmanship has taken place well outside the bounds of appropriate or decent conduct. I stay
Prosecutor's Office do not need to go through the Sheriff's Department for a warrant. One would fairly busy with the two District Court cases (as one does), and therefore, had no interest in
then logically deduceit was your colleague. Deputy Detective Micheal Ross, who somehowgot a pursuing yet another Federal action against yet another group of morally bankrupt actors; so I
warrant issuedto rifle through my private affairs on a "hunch";though for what actual reason I'm instead came to Public Servant Prosecutor Tekuive and explained my rights, your lack of
at a toss and a bit befuddled. From what I can tell, the meritless OVI case you've now played a standing, and assumed/hoped you would then do not only what was right, but what was legal
tremendous part in perpetuating has been administrati'/ely closed for some time. In fact, to my required. Instead, you ("you" referring to Christopher S. Baarlaer) made several attempts to trick
knowledge, there is no reason the Ciermont County Sheriff'sDepartmentwould or shouldhave an me into admitting to doing things I did not do; allowing you to access my private medical
open investigation againstme, unless one wasopened for an improperpurpose, andfor whichyou records you had no legal need for, and further colluded against me with the very person you were
would have been requiredto disclose long ago. Is it legal for a Deputyto request warrants strictly tasked to objectively investigate for retaliating against me. Shame on you. I mean that. That is
for a retaliatory purpose? I do not believe that dog's gonna hunt; and so, I'll keep it moving... conduct unbecoming. And as such, this is my official notice of my intent to file a complaint in
In addition to those emails, you'll find several'seemingly tinrelated court documents are the United States District Court Southern District of Ohio Western Division for wanton

attached; specifically from the United States District Court for the Southern District of Florida. violations of 42 U. S. C. g 1983, etcetera. You wil\ be named personally in that Complaint.
The first set of documents you will no doubt find familiar and warm; !ike a comfortable pair of As you should be aware, the Ohio Rules of Professional Conduct 3. 8 (Special
woolen sockson the first chilly eveningof autumn (just kiddingr moved awayfrom that amateur- Responsibilities of a Prosecutor) mandates a prosecutor giu?t ensure sufficient evidence exists to
hour weather 25 years ago). Jokes aside, you'll find copies of the falsified statements and iupport a criminal charge befpre initiating any such prosecution, As such, the Clermont County
manufactured evidence conjured up by Deputy Michael Ross; and for which he and his pals Prosecutor's Office would have been obligated to cross-reference with the OARRS database prior
dreanied up against me in April 2020 when they pulled probable cause out of thin air to file a to filing charges against me for possession of a controlled substance. You would have been
inalicious prosecution captioned 2020TRC03599 State v. Lewis just for fun. Well, that same obligated to cross reference the same infomiation to maintain standing in light of my having
malicious prosecution would later be weaponized in another malicious prosecution in retaliation for provided a valid prescription, which is a complete defense. I will need ail records of any instances
my reporting safety vioi'-itions of a Yacht owner to the U. S. Coast Guard, and later to OSHA, of yoii, Deputy Ross, or anyone else, accessing my private medical records via the OARRS
pursuaiitto 46 LTSC § 2114The Seamaii's Protection Act in December 2023 while a chef on a yacht database. Rule 3. 8 goes on to say That a prosecutor is further required tu disclose any evidence that
in Turks &, Caicos Dunng the subsequsnt Department of I^bor Office of Administrative Law might tend to negate the giiilt of the accused or mitigate the alleged offense. Nonetheless, it has
Judges proceeding 2024-SPA-00005,opposing counsel secretly filed a fraudulent lawsuit against been 29 days since I requested your office provide me any such documentation, and as response or
rne usinga peijuredstateinsntalone for standingto do so. Theirperjured statement was legitimized production has been forthcoming despite officially serving your office the request via USPS. Please
by your Deputies'perjured statements, grantingthem standingto file suit (possibly for hundredsof producethesedocumentsassoonaspossible, or insteadprovidethe legal standingfor refusal.

Page 2 of 6

Moreover, this correspondence is to function as a formal notice of my intent to initiate 10. Attempt at post hoc /n-obable cause five years after investigation and while case is
administratively closed in violation of Franks v. Delaware, 438 U. S. 154 (1978);
litigation against yourself and others to be named, under color of law, and farther serves as a
11. Probable cause affidavits reliant upon uncorroborated heareay/lacking direct observation for
demand that your office preser/e all evidence related to the above-referenced criminal matter
warrantinviolationofSatev. Cari.mn, 102OhioApp.3d 585(1995);
Slate v. Lewis Case No. 2020TRC03599, and all related actions and investigations undertaken by
12. Malicious prosecution and retaliatory surveillance in violation of 42 U. S. C. § 1983;
your office, law enforcement agents, or affiliatedagencies.This notice is provided in accordance 13, Abuse ofmvestigatoiyauthoritym\4olatioTi of civil rights puisuantSo42U, S.C. § 1983;
with your obligations under Ohio conimcn law, Ohio Rules of Civil Procedure, and federal 14. Retaliatory actions under color of law taken "with malicious puipose, in bad fa'th, and
preservation standards(see Sih'estriv. General Motors Corp., 271 F. 3d 583 (4th Cir. 2001), and in a wanton or reckless manner" in violation of R. C. § 2744. 03(A)(6)(b);
Zubulake v UBS Warbwg, 220 F.R.D. 212 (S. D.N.Y. 2003)). You are further placed on notice 15. Violations of Ohio's anti-harassment laws, R. C. §2917.21;

that you must take immediate steps to preserve all materials that may be relevant to anticipated 16. Violations of Ohio's anti-menacing laws, R. C. § § 2903.21]-. 22
17. Violations of federal witness tampering statutes, 18 U. S. C. § 1514;
litigation involving malicious prosecution, deprivation of civil rights under 42 U. S. C. § 1983,
18. Violations of federal witness retaliation statutes, 18 U. S. C. 51514;
retaliatory surve'llance, and violation of due process in connection with Case No.
19. Violation of spesdy trial rights guaranteed by R. C. § 2945. 71;
2020TRC03599, State of Ohio v. Bert D. Lewis. This does not preclude your obligation of any
20. The totality of conduct dsmonstrates further due process vioiations under color of
pending reqi iests made v/itli your office 29 days ago and again, 3 days ago.
law occurred as set fonh in ^/Mgfi(v. O/ivw, 510 U. S. 266 (1994);
The intent to file suit involves, but is no+ limited to, Deputy Ross' et ai submission of 21. Any othermisconductpendingfurther inveiirigarionanddiscovery,
sworn statemenls to elii-it an invalid Adminislre. tive License Suspension (ALS) imder R, C,
"Due process is violated where a defendant is not afforded timely notice and an
4511. 191 (and contrary to controlling precedent in Stale v. Whitt, 2012), which was itself based opportimity lo be heard on outstanding criminal chargffs"Statev, McDaniel,44 OhioApp. 3d 27
upon false testimony that I had refused an implied consent chemical test on March 14, 2020; (1988); see also Ohio Crim.R. 4(E)(1). Due Process requires the prompt execution and return of
upon further information and belief, r now aver that tlie following misconduct either has arrest warrants. Despite this requirement, no such prompt execution occurred-despite Deputy
occurred-or is presently still occurring-in Statev. Lewis (2030TRC03599); to wit: Ross' knowledge of my mother's artdress at the time (evidenced by his February harassment of
1. A warrant block preventing renewal of my California driver's license and issuance of her which amounted to stalking). Additionally, Detective Ross's misconduct in Stale v. Lewis
MMC crudei.tials in violation of Fed. R. Crim. u 4 anri the Fourth Amendment; parallels misconduct seen before and after in the Chad Doerman case, in which a Clermont
2. Prolonged imposition of said warrant block preventing said licenses lacking judicial County judge suppressed evidence due to Deputy Ross' procedural misconduct. In both
ovmight coiltrary to Statev. Bmote, 113 Ohio St.3d 199 (2007);
instances, Detective Ross disregarded clearly established iegal protections, acted with reckless
3. No evidence of 2255, refusal or being informed of the consequences of refusal,
pursumt » R. C. § 4511. 191(B)and Slatev. Whitt,2012-0hio-3934; disregard for constitutional safeguards, and persisted in misconduct even after being placed on
4. Absence of valid sen/ice for OVT and absence of citation for OVI in violation of formal notice. This pattern of behavior not only reflects a complete disregard for individual civil
Crim.R-, 3 and 4, and tile Fourth and Fourteenth Amendments;
rights, but also supports the basis for a h/fonell claim or a supervisory liability theory under 42
5. Failure to meet the 'substantia: compliance' standard required for OVI arrest as
U. S. C. § 1983 against the Clermont County SherifTs Office. It further implies complicity-or at
outlined in aau v. Branrfenfturg. 146 OhioApp. 3d 221 (2001);
minimum, deliberate indifference-on the part of the Clennont County Prosecutor's Office and
6. AT^S and OVT chargeii rpmaining despite verified prescription presented 4 monthi
prior contrary to R. C. 292S. Il(B)(I)(d) and Itrady/Gislm: yourself, Investigator Christopher Baarlaer, specifically.
7. Form 2255 not signed, dmestaniped, or rcferericod m violation ofR.C. § 4511. 192; Finally, given the total lack of any meaningful protection for the victims of malicious
8. No evidence paraphernalia was used for drug consumprian, or linked for constructive prosecution, credible police misconduct mveEtigative bodi5S or civilian law enforcement
possessionpursumtto Slatev. Codeluppi, 139 OhioSt.3d 165(2014); oversight in Clennont County, I am including an article I am writing for submission to media
9. Issuance of illegal geofence warrants in violation of Brandenburg, 146 Ohio App. 3d outlets and civil rights organizations {Propublica, The Intercept. Reuters, Channel 9, et al)
221 (2001), »nd/;Bni;UK uola, 4«2 U. S. 213 (1983);

Page 4 of 6
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EXHIBIT <k:|
PROXIMITY!

MAL]CIQUS.PRQSECUTiON_AND_RETAL!AT[ONUNDER COLOR OF LAW

highlighting the egregious misconduct F've suffered as a proximate cause of your actions and Mr. Lewis has discovered that the Clermont County Proseci. Kor's Office has,
for severs! months, engaged with him under faise pretenses. This engagemerU
those both named and to be named :n the forthcoming verified Complaint. This is to deter any
was not conducted in pursui: of justicsi but as a caiculatsd strategy to onabie
furtherretaliation againstmy fiiends andfamily still residingin Clennont County. Deputy Michael Ross to execute a retaliatory ano' maiicipus prosecution intended
As before, I remain open to any productive, good faith conununicarions to resolve this to shieid his own career from collapse. Every action taken by the Prosecutor's
matter cordially andamicably, andpointout that you have110reasonto questionmy integrity as I Office has demonstrated bad faith, delay, and ccnceaim&rt, designed to obstruct
justice and cover up ciesr patterns of misconduct by Deputy Ross. \-1r. Lewis now
have done all I.said I would and at no time have I misrqiresented my intentions, nor concealed
understands that the Prosecutor's Office has eithGr filed or is prepanng to fiie an
any material facts. I welcome the opportunity to speak with you personally and I have cleared indictment against him alleging six counts of aggravateci vehicuiar assauit These
my schedule for the remainder of today in the event you would like TO discuss things further; charges arc* based on an 0V! allegation from March 2020. The basis for these
correct anything I potentially misunderstand or correct Emy facts I possibly got wrong. charges-Deputy boss's atiegeci observations st the scene-is unsupported by
Additionally,upon my retainingofCounsel, your officewilt be notified immediatelyassuch. credibia evidence; contradicted by the phys'cai and msdical record, and f-actuaiiy
p'-eciuded by exonerating information in the Prosecutor's possession for several
months. Ths Prosecutor's continued maintenance of thess charges violates
Rcspcctfillly Submit! cd, obligations under Brady v. f^ryiand. 373 U. S. 83 (1963), and Ohio Crim. R. 16,
MARCH Z020 PERJURED STATEMENTSAND MANUFACTURED EVIDENCE
s/Bcrt Damim Lewis Aii evidence compi'ed by DepLity Ross afxer March 14, 2020, must be
BERT DAMIANLEmS
suppressed as fruit of the poisonous tree. The vehicie search at the scene of the
chefdamianlewis@gmail, com 2020 coJli'sion was warrantless and unsupported by pfobable cause. Under the
Fourth Amendment and Ohio Const. Art. ;, §14, the search and subsequent seizure
of s prescription medication (Buprenorphine) was uniawfui. The drug was lawfully
prescr'bed and known not to cause the symptoms Ross rolied upon. Slurred
speech, contusion, and drowsiness-the on!y symptoms cited-are instead classic
signs of traumatic brain injury, 35 corroborated by AMA iirerature and ihe Mayo
Clinic, The conditions at the time of the crssh-coSd temperatures. sieet, poor
visibjii:y, and a dangorousiy curved rosdwsy-were tar more iikeiy causes of the
coiiision than aliegea' intoxication. No chemical test was refused. No field sobriety
test was performed. The eontroiied subsrance charge came 11 days after the OVt
citauon. 1'he search was retroactiveiy justified fhrough fnsnufactured stal'ement-s,
Pass's conduct constitutes a patterri of retaliatory targeting and fabricstion,
His motive is clear: l^e was neariy rernoved from duty after procedura! misconduct
in the high-profiie Chad Doerman case in 2023, In that case, Ross misresd
Mirsinda rights and ignored a suspect's invocation of counsel. Similariy, in 2020,
ROKS mishgndled a DVCPO enforcement and was irnpiicated in chain-of-custody
failures- invoiving sensiiive evidence. Any credible new misconduct siieystion
couid terminate hss career and undermi ne his entire case history.
DEPUTY ROSS CRIMIMALACTS UNDER COLOR OF LAW.
!n Pebrusry 205, 5, Mr. Lewis msde rnu!tip!e forma! repurt-s to the Prosecutor's
Office outlin'ng miscondud;, inci'Liding perjured lesii'mony by Ross Jesding to a
wrongful ALS suspens'on. Desp;te a'isurances from Proyecutorial invesrigator
Chris Bsa.schei-that Ross would r'iO Sunger be invofved, Hoss obtained retaliatory
geofef^Ct3 and social media '/vai'rants days Sater. Mr, lewis has been denied copies
of Ihese warrants and their supponing ciffidsvits, in v'oistioi'1 of his due process

rights. MALICIOUS PBOSECUTION AND RETALIATION UNDER COLOR OF LAW

Ross's retaiidtory campaiQn intensi^ed immediateiy after these con-iplaints, Mr. Lewis has discovered that the Clermont County Prosecutor's Office has,
Within days of his February 13 report, Mr. L.£!W!Sand nis family were; stalked and for sesverai months, engaged with him under faise pretensey. This engagement
harassed in a" app&r^'it sttempi: to tntirnidst. e witnesses. This was followed by was not conducted ;n pursuit of jusUce but as s calculsted strategy to enabie
iilegal surveiiiance and suppressed excu!palcry evidence. 8y February 24, Mr. Deputy Michael Ross Lo execute a retaiiatory and malicious pro'iecution intended
Lewis had ma6e three fo;'mal reports against Ros-s. On Februsry ?ft, a cjeofence to shieid his own career from coiiapse. &very action taken by [he Prosecutor's
warrant was executed. SIK days iater, his i-acebook account wys accessed. The O'fice has demonstratsd bad faith, deiay, and conceaimer'i, designed to obstrf. ict
prescription thst wouid ht ive invaiidaied the March 2Q'20 possession chafye was justice and cover up csyar pal'terf';s of misee.) nduct by Ueputy Ross. Mr, Lewis now
disclosed to the prosecution tive days before these w3?'rants were issued, making understands that the Prosscutor's OFncehas either filed or is preparing to fiie an
their issusnce !ega!!yand ethicaiiy indefepsible. indictment against him aiieging si>; counts of agorsvated vehici.. isr ssssuit, These
On February 19, Mr, i. ewis Fi!ed ten separate reports of Deputy Rossr charges are based on an OVi aliegalion from March 2020. The baiiis for these
retaliation, inciudJfg a plea co the Clermunt County Commissioners. All responses' charyes-Deputy Ross's aiieged observations at the scene-is unsupported by
were delayed or dismissive, designed to ai!ow Hoss time to fabricate new credible evidence, contradicted by the physica! and rnedica! record, and faciuafly
aiiegalions, Ro?s, sided by prosecutonal misconduct, misfepresented this i!tegai!y preciuded by exonerating information in the Prosecutor's possession fof severai
obtained evkience to a grand jury whiie sitppressing known exonerating facts. months. The Proseculor's cuntinued mainl'enance of Ihese charges violal'es
CONCI-USION obiigat-ions under Bf-ady v. Maryiand, 373 U. S. S3 (1963J, and Ohio Crim. H. 16,
This memorandum hcks case citations only due to the urgency and gravity of MARCH 2020 PERJURED STATEMENTS AND_MANU_FACTURED EVIDENCE
the unconstitutional retsiistion underway. Mr. Lewis does not aiiege that every Aii evidence compPed by Deputy Moss a^ter March 14, 2020, must be
actor is compiicit. Sheriff Chris Stranon, to Mr. Lewis' knowledge, responded suppressed as fruit of the poisonous tree. The vehicie search at the scene of the
timely and appeared to act in good Faith, providing reQuested documents and 2020 coliision was warrantless and unsupported by probable cause. Under the
demonytratsng transparency. Should these felony charges move forward, it is Foi;rth Amendment and Ohio Const'. Art. I, §14, the seBrch and subsequent seizure
evidpnt they were pursued in secret, in bad faith, and in retaiiation for of s prescription medication (Buprenorphine) wss unlawfu'. The drug was lawfutly
constitutionally protected conduct. !f charges have not yet been fiiea, this pi -escrsbed and known not to cause the symptuins Ross reiied upon. Siurred

memorandum strongiy urges the Prosecutor's Office to abandon its campaign speech, contusion, and drowsineRs-the only symptoms cited-are instead classic
against Mr. Lewisand instead initiate approprial'e proceBdsngs against Deputy Signs of traumatic brain injury, as corroborated by AMA iiterature ar'. d the i^ayo
Ross. Ms-. Lewis demBnds the imfneoiate dismissal of al! basefess charges, fuli C'inic. The conditions st the time of the crash-coid temperatures, sleet, poor
disciosure of alt investigatory materials, and accountabiiity for those who enabied visibility, and a dangerousiy curved roadway-were far more iikeiy causes of the
these unlawful acts. This document ano supporting exhibits ars being submitted to c;oi!;sion than aiieged intoxication. No chemical test was refused. No field sobriety
oversight bodies, media outiets, and federal civi! rights authyritieH, A!) misconauci test was pecformed. The cortroiled substance chafge came 11 days after ths OVi
will bo pursued to the fu!iest extent of ths !aw with or without ?he withheld citation. The search was retroactivsiy justified through msnufactured statements.
records. Rnss's conduct constitutes a pnttorn of rstaliatory targeting and fabi'ication.
t-iis motive is ciesr: he was nearly removed h'om duty after procedurai misconduct
Respectfuiiy submitted, in the high-protiie Chad Duerman case in 2023. in thax case, Ross misread
June 20, 2025 M'rand? rights and iQnor&ci a suspect's invocation of counsel. SSmilgriy, in 2020,
Bert Damian Lewis Ross mjsh?ndled a OVCPO enforcement and was implicated in chain-of-custody
faiiures invo!ving sensitive evidence. Any credible new misconduct £iilegat!on
couid term'nate his career and undermine his entire case history,
DEPUTY BOSS CRIMINAL ACTS UNDER COLOR OF LAW
in February 2025, Mi', Lewis made muitipie formol reports to the Prosecutor's
Office outlining misconduct, including perjured S&stimcny by Ross leading TO a
wrongful ALS susponsion. pfispite assurances fron'i Prosecutoriai investigator
Chris Ssascher that ^oss wou!d no ionger be invofved, Ross obtained retaiiatory
geofence and socia! media warrants days later. Mr. Lewis has been d&n'ed copies
of these warrants and their supporting affidavits, in vioiation of his due process
EXHIBIT1:|
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 63 of 80 PAGEID #: 718
PROXIMITY)

rights.
Ross's retaiiatyry campaitjn inlensified immediately after these compiaints.
Within days o? his Pebruai'y 13 report, Mr. Lewis and his family were sxaiked and
harassed in en apparent anempt to iniiinidate witn&ys&s. This was foiiowed bv
itiegai surveiilance and suppro'is&d exculpatory evicience. By February 24, Mr.
Lewis had made three formal reports against Ross, On February 25, a geofence
warrant was executed. Six days later, his Facobook account was accessed. The
pcescripTion thai would have invalidaied the March 2020 possession charge was
disposed to the prosecution five days before these warrants were! issued, making
their issuance legaiiy enci BthicaSiy indefensible.
On February 19, Mr. Lewis filed ten separate reports of Deputy Ross'
reta'iation, including a pica to the CS&rmont County Commissioners. All responses
were; deiayed or dismissivG, designed to sliow 9oss tiine to fabricate new
aiieggtions. Ross, aided by prosecutorial misconduct, misreprcssented this il'egaliy
obtained evidence to a grsncf jury whiie suppressing known exonerating facts.
coi-iCLU.siay
This memorandum tacks case citstiorss only due to the urgency and gravity of
the unconstitutionai retaliation underway. Mr. Lewis does not allege that every
actor is comptfcst. Sheriff Chris Stratton, to M.", Lswis' knowiedge, responded
timely and appeared to act in good faith, providing requested documents and
demonstrating transparency. Should these felony charges move forward, st is
evident they were pursued in secret, in bad faith, and in retaiiation for
constitutionuiiy protected conduce, if charges have not yet been filed, this
memorandum strongly urges the Prosecutor's Office to abendon its campc iign

aga'nst ?^r. Lewis and instead initiate appropriate proceedings againstOeputy

Ross. Mr. Lewis demands the immediate' dismisssl of aii baseless charges, full
disc'osure of a!! jnve-stigatory materials, and accountab(!ity for those who enabied
these uniawfu! acts. This docurrtent and supporting exhibits aro baing submitted to
oversight bodies, media Dutiets, and federal civil rights authorities, Ai! misconduct
wil! be pursuffd to the fi.iiiest exten; uf the !aw w'th or wnhout the withheid
records.

Respectfully yubmsi'ted,
June 20, 2025
Bert Dairiian Lswis
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 64 of 80 PAGEID #: 719
EXHIBIT 0\
From: als@dps. ohio. gov <f
Subject: RE: [EXTERNAL]BMV 2255
Date: June30, 2025at1:28PM
To; chefdamianlewis@gmail. com

Greetings,

Thank you for writing to the Ohio BMV concerning your driving record. Please see the
attached BMV 2255 document. This is the only document the BMV has received regarding
this suspension.

Thank you,
Ohio BMV

From: DPS BMV Records <bmvrecords@dps.ohio.gov>

Sent: Monday, June 30, 2025 11:10 AM
To: DPS ALS <als@dps.ohio.gov>
Subject: FW: [EXTERNAL]BMV 2255
We received the below. If possible, please assist the customer.

Jeff Payne
Chief, BMV Record Services
Ohio Department of Public Safety
Phone #-(614)752-7631

From: Chef Damian Lewis<chefdamianlewis@gmail.com>

Sent: Monday, June 30, 2025 7:45 AM
To: DPS OntineRecordsRequest <onlinerecordsrequest@dps. ohio. gov>
Subject: [EXTERNAL]BMV 2255
llea&e send the jco of the BMV 2255 form used to enact the administrative
Vl^iy related documents that are associated. Thank
yo uch!

Bert D Lewis
3898 Vineyard Green Drive
01/27/1980

3 B
a
^
.

OHIO DEPARTMENT OF PUBLIC SAFETY

BUREAU OF MOTOR VEHICLES

RFPriRT OF I AW FNFORCEMENT OFFICER ADMINISTRATIVE LICENSE SUSPENSION /

EXHIBIT 61
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 65 of 80 PAGEID #: 720

NOTICE OF POSSIBLE CDL DISQUALIFICATION / IMMOBILIZATION / FORFEITURE

A. NAME DRWER LICENSE # CLASS STATE.
\- t^^l& e^os-^o^'-^l^o 0{^
lE^BYOfF^ER)
^^. OHIO Q
;TO^&eiN oE tah- i ^Jr I z'40^^.
COUNPi'OFVIOI
nos^e?
-4-DiGIT COURT CODE
JD ^W^^^T-
;EO^,fE
F VIQL^TJQt
TIMEOF VI
_a_AM[%M m^^ 'ft'&cl^Z.f^S-0AO^ZO^Z,
DAT TIME OF TE;
DAM^BPM mwK^^w^^<dn pEP^ a.
VEHICLE DATE OF BIRTH STREETADDRESS
°^EK^ ZIP CODE
crrr STATE

VEHICLE STOF^D AT 1STREET ADDRg§^)| CITY

<A
B. Officer to Completfi for All OVI I Physical Control Arrests: Trequested the driver, byreading advice on Iheback, to submit to a chemical test (s) loralcohol
Circlearresttype: OVI PhysicalControl and/ orforthepresenceofanycontrollBdsubslanceormelabolile. Mypeyonablegroundsfor
The driver
OVI/ Phyij^lCcnly!anTBgl\e^ . Ipsyprs:_ . _^ l_» /VVVi
Refused to submitto lest (s).
:uu\ykJL<J ^"fr^^AVSYI+-? , (;vuyK^L&
.
D Subject lestcd forcontrolled substance ormelabolite. Cirefe test type forwhidi controlled subslance
Submined to lesl (s). 0;_% alcohol lesl result ormetaboliteresultswerereported:Urine,WholeStood.BloodSerum.01BloodPlasma.
D Circletesttype forwhjdiresullswerereported: Q Spedlycontroiledsubstanceand/ or metabolileresults:.
WholaBlood, Breath, Urins, BlnodSenim,or BloodPlasma D Subject(Mtedpositivetorprohibitedlevelofmarihuanametabolite_ Specifyamount)
a WasplacedunderanAdminislrativeLicenseSuspension(R.C.4511. 191) andwasunder the inlluence offllcoho] and/ or a dnjg ol sbusa.
D License was seized d Alcohol,conbclledsubstanceormetaboClstearesultreceivedon. _. Subject served
D Offender was provided a copy of this farm al the lime of arrest. with notice of Administralive License Suspension on.
ieasonable
;easonable means oDicer usedjoens
usedjo ensure atfender submitted lo a chemical test were:
tf^^^^^r
C. Officerto CompleteApplicableVehicleSancUons: Q Vehideseized under R. C, 45W. 41 only (DUSorwrongful entruslment ofa motor vehide) Ifso, Do
not mall this form to the BMV
D Ucense plale(s) seized
a VehiciaseizedunderR.C.4511.195(OVI) D Vehide subject lo immobilization
D Vehidesubjecttoforfeiture
D. Officerto Complett ifCWeiidtris thetiolderof a commercialdriver D Prohibited Alcohol Content with OVI charge
licenseorwasOperaU'nga ComiTwn-.lal Vehicle: D Commerdalvehideperdefinilion(R.C,4506.01(E))
D Readandshowedadvi'cetooffender(R.C.4506. 17) D 24-houroul-of-serviceorder
D Refused to submil to leslfs) D COL to be disqualified
D Submined to IBSI(S) I^ %alcnhollesl result D COLseized
)no)~WholeBlood.Breath,Urine,BloodSenjm,orBtoodPlasma D Hazardousmaterial _ ^
'
^_
a ftohibitedAlcohorCon7enlw«Jhout-OVI'chgrg8-- D Operated a co-i^rdalvehide under iheinHuenceof a conlrolled substance
E. The adviceon fhebackofthis formwasreadto meandI havereceived a
copy of this form.
rr? ;EFUSEDTOSIGN
jRE
F. CompietaBelowOnly<oranOV11PhysicalControlARREST: __....... . "".,....", .^ ....,. __. _ ^____^. _. _... _ ., _-. ^.,-
We,"UnBund6rsigned, 'certify-lhaYtheadviceprescribedbyItieGeneralAssembly(underR.C.4511. 191andR.C.4511. 192),wasshowntoISepereonunderarrestandreadtohimorherin
thepresenceofIherestingofficerandone^Uy person
OHO I I \^\D 10
ARRESTING' N.C. I.C,#
2^=_
u^^^w^^- "^ ^^ STATE ZIP CODE
WTJ?
r?
OR ARREST INVOLVING COMMERCIAI. VEHICLE. AFFIDAVFT OF ARRESTING OFFICER:
COMPLETE BELOW ONLY ON QV1ARREST,
STATE OF OHIO, COU^mf OF . S3 8ffi^
FcerifyFarosted'lhe'person, havinghadi3Tsona6Tegroundslobelievehepereon^ras operatinga vehideupona highway,oruponpublicorprivatePr°Pertyusfldbyu'_ePubl":l" veh":I,lla'
perec
travelor'parking m"therState of Ohio' undef the influan'ce of alcoholand / drugs olabus, in physical cgnlml ol vehiclB while under the inllusncs of alcohol and ' c"6'uss, ol^ysa. "ilh a
or a Of

pro'h^tedmnSntraiion ofalcoholinthewholeblood,bloodseium, btocdplasma,breatti.orurine.1 advisedthepersonin theprescribedmannerofIhemnssquences o^are^ora tesL

Thepersoneitherrefusedthelest,orwasunderarreslforOVIandlookDietestandhada prohibilsdccnceniraUonolalcoholinthewholeblood bloodserum bloodplasma breath orunne
I'alTas'desCTbed aEove). (n the case of commeraal vehide (if applicable) I had reasonable grounds to belfeva the pB
a dnving commBraal motor vahide in Iha Stata of Ohio in
reon was a

violationofsection1506.15of e OhioRevisedCode.Theinlormalloncontainadonthis(omiistrueto[hebeslofmyknowlsdgaandbelief.
1^-^£)^T_ "PEACE OFFICER SIGNATURE
ARKE; G OFFICERSIGNATURE

Sworn to before me this. ~]~^_ day of. MMCjh 20_^)_

NOTARYPUBLICSSIGNATURE
City of
.

OEPUlYCLERffiF CO'URT'SSIGNATURE
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 66 of 80 PAGEID #: 721
EXHIBIT 0|
From: Chef Damian Lewis chefdamianlewis@gmail.com
Subject: Deputy Ross' BMV2255 (March 19, 2020)
Date: July 2, 2025 at 3:41 PM
To: cstratton@clermontcountyohio. gov
Cc: ethics@ethics.ohio.gov, sunshine@ohioago.gov

July 2, 2025

Dear Sheriff Stratton,

By now you are aware that my numerous records requests ultimately resulted in a Grand Jury
indictment being brought against me on July 12, 2025. I have filed appropriate motions with the
Clermont County Court accordingly despite the Prosecutor's Office withholding and concealing
notice, aiming instead for a "surprise arrest" meant to prejudice my ability to mount a reasonable
defense. Sir, I contend that this is not justice in any sense of the word.

Despite this, indeed because of this, I instead found ways to acquire some of the exculpatory
documents I requested from The Clermont County Prosecutor and The Clermont County Sheriff's
Office. Amongst these is a copy of Detective Ross' BMV 2255 form and sworn affidavit attached to it.
Much pushback resulted from that request, including six charges for aggravated vehicular assault five
and a half years after-the-fact. Upon a good faith request being made to the Ohio Bureau of Motor
Vehicles, I now have in my possession the sworn affidavit of Detective Michael J. Ross attesting,
under penalty of perjury, that he arrested me for OVI on March 14, 2020 when he irrefutable did not.

Ohio Revised Code Section 2921 . 11 Perjury

(A) No person, in any official proceeding, shall knowingly make a false statement under oath or
affirmation, or knowingly swear or affirm the truth of a false statement previously made, when either
statement is material.
(F) Whoever violates this section is guilty of perjury, a felony of the third degree.

Would it not have been a conflict of interest for Deputy Ross to conduct the investigation which led to
these felony counts against me after I unknowingly implicated him for felony perjury?

Additionally, is it not in any way suspicious the indictment came the day following my June 11 Notice
of Intent to Litigate, sent to The Prosecutor's Office?

I have attached the BMV 2255 filed on March 19, 2020 by Deputy Ross is deficient in the following
ways:

1. Incorrect Drivers License for identification (I've been a California resident since 2013 and was
licensed in that state on March 14-19, 2020)
2. Incomplete social security number
3. Incorrect Address (726 Rue Center Ct. does not exist)
4. The vehicle was a 2014 Honda, not 2013
5. Event in question was March 14, 2020. The BMV 2255 was submitted to the BMV five days
later on March 19, 2020, three days outside the 48 hour mandate to submit.
6. No details are given concerning the alleged refusal on March 14, 2020. However, Deputy Rudd
swore that Deputy Ross told him the vehicle operator was in and out of consciousness during
the reading of the BMV 2255, which would preclude an ability to refuse.
7. No description for the "reasonable means" is given except "BMV2255"
8. Deputy Ross swore that "I arrested the person" while he did not arrest me.
9. Deputy Ross swore that "I advised the person in the prescribed manner of the consequences
of a refusal or a test. " This is also untrue
10. Deputy Ross swore that "The person either refused the test or was under arrest for OVI and
took the test and had a prohibited concentration of alcohol in the whole blood, blood serum,
blood plasma, breath, or urine. " Neither is true
11. Deputy Ross and an RN swore that "We, the undersigned, certify that the advice prescribed by
the General Assembly (under R. C. 4511. 191 and R. C. 4511. 192), was shown to the person
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 67 of 80 PAGEID #: 722
EXHIBIT B

under arrest and read to him or her in the presence of the arresting officer and one other
person. " I was never arrested.
12. Wherethe BMV 2255 form states that "COMPLETEBELOWONLYON OVIARREST,
PHYSICALCONTROLARRESTOR ARREST INVOLVINGCOMERCIALVEHICLE.AFFIDAVIT
OF ARRESTING OFFICER: STATE OF OHIO, COUNTY OF CLERMONT" Deputy Ross signed
his name under oath that I had been arrested. I was never arrested.
13. If I was not arrested, I could not have refused the implied consent test, which is another series
of false statements under oath.
14. There is no peace officer witness signature.
15. This was never reported to California, where I resided and where I was licensed.

Considering Deputy Ross played a substantial role in gathering the evidence for the 2020 charges and
the revived 2025 charges, how exactly do I know which statements he made in that investigation are
true and which are also perjured.

I am not a Police Officer, nor a lawyer. Yet I've listed 15 major discrepancies on this sworn statement
alone. For instance, a professional has not yet looked at any of the evidence i've submitted in my
defense. Further, the invalid information shows Deputy Ross identified me as the driver strictly through
the vehicle registration itself. Does ownership of a vehicle automatically imply guilt for an OVI charge
in the state of Ohio?

I wrote to you 13 days ago and respectfully requested an investigation into Deputy Ross' Investigation
of me following my implication of his misconduct be undertaken. I am providing to you right now
irrefutable evidence that Deputy Ross committed perjury against me; exculpatory evidence that was
concealed from me for months. I have stated for the record numerous times you were the sole law
enforcement professional with integrity in the entire scenario. Am I mistaken that an arrest must occur
prior to a refusal and subsequent ALS suspension under Ohio law? Please, sincerely, explain what am
I misunderstanding so I'm not falsely accusing someone of a crime.

I have additionally attached the June 11 Notice of Intent, Boss crash report from March 14, 2020 that
states the vehicle was driving at the speed limit in adverse weather conditions when the wreck
occurred (no reckless driving is mentioned), My BMV abstract showing the ALS was placed despite no
arrest, My California driving record showing no contact was made with them, My record showingthe
warrant for OVI replete of probable causes cause and the possession charge for which a valid
prescription was given to Ross and Prosecutors in February, and one of the actual prescriptions.

What do you make of this and where does the complaint I made on June 20, 2025 against Deputy
Ross stand?

Thank you for your time,

Bert Damian Lewis

Achieve Medical Group

23000 Cranshaw Blvd.
Torrance, CA 90505
Phone: 310-326-1147 Fax: 310-326-1148

Patient; Bart D Lewis DOB-1/27/1980 Phone;415.741-4048

Addrass: NA Sex: Male MRN: 58137183
NA. CA 90505

I^BUPRENORPHINE 8 MGTABLETSL
SIC:Take1 tabletsublingualy3 times a day
DispenseAmt:90(Nfneiy)Tatote!(30 DaysSupply) Brand Necessary: No
Reflll: 1
]25-49 ] 50.74 175-100 D 101-150 D 151 S Over
Quantfty: | a 1-24
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 68 of 80 PAGEID #: 723

Bert Damian Lewis

769 Rue Center Ct. #i
Cincinnati, Ohio 45245
chefdamianlewis@gmail. com
754-200-1970

Date: July 4, 2025

To Whom It May Concern,
I am formally notifying the Ohio Attorney General's Office and all law
enforcement oversight divisions under its authority that Deputy Michael J. Ross, of the
Clermont County Sheriffs Office, knowingly submitted a falsified BMV 2255 form for an
incident dated March 14, 2020. On this affidavit, Ross falsely swore under penalty of
perjury that I was lawfully arrested for OVI that day-when in fact, no arrest ever
occurred, no chemical or field sobriety test was administered or refused, I was never
served or booked, and therefore no contemporaneous ALS is lawful.
The BMV 2255 is materially invalid on multiple grounds; it was signed and filed
five days after the date Ross falsely claimed he effected an arrest, violating Ohio Revised
Code 45ii. i9i's mandatory contemporaneous arrest and sendee requirements within 48
hours. There is no credible witness or record of any Advice to Motorist being read to the
vehicle operator, and, as stated, no arrest occurred to trigger the implied consent in the
first place. The same form and false statements were used to justify an ALS and then
revived five and a half years later to anchor felony charges based entirely on the same
perjured narrative by Deputy Ross in retaliation for reporting Ross for misconduct.
After I discovered this fraud, I reported it in February 2025 and provided
exculpatory proof-including a verified prescription for buprenorphine, which under
Ohio law (ORC 2925. ii(B)(i)(d)) precludes the alleged possession charge-and formally
requested at that time that the Prosecutor drop the charges. Instead, the Prosecutor
concealed critical exculpatory evidence for five months, and then filed six new felony
charges against me the day after I served a Notice of Intent to Litigate for Civil Rights
violations proximate to the fraudulent ALS, Ross' warrantless search, and the ongoing
suppression of Brady material.
These new felony charges were based solely on an investigation Ross initiated
after I implicated him for his fraudulent ALS placement. Afterwards, I was targeted with
retaliatory digital warrants and surveillance immediately following that report. The
Prosecutor's Office has refused to produce any warrant affidavits in response to public
records and discovery requests, and likewise refuses to produce a valid arrest report,
ALS notice, test logs, chain-of-custody documentation, or any evidence showing I was
the vehicle operator. After filing fraudulent felony charges on June 12, they have
Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 69 of 80 PAGEID #: 724

continued to withhold all information for these charges despite my having made an
appearance in the proceeding and formally requesting legal representation. The felonies
in question are predicated on the same false testimony Deputy Ross gave under oath
when he swore I had been arrested for OVI on March 14, 2020-when I unequivocally
was not, nor have I ever been arrested for OVI at any time in my life.
All these facts are stated in my formal Brady notices, discovery demands, and
public records requests, including multiple unanswered emails sent to Prosecutor Mark
Tekulve, Assistant Prosecutor Brian Shrive, Investigator Chris Baarlaer, and the entire
Clermont County Prosecutor's Office. Together, these show a deliberate pattern of
concealment, false probable cause, misuse of a fabricated BMV 2255, warrantless
searches unsupported by law, and prolonged bad-faith delay intended to deny my due
process rights and coerce a plea where no valid probable cause even exists for their
meritless, malicious prosecution.
Accordingly, I request that the Attorney General's Office, OPOTC, BCI, and all
relevant oversight agencies fully investigate Deputy Ross's misconduct, the Prosecutor's
cover-up, the retaliation under color of law, and the knowing misuse of a falsified BMV
2255 to place and maintain an invalid ALS on my driving record. I further request that
all internal squad logs, warrant applications, dispatch records, OARRS access logs, and
any digital surveillance records be preserved immediately and disclosed for federal civil
rights review and further litigation. This matter implicates due process violations under
the Fourth, Fifth, and Fourteenth Amendments, retaliation for protected speech under
the First Amendment, and an ongoing Brady/Giglio breach for implicating Deputy Ross
in perjurious misconduct. I further request written confirmation that the BMV 2255 will
be struck as false, the fraudulent ALS removed, and that every state actor involved will
be held fully accountable for perjury, malicious prosecution, civil rights violations, and
retaliation. I thank you in advance for your service, and wish you all a safe
Independence Day weekend.

Sincerely,

s/Bert D. Lewis
BERT DAMIANLEWIS
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 70 of 80 PAGEID #: 725

Section 2921. 11 | Perjury.

Ohio Revised Code / Title 29 Crimes-Procedure /
Chapter 2921 Offenses Against Justice and Public Administration
Effective: January 1, 1974 Latest Legislation: House Bill 511 - 109th General Assembly

(A) No person, in any official proceeding, shall knowingly make a false statement under oath
or affirmation, or knowingly swear or affirm the truth of a false statement previously made,
when either statement is material.

(B) A falsification is material, regardless of its admissibility in evidence, if it can affect the
course or outcome of the proceeding. It is no defense to a charge under this section that the
offender mistakenly believed a falsification to be immaterial.

(C) It is no defense to a charge under this section that the oath or affirmation was
administered or taken in an irregular manner.

(D) Where contradictory statements relating to the same material fact are made bythe
offender under oath or affirmation and within the period of the statute of limitations for
perjury, it is not necessary for the prosecution to prove which statement was false, but only
that one or the other was false.

(E) No person shall be convicted ofa violation ofthis section where proofoffalsity rests
solely upon contradiction bytestimony ofone person other than the defendant.

(F) Wlioever violates this section is guilty ofperjury, a felony ofthe third degree.

Available Versions of this Section

January 1, 1974 -- House Bill 511 - 109th General Assembly
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 71 of 80 PAGEID #: 726

OHIO DEPARTMENT OF PUBLIC SAFETY

BUREAU OF MOTOR VEHICLES

INSTRUCTIONS
For Preparing the BMV 2255 for OVI/PhysicalControt/Refusal Arrest

All items must be completed on the form in order forthe BMVto process the suspension onto the driving record ofthe individual.

A. IDENTIFYINGINFORMATION
1. Driver's Information:
a. Enter driver's name, driver license #, class of driver license & state.
b. Verify and enter current address ofdriver (enter only one address).
c. Enterdriver's Dateof Birth and Social Security number.
2. Violation Information:
a. Enter date and time of violation.
b. Enter date and time of refusal/test.
c. Enter the four-digit court code of court that will hear OVI/Physical Control.
d. Lnter the county in which the violation occurred.
e. Enter date, time and place oftest ifthe offender refuses and if reasonable means are used to ensure a chemical test.
3, Vehicle Information:
a. Verify and enter VIN# (1981 model years and beyond have 17characters).
b. Enteryearand makeofvehicle.
c. Enterplate number, type ofplate and state ofissuance.
d. Enter vehicle owner information.
e. Enter address where vehicle will be stored.

B. QUESTIONS FORALS
1. Document the reasonable grounds for OVt or Physical Control arrest before test.
2. Circle whetherthe arrest was an OVIarrest or a PhysicalControl arrest.
3. Checkappropriateboxifoffenderrefusedto submitto test(s).
4, Ifthe offender submitted to the test, indicate test level and circle type oftest. NOTE: Iflevel is bplow the required level,
the offender will not be placed under an Administrative License Suspension, (ALS). Forward all information to the court.
If the offender submitted to the test, the test score must be entered.
5. Check box for "Was placed under an Administrative License Suspension (ALS). " If the box is not checked, then
the ALS cannot be imposed.
6. Check box if driver license was seized.
7. Checkboxifoffenderwasprovideda copy ofthisform at timeofarrest,
8. If offender submits to test(s) and test results are not immediately available, do not impose the ALS until results are
available and offender is notified.
9. Theperson mustsubmitto thechemicaltestor tests, subsequentto therequestofthearrestingofficer,withintwohours
ofthe time ofthe allegedviolation and, if the person doesnotsubmitto the test or tests withinthattwo-hourtime limit,
the failureto submitautomaticallyconstitutes a refusal to submitto the testortests.
10. Document the reasonable grounds for the OVt/Physical Control arrest before test.
11. Ifthe subjecttestedfor a controlled substanceor metabolite, circlethetest type.
12, Specifythecontrolledsubstanceand/ormetaboliteresults:Pleasenotetheresultsshouldbeprovidedinng/ml.
13. Check ifthe subject tested positive for a prohibited level ofmarihuana metabolite and wasunderthe influence ofalcohol
and/or a drug of abuse.
14. Please note: Under ORC 4511. 19 (J)(viii)(l), the prohibited level of marihuana metabolite, in conjunction with a person
being underthe influence ofalcohol, a drug ofabuse, or a combination ofthe two, is 15 nanograms per milliliter of urine
or5 nanogramspermilliliterofwholeblood, blood serum, or plasma. Checktheappropriateboxandlistthe marihuana
metabolite test results if the subject tested positive for prohibited level of marihuana metabolite and was under the
influence of alcohol and/ora drug ofabuse.
15. Ifthe subject tested over a prohibited level for a controlled substance or metabolite, indicate the date the results were
receivedand indicatethedatethe subjectwasservedwiththe noticeofALS.
16. I requestedthedriver, (byreadingadviceontheback),to submitto a chemicaltest(s) foralcoholand/orforthepresence
ofanycontrolled substance or metabolite. Thereasonable means I usedto ensure the offender submitted to a chemical
test were.

OVER
8MV22557/10
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 72 of 80 PAGEID #: 727

INSTRUCTIONS
For Preparing the BMV 2255 for OVI/Physical Control/Refusal Arrest

C. Vehicle Sanctions
1. Check box if the plates were seized.
2. Check box if vehicle was seized as a result of an arrest for OVI.
3. Check box if vehicle was seized as a result of an arrest for DUS or wrongful entrustment of a motor vehicle.
4. Check boxes if vehicle is subject to immobilization/forfeiture.

NOTE: Do not send this form to the BMV if this arrest is only for DUSor Wrongful Entrustment of a Motor Vehicle.

D. CDL Information
Complete this block only if the offender was operating a commercial vehicle. Officer is to read the advice on back of form
BMV 2255 (ORC 4506. 17) and indicate that the advice was read and shown by checking the box.
1. Indicate if a refusal.
2. Indicate test results if test was taken.
3. Checkappropriate remainingboxes.

E. Offender'sSignature
1. Have offender(driver) sign.
2. If the offender refuses to sign, check refused to sign box.

F. Signatures
All signatures on bottom portion ofform, "Complete below only for OVI/Physical Control Arrest, " must be included in order for
BMVto process,
1. Arresting officer must sign, followed by signature ofwitness. This indicates that the officer in fact has read the advice to
the offender.
a. Complete County in affidavit portion.
2. Enforcementagencyofarrestingofficermustbe indicated.
3, Ingeneral,thefourdigitsthatarerequiredarepositionsfourthroughsevenofyournine-characterNCICnumber.Check
with your agency head if you have any questions.
NOTE: OSHP,Columbus PD, and Cincinnati PD:
Pleasecheckwithyouragencyfor the four digitsofthe NCICnumberto use,
4. Enterarrestingofficer'sbusinessstreet address.
5. Officermustsignform againinpresenceofa NotaryPublicorDeputyClerkofCourt, orpeaceofficer.
6. Notary, DeputyClerkor peaceofficermustsignform.
a. IfNotary signs, must include seal and commission stamp. Must also indicate date sworn to.
b. IfDeputy Clerk signs, must include court seal/stamp and city.
c. Ifpeaceofficersigns,heorshemusthavecompletedanapprovedcourseoftrainingasrequiredbyORC2935.081.
G. When all of the above have been completed, distribute the copies as follows:
NOTE: Onlymail BMV2255oncea positivetestresult hasbeenreceivedandanAdministrativeLicense
Suspension imposed, or ifthere was an arrest involving a commercial vehicle.

White BMV(use 2257envelope), includedriverlicense

Canary Law Enforcement
Pink Court
Goldenrod Offender

BMV 2255 7/10

 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 73 of 80 PAGEID #: 728
OHIO DEPARTMENT OF PUBLIC SAFETY
BUREAU OF MOTOR VEHICLES

REPORT OF LAW ENFORCEMENTOFFICERADMINISTRATIVELICENSESUSPENSION/

NOTICE OF POSSIBLECDL DISQUALIFICATION/IMMOBILIZATION/FORFEITURE
A. NAME DRIVERLICENSE » CLASS STATE

CURRENTSTREETADDRESS(AS VERIFIEDBY OFFICER)

CIP/ OHIO COUNTY OF RESIDENCE STATE ZIPCODE

DATE OF BIRTH SOCIALSECURin # 4 DIGITCOURTCODE COUNTYOFVIOLATION

/ /
DATEOFVIOLATION TIMEOFVIOLATION PLACEOFTEST VIN
/ D AM D PM
DATEOFREFUSALORTEST TIME OF REFUSAL Of TEST YEAR MAKE LICENSE PLATE » TYPEPLATE STATE
/ C] AM D PM ^
VEHICLE OWNER'S NAME DATE OF BIRTH STREETADDRESS

CITI' STATE ZIPCODE

VEHICLESTOREDAT (STREETADDRESS) CITY

B. Officerto Complete for All OVI;PhysicalControl Arrests: I requested the driver, by readingadvice on the back, to submit to a chemical test (s) for alcohol
Circle arrest type: OVI PhysicalControl and/or for the presence of any controlled substance or metabolite. My reasonable grounds for
The driver:
OVI/PhysicatControl arrestbeforetestwere:
Q Refused to submit to test (s). C3 Subjecttestedforcontrolledsubstanceormetabolite.Circletesttypeforwhichcontrolledsubstance
D Submittedto test (s). 0;,_ ^ alcoholtes!result or metabdte results were reported: Urine, Whole Blood, Btood Serum, or Blood Plasma.
D Circletesttype forwhichresults werereported: D Specifycontrolled substanceand/ormetabofiteresults:.
Whole Blood. Breath. Urine. Blood Serum, or Blood Plasma D Subject tested positive forprohibited level ofmarihuana metabolite. ^specify amount)
D Was placed under an Administrative License Suspension (4511. 191) and was under the influence of alcohof and/or a drug of abuse.
C3 Licensewasseized D Alcohol, controlledsubstanceor metabolitetest result receivedon. Subject served
D Offender was provided a copy ofthis form at the Ume ofarrest with notice of Administrative License Suspension on.
D Reasonable means officer used to ensure offender submitted to a chemical test were:

C. Officerto CompleteApplicableVehicleSanctions: Q Vehkjeseizedunder4510.41only(DUSorwrongfulentrustmentofa motorvehicle)ffso,Donot

C] Licenseplate(s) seized mail this form to the BMV
D Vehideseizedunder4511. 195(OVI) D Vehicle subject to immobilization
D Vehiclesubjscttoforfeiture
D. Officerto Complete if OffenderwasOperatinga Commercial Vehicle:
D Read and showed advice to offender (4506. 17) Q Commercialvehicleperdefinition(4506.01(E))
C] Refused to submit to tesl(s) D 24-hourout-of-serviceorder
0 Submittedto test(s) 0,_% alcoholtest resuK D CDLto bedisqualified
(Circle One) Whole Blood, Breath, Urins, Blood Serum, or Blood Plasma D CDLseized
D ProhibitedAlcohol ContentwithoutOVIcharge Q Hazardousmaterial
D ProhibitedAlcohol ContentwithOVIcharge D Operateda commercialvehicleunderthe influenceofa controllad substance
E. Tha advice on the back of this form was read to me and I have received a
copy of this form.
D REFUSEDTOSIGN
DRIVER'SSIGNATURE
F, Complete BelowOnlyfor an OVI/ PhysicalControl ARREST:
We, the undersigned,certifythat theadviceprescribedby the GeneralAssembly (under4511. 191 and 4511. 192),wasshownto the person underarresfand read to him or her in the
presence of the arresting officer and one other person,
X ' ________ __OHO_
ARRESTING OFFICER'S SIGNATURE ENFORCEMENT AGENCY N, C. I. C.#

OFFICER'S BUSINESS STREET ADDRESS

WITNESS'S SIGNATURE cin STATE ZIPCODE

COMPLETE BELOW ONLY ON OVIARREST, PHYSICAL CONTROL ARREST, OR ARREST INVOLVING COMMERCIAL VEHICLE. AFFIDAVIT OF ARRESTING OFFICER:
STATEOFOHIO,COUNTrOF .
I cert'fy I arrested the person, havinghad reasonable grounds to believe the person wasoperating a vehicle upon a highway, or upon public or pnvate property used by the public forvehicular
Ifavel or parking in the State of Ohio, uridBrthe influence ofalcohol and/or drugs ofabuse, in physical control ofa vehide while under the influence ofalcohol and/or drugs ofabuse, or with a
prohibited concentrabon ofalcohol in the whole blood, blood serum, blood plasma, breath, or urine. I advised the person in the pfescribed manner of!heconsequences ofa refusal or a test.
Thepersoneitherrefusedthe test, orwasunderarrestforOVIandtookthetestandhada prohibitedconcentrattonofalcoholinthewholeblood, bioodserum,bloodplasma,breath orurine
(all as described above). In the case of a commercial vehicle (if applicable) i had reasonable grounds to believe the person was driving a commercial motor vehicle in the State of Ohio in
/lolation of section 4506. 15 of the Ohm Revised Code. The information contained on this form is true to the best ofmy knowledge and belief.
.

ARRESTINGOFFICERSIGNATURE PEACE OFFICER SIGNATURE

Sworn to before me this.. .

dayof ^20_
NOTARY PUBLIC'S SIGNATURE
x___" -Cityof.
DEPUnCLERKOFCOURT'SSIGNATURE
BMV 2255 7/10 WhHe/Origlnal- BMV Canary- LawEnforcement Pink-Court Goldenrod - Offender
 Case: 1:25-cv-00481-DRC-KLL Doc
OHIO #: 6 Filed:
DEPARTMENT OF08/21/25 Page: 74 of 80 PAGEID #: 729
PUBLIC SAFETY
BUREAU OF MOTOR VEHICLES

REPORTOF LAW ENFORCEMENTOFFICERADMINISTRATIVELICENSESUSPENSION /

NOTICEOF POSSIBLECDL DISQUALIFICATION/ IMMOBILIZATION/ FORFEITURE
CLASS
A. NAME
L^l^tS
DRIVER LICENSE #
I^JQg'^^-^1^0 STStf-
^^E! OHIO 0
C\Vf
g%£WoE <a y^r v^^
.

4 DIGIT COURT CODE COUNPr'OFYIOI

-IQS^ C.I 1^^/sfJ-
ytot CEOT,T^ST
JJZ^LO^^M.
TIMEORSBU^^RTESr
^E^p-^: l/fr&»C(^Z. <;^S"0'w^Z®2^
STA Fi'PEPl,
DATf
"E%® Jl'T&-T5 gAM^tPM SQwwJggyii _fiL1
VEHICLE EOFBiRTH
DATE OF I 1 STREET ADDRESS
0^^^
cm' STATE ZIPCODE

VEHICLESTO CIFf
pR>RE^D§i^^ I requestsd the driver, by reading advice on ihe back, to submit to a chemical test (s) (or alcohol
B. Officer to Complete (or All OVI / Physical Control Arrests:
Circle arresttype: OVI PhysicalControl and / or fof the presence of any controllsd subslance or mslabolilB. M^reyonable grounds for
OVI/ Ph^i(3l ContrptarTBit kefpre |pst_^re: _ » . Y^'
The driver
UU\.l I^A^ fcvt/Tiryi C^
Refused to submit to lest (s). a Subjecttestedforcontrolledsubstanceormetabolite. Circfetest typeforwhidicontrolled subslance
SubmiHedto test (s). 0_ _% alcohol lesl result or metaboliteresultswerereportsd: Urine, WholeBlood, Blood Serum,OfBlood Plasma.
D Cirdetesttype torwhichresultswerereported: D Spedfy controlled substance and / or metabolrte results:.
WhotsBkx)d, Bnea^, Urine, BloodSerum, or BloodPlasma D Subjecttestedposi'Bvelorprohibitedlevelofmarihuanametaboiite. _(speo'iyamount)
D WasplacedunderanAdministrativeLicenseSuspension(R. C.4511.191) andwasunderthe influenceof elcohol and / or a dfug ofabuss.
D License was seized D Alcohol, controlled subslance or metaboliie tesi result received on. .. Subject served
D Offender was provided a copy of this form al the lime of airest. wilti notice of AdministraUve License Suspension on_
;easonable means officer used to ensure offender submitted to a diemicat test were:
^f^ /i^^r
C. Officer to Complete Applicable Vehicle Sanctions: D VehideseizedunderR.C.4510.41 only(DUSorwrongfulentrustmento(a motorvehicle)Ifso, Do
Q Licenseplate(s) seized not mail this form to the BMV
D Vehicfs seized under R.C. 4511. 195 (OVI) D Vehide subject lo immobilizaiion
D Vehidesubjecttofoffeiture
D. Officerto Complete ifOffenderis theholderof a commercialdriver D Prohibited Alcohol Content with OVI charge
licenseorwasOperatinga CommercialVehicle; D Commera'at vehicle per definition (R. C. 4506. 01(E))
D Read and showed advice to offender (R. C. 4506. 17) D 24-hour oul-of-service order
D Refused to submilto testjs) D CDL to be disqualified
D Submined lo Issi(s) a_% alcohol test result D COL seized
;ircle One) Whole Blood. Breath, Urine, Blood Serum, or Stood Plasma D Hazardous material
a Pfohibited'Alcohol'ContenlwithoutOVI'charge_0 OP^ateda com^errialvehicteunderiheinfluen^ofa controllBdsubstance
E. The advice on the back of this form was read to me and I have received a
copy of this form. 0<2_W ;EFUSEOTOSIGN
Kl'RE
"f. Complete BelowOnlyforanOVII PhysicalControl ARREST:
We.theundersigned, certify thattheadviceprescribed by e GeneratAssembly (under R. C.4511. 191andR.C.4511. 192),wasshownto (heperson underarrestandreadtohimorhsrin
thepresenceofthe^{festingoffiarandone^thyperepn
^ 'T^r^) |^/\^ [/^f CCJ 0 _o"o I 1 N.C.
1^1^ I.C. ff
1(^
ARRESTING'OSFlCEFtS SIGNATURE
^^'2-
SSTFi^TADDF
OFFIC£R'S BUSINESS STREET ADD
X /<C^~t^to->C^ ^) l/Tff-Tl^L 4.^7D ^STATE ZIP CODE
WIT/iESS'8'SlGNATURE'

COMPLETEBELOWONLYONOV1ARREST,Py^Wl.CONTROL4RRESLORARRESTINVOLVINGCOMMERCIALVEHICLE.AFFIDAVFTOFARRESTINGOFFICER:
STATEOF OHIO.COUNTYOF f'yt J^iyWlQI/LT: _
I certify I arrested theperson, having had'r^onabTe grounds tobelieve Iheperson wasoperating a vehideupona highway or upon publicor prfvatBproperty usedbythepublicforvehicular
travel orparkingintheSlateofOhio,undeftheinfluence ofalcoholand/ ordmflS^a^ysf, inphysical control ofa vehiclewhiteundertheinfluenceofalcoholand/ ordnjgsofabuse,orwith a
prohibited contintration ofatcohol inthe wholeblood, blood seium, blood plasma, breath, or urine. I advised theperson in the prescribed mannsrofthe consequBnces ofa refusal ora test.
Piepereoneilherrefusedthelest,orwasunderarrestforOVIandlookthetestandhada prohibitBdconcentralj'onolalcoholinIhewholeblood,bloodserum,bloodplasma breath orurine
(all asdescribed a6ove7. h the case ofa commercial vehide (if applicable) I had reasonable grounds to believe the person wasdriving a commBro'al motor vehide in Ihs State of OhioIn
violationofsection4506. 15oftheOhioRevised^Code.Theinformalioncontainsdon Ihisformistrueto [hebestofmyknowledgeandbelief.
>^^-^I5>SVL
ARfiEiSffGOFFICERSIGNATURE PEACEOFFICERSIGNATURE

Sworn to before me this MOACJh 20^)

NOTARY PUBLIC'S SIGNATURE
.
Cityof,
OEPLnYCLERl?bF COyR TS SIGNATURE

BMV22554/17r?60-10051 PUBLIC UVh+to /rirlnlna) " OUtV rand^ C»*4r, n"A^->n< DI-1, r..,, -< /'. l^-. -j nu-^-j--
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 75 of 80 PAGEID #: 730

From: als@dps. ohio. gov <^

Subject: RE: [EXTERNAL]BMV2255
Date: June 30, 2025 at 1:28PM
To; chefdamianlewis@gmail.com

Greetings,

Thank you for writing to the Ohio BMV concerning your driving record. Please see the
attached BMV 2255 document. This is the only document the BMV has received regarding
this suspension.

Thank you,
Ohio BMV

From: DPS BMV Records <bmvrecords@dps.ohio.gov>

Sent: Monday, June 30, 2025 11:10AM
To: DPS ALS <als@dps. ohio. gov>
Subject: FW: [EXTERNAL]BMV 2255
We received the below. If possible, please assist the customer.

Jeff Payne
Chief, BMV Record Services
Ohio Department of Public Safety
Phone #-(614)752-7631

From: Chef Damian Lewis <chefdamianlewis@gmail.com>

Sent: Monday, June 30, 2025 7:45 AM
To: DPS OnlineRecordsRequest <onlinerecordsrequest@dps. ohio. goY>
Subject: [EXTERNALJBMV 2255
of the BMV 2255 form used to enact the administrative
1fillgI1y related documents that are associated. Thank

Bert D Lewis
3898 Vineyard Green Drive
01/27/1980

OHIO DEPARTMENT OF PUBLIC SAFETi'

BUREAU OF MOTOR VEHICLES

RFPDRT (~lF I AW FNFnRCEMFNTOFFICPR AnMINISTRATIVF1 ICFNSE SLISPENSION /

 Case: 1:25-cv-00481-DRC-KLL Doc #: Search
6/30/25, 1:53 PM 6 Filed: 08/21/25
Results Page:
- CourtView Justice 76 of 80 PAGEID #: 731
Solutions

Exhibit C:
ch^
Crim. Record

Showing 1 to 8 of8
« < 1 >»
Case Case File Date Initiating Action PartY/Comfiany Party. Date of AffiUa m Disposition
^.^ Number ' jyea -rf'*^~~' ^ Typje -* Birth
TR-Traffic 03/04/1998 Speed Lewis, Bert D Defendant 01/27/1980 (AJ) Bond Forfeiture

CR- 07/01/2000 Underage consumption - Repealed Lewis, Bert D Defendant 01/27/1980 (AJ) Guilty, No Contest, Bound
Criminal 10/11/02 Ov - Crim & Traf

TR - Traffic 07/20/2000 Speed > 60 MPH on Two-LaneState Lewis, Bert D Defendant 01/27/1980 (AJ) Bond Forfeiture
Route
TR - Traffic 09/07/2005 Obeying Traffic Control Device Lewis, Bert D Defendant 01/27/1980 (AJ) Bond Forfeiture

0 CR - 05/10/2020 Possession of a Controlled Lewis, Bert D Defendant 01/27/1980 Party unavailable

Criminal Substance/misdemeanor
CV - Civil 09/11/2020 BMV and All Other Civil 1 Def OMW Lewis, Bert D Defendant Magistrate - Judgment, Writ for
Civil Cases
0 TR - Traffic 04/29/2020 Driving under the influence of Lewis, Bert D Defendant 01/27/1980 Party unavailable
alcohol/drugs
CV-Civil 01/19/2022 Complaint on Contract or Account 1 Def Lewis, Bert D Defendant Magistrate - Judgment, Writ for
cert. mail OMW CivilCases " |
J

Administrative License Suspension

lacking prerequisite OVI arrest
(R. C. 4511. 191)

https://municipal. clermontclerk. org/eservices/searchresults. page 1/1

 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 77 of 80 PAGEID #: 732
OHIO DEPARTMENT OF PUBLIC SAFETY
BUREAU OF MOTOR VEHICLES
P. O. BOX 16520
COLUMBUS, OHIO 43216-6520
DRIVING RECORD HISTORY
REQUESTON

DATE NAME DATE OF BIRTH DRIVER LICENSE NUMBER

06/30/2025 1/27/1980

BERT LEWIS The following is a true and accurate enumeration of

DAMOCALI PRODUCTIONS motor vehicle accidents and records of convictions for
769 RUE CENTERCOURT violations of the motor vehicle law pursuant to Section
CINCINNATI,OH 45245 4509. 05 of the Ohio Revised Code.

REGISTRAR, OHIO BUREAU OF MOTOR VEHICLES

DRIVERINFORMATION
NAME DATE OF BIRTH SOCIAL SECURIT]'NUMBER DL/ID NUMBER DATE OF ISSUANCE

BERT D LEWIS 1/27/1980 RN085053 11/25/2011

LAST KNOWNADDRESS DATE OF EXPIRATION

3898 VINEYARD GREEN DR, CINCINNATI, OH 452555632 1/27/2015

SEX HEIGHT WEIGHT HAIR COLOR EYE COLOR LICENSE/IDCLASS

MALE 5'9" 150 BROWN BLUE CLASS D - OPERATOR

STATUS AS OF 06/30/2025: FAILURE TO REINSTATE

ENDORSEMENTS:NONE
RESTRICTIONS:CORRECTIVELENSES

DRIVING RECORD HISTORY

WITHDRAWALS
Sl ADMINISTRATIVELICENSESUSPENSION/REFUSAL STATUS: FAILTO REIN
START: 3/14/2020 END: 3/14/2021 CLEAR: N/A BMV CASE: S120005819
COURT CASE: OFFENSE:

LF LICENSEFORFEITURE STATUS:CLOSED
START: 11/23/2005 END: INDEFINITE CLEAR: 12/1/2005 BMV CASE: LF05073470

COURT CASE: OFFENSE:

CONVICTIONS
C3 OUT-OF-STATECONVICTION
COURT: TEXAS-UNKNOWNCOURT COURT CASE: UNKNOWN

OFF DATE: 5/17/2012 CONV. DATE: 6/11/2012 POINTS:

OFFENSE: F04-S B NOT USED JURISDICTION: TX

COMM. VEHICLE:NO HAZMAT MATERIAL:NO

C3 OUT-OF-STATECONVICTION
COURT: NEVADA-UNKNOWCOURT COURT CASE: UNKNOWN

OFF DATE: 7/18/2006 CONV. DATE: 9/8/2006 POINTS:

OFFENSE: S93-SPEEDING**** JURISDICTION: NV
BMV 1155 10/21 [17601059] Page 1 of 3
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 78 of 80 PAGEID #: 733
i\i & Sa^ty
TRAFFICCRASH REPORT .
DENOTESMANDATORY FIELDFOR SUPPLEMENTREPORT LOCAL REPORT NUMBER .

IOH-Z IXJOH-3
LOCAL INFORMATION 002000010951
PHOTOS TAKEN
HIT/SKIP NUMBER OF UNITS UNIT IN ERROR
IO H-IP Q OTHER REPORTING AGENCY NAME . NCIC*
1 - SOLVED 98 - ANIMAL
I SECONDARYCRASH
IPRIVATEPROPERTl' CLERMONT COUNTY SHERIFF 01300 | 12-UNSOLVED L 99 - UNKNOWN

CRASH SEVERITY
COUNTY*
LOCALIT-CITV LOCATION:CIT/. VILLAGE.TOWNSHIP* CRASH DATE/TIME*
1 - FATAL
VILLAGE
13 I ^r- TOWNSHIP
Batavia 03/14/2020 15:49 2-SERIOUS INJURY
ROAD TYPE SUSPECTED
ROUTE NUMBER IPREFIX1 - NORTH LOCATION ROAD NAME LATITUDE DECIMALDEGREES
2 - SOUTH 3 -MINOR INJURY
3 - EAST RD 39.079786
4-WEST
Amelia Olive Branch SUSPECTED
4 - INJURY POSSIBLE
IROUTE NUMBER IPREFIX 1 - NORTH REFERENCEROAD NAME (ROAD. MILEPOST. HOUSE*) ROAD TYPE LONGITUDE DECIMAL DEGftEES
2 - SOUTH 5 - PROPERTi' DAMAGE
3-EAST 4262 -84. 224368 ONLY
4 - WEST
DIRECTION, ROAD TYPE INTERSECTION RELATED
REFERENCE POINT ROUTE TYPE
FBOM REFERENCE
1 - INTERSECTION At - ALLEY HW . HIGHWAY RD - ROAD WITHIN INTERSECTION OR ON APPROACH
1 - NORTH IR-INTERSTATEROUTEfTP)
3 I 2 - MILEPOST 2 - SOUTH AV-AVENUE LA-LANE SQ-SQUARE
3-EAST US - FEDERAL US ROUTE BL-BOULEVARD MP-MILEPOST ST-STREFT
3 - HOUSE*
4 - WEST
WITHIN INTERCHANGE AREA NUMBER OFAPPROACHES
SR - STATE ROUTE CR - CIRCLE 0V - OVA1. TE - TERRACE
DISTANCE. DISTANCE
UNIT OF MEASURE
CT- COURT PK- PARKWAY TL - TRAIL ROADWAY
FROM REFERENCE CR- NUMBERED COUNTf ROUTE
1 - MILES DR-DRIVE Pl. PIKE WA-WAY
2 - FEET TR - NUMBERED TOWNSHiP HE-HEIGHTS PL-PLACE ROADWAY DIVIDED
3 - YARDS ROUTE

LOCATION OF FIRST HARMFUL EVENT MANNER OF CRASH COLLISION/IMPACT DIRECTIONOFTRAVEL MEDIAN rypE
1 - ON ROADWAY 9 - CROSSOVER - NOT COLLISION 4 - REAR-TO-REAR 1 - NORTH 1 - DIVIDEDFLUSH MEDIAN
2 - ON SHOULDER 10 - DRIVEWAY/ALLEY ACCESS BETWEEN 5 . BACKING 2 - SOUTH ( <4 FEET 1
TWO MOTOR
3 - IN MEDIAN 11 - RAILWAYGRADE CROSSING 6-ANGLE I_I 3-EAST 2 - DIVIDED FLUSH MEDIAN
VEHICLESIN 4 - WEST ( it FEET)
4-ON ROADSIDE 12 - SHARED USE PATHS OR 7 - SIDESWIPE, SAME DIRECTION
TRANSPORT
5 - ON GORE TRAILS 3 - DIVIDED. DEPRESSEDMEDIAN
B - SIDESWIPE,OPPOSITEDIRECTION
6 - OUTSIDETRAFFIC WAY 13-BIKE LANE REAR-END 4 - DIVIDED, RAISED MEDIAN
7-ON RAMP 14-TOLL BOOTH HEAD-ON 9-OTHER/UNKNOWN (ANY TYPE!

8-OFF RAMP 99-OTHER/UNKNOWN 9-OTHER/UNKNOWN

CONTOUR CONDITIONS SURFACE

WORK ZONETYPE LOCATION OF CRASH IN WORK ZONE
I WORK ZONE RELATED
1 -LANE CLOSURE 1 - BEFORETHE 1ST WORK ZONE 4 2
II WORKERSPRESENT 2 - LANE SHIFT/ CROSSOVER
WARNINGSIGN
2 - ADVANCEWARNINGAREA 1 - STRAIGHT 1 -DRY 11 -CONCRETE
II LAWENFORCEMENTPRESENT 3 -WORK ON SHOULDER
3 - TRANSITION AREA
LEVEL 2-WET 12 - BLACKTOP,
OR MEDIAN 2 - STRAIGHT 3-SNOW BITUMINOUS,
4 - ACTIVITYAREA
4 - INTERMITTENT OR MOVING WORK GRADE 4-ICE ASPHALT
ACTIVE SCHOOL ZONE S - TERMINATIONAREA
3-CURVE LEVEL 5 - SAND, MUD. DIRT, |3 - BRICK/BLOCK
5 - OTHER
OIL GRAVEL 14 - SLAG , GRAVEL,
14 - CURVE GRADE
LIGHT CONDITION WEATHER STONE
19 - OTHER 6-WATER (STANDING,
1 - DAYLIGHT 1 - CLEAR 6 - SNOW MOVING) 15 - DIRT
/UNKNOWN
2 - DAWN/DUSK Z-CLOUDY 7-SEVERE CROSSWINDS 7 - SLUSH 19 - OTHER
3 - DARK - LIGHTED ROADWAY 3 - FOG, SMOG, SMOKE 8 - BLOWING SAND, SOIL, DIRT, SNOW /UNKNOWN
9-OTHER/UNKNOWN
4 - DARK - ROADWAY NOT LIGHTED 4 - RAIN 9 - FREEZING RAIN OR FREEZING DRIZZLE
5-DARK-UNKNOWN ROADWAY LIGHTING 5-SLEET. HAIL 99 - OTHER/UNKNOWN

9-OTHER/UNKNOWN

NARRATIVE

On 3/14/2020- Unit 1 traveling South on Amelia Olive Branch crossed center and
struck unit 2 head on. The roadwaywas curved and wet. The driver of both units
weretransportedto Universityof Cincinnati MedicalCenter. Both passengersof unit
2 werejuvenile andtransported to CincinnatiChildren'sHospital. Bothvehicleswere
not operable and towed. Airbags deployed in unit 1 but not unit 2. A vehicle
inventorysearchwascompleted. A cut strawand powderwasfound insidea Rx
bottle in unit 1.

I made contact with both drivers at University Medical Center. Unit 2 estimated his
speed around40 MPH. Unit 1 didn'tknowhowfast hewasgoing and doesnot
know what happened,

Unit 1 is believedto be impairedandwasread the BMV2255witnessed bystaff. A

test was offered and refused.

Dep. M. Ross

#2064

DISPATCH DATE/TIME ARRIVAL DATE/TIME SCENE CLEARED DATE/TIME REPORT TAKEN BY

CRASH REPORTED DATE / TIME
POLICEAGENCY
03/14/2020 16:00 03/14/202016:00 03/14/202016:00 03/14/202020:00

OFFICER'SNAME* CHECKEDBV OFFICER'S NAME'

TOTAL TIME OTHER TOTAL
IROADWAY CLOSEDI INVESTIGATION TIME MINUTES Dep. M. Ross Scott, D ISUPPLEMENT
(CORRECTIONORADDITION
OFFICER'SBADGE NUMBER* CHECKEDBY OFFICER'SBADGE NUMBER* TO AN EXISTINGREPORTSENTTO
ODPS)
240 2064 R2367

PAGE 1 OF 5
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 79 of 80 PAGEID #: 734
LOCAL REPORT NUMBER
Ohio UNIT 002000010951
OWNER PHONE:INCLUDEAREA CODE(D SAMEASDRIVER} I'y.iAi.icn
UNIT* OWN ER NAME: LAST. FIRST, MIDDLE (D SAME AS DRIVER)
DAMAGE SCALE
1 LEWIS, BERT, D.
OWNER ADDRESS:STREET,CITY. STATE, ZIP |Q SAMEASDRIVER) 1 - NONE 3 - FUNCTIONAL DAMAGE

3898 VINEYEARD GREEN DR., CINCINNATI, OH. 45255

4 | 2 - MINORDAMAGE 4 - DISABLINGDAMAGE
9-UNKNOWN
COMMERCIALCARRIER: NAME.ADDRESS.CITY, STATE.ZIP COMMERCIALCARRIER PHONE:INCLUDE AREA CODE
DAMAGED AREAIS1
INDICATEALL THAT APPLY
LP STATE LICENSEPLATE » VEHICLEIDENTIFICATION S VEHICLEYEAR VEHICLE MAKE

2013 HON DA
OH HQY2902^ 1HGCR2F35DA072023
INSURANCECOMPANY INSURANCE POLICY » COLOR VEHICLEMODEL
IINSURANGE
fERIFiED BLU ACCORD

TVPEOFUSE TOWED BY: COMPANY NAME

IIN EMERGENCY AUTO WORKS
[""JC OMMERCIAL |[GOVERNMENT I RESPONSE
HAZARDOUS MATERIAL
VEHICLEWEIGHTGVWR/GCWR
.
INTERLOCK
IDEVICE I IHIT/SKIPUNIT
» OCCUPANTS
1 - S10KLBS.
2 - 10.001 - 26KLBS.
D;|MATERIAL
'RELEASED
CLASS* PLACARD ID»

'EQUIPPED 1 3 - > 26K LBS. IPLACARD III J

1 - PASSENGERCAR 6-VAN (9-15 SEATS) 12 "GOLF CART 18-LIMOfUVERVVEHICLE) 23 - PEDESTRIAN/SKATER

2 - PASSENGERVAN 7 - MOTORCYCLE 2-WHEELED 13-SNOWMOBILE 19" BUS (16+ PASSENGERS) 24 - WHEELCHAIR (ANY TYPE)
(MIN)VAN) 8 - MOTORCYCLE3-WHEELED 14-SINGLE UNIT 20-OTHER VEHICLE 25 - OTHER NON-MOTORIST
3 - SPORT UTILITY 9 - AUTOCVCLE TRUCK
21 -HEAW EQUIPMENT 26 - BICYCLE
VEHICLE W - MOPED OR MOTORIZED 15-SEMI-TRACTOR
22-ANIMAL WITH RIDER OR 27-TRAIN
4-PICKUP BICYCLE 16-FARM EQUIPMENT
ANIMAL-DRAWNVEHICLE gg . UNKNOWNORHIT/SKIP
5 - CARGO VAN 11 -ALL TERRAIN VEHICLE 17-MOTORHOME
(ATV/UTV)
» OF TRAILING UNITS

WAS VEHICLE OPERATING IN AUTONOMOUS 0-NO AUTOMATION 3 - CONDITIONAL AUTOMATION 9 - OTHER/UNKNOWN

MODE WHEN CRASH OCCURRED?
1 - DRIVERASSISTANCE 4 - HIGH AUTOMATION

1 - YES ? -NO 9 - OTHER/ UNKNOWN AUTONOMOUS2 - PARTIALAUTOMATION 5 - FULLAUTOMATION

MODE LEVEL

1 - NONE G - BUS - CHARTER/TOUR 11 - FIRE 16-FARM 21 -MAIL CARRIER

2 - TAXI 7 - BUS - INTERCITY 12-MILITARY 17 - MOWING 99-OTHER/UNKNOWN

3 - ELECTRONIC RIDE 8 - BUS - SHUTTLE 13-POLICE 18-SNOW REMOVAL

SPECIAL '. HARINK 9^ BUS-OTHER 14-PUBLIC UTILITY 19-TOWING

FUNCTION4 - SCHO°LTBANSPORT ," ,AMBUtANCE 15 - CONSTRUCTIONEQUIP, 20 - SAFETYSERVICE

5 - BUS - TRANSIT/COMMUTER PATROL

1 -NO CARGO BODY TYPE 4 - LOGGING 7 - GRAIN/CHIPS/GRAVEL 11-DUMP 99 -OTHER/UNKNOWN

/ NOT APPl. iCABt.F 5 - INTERMODAL 8 - POLE 12 -CONCRETEMIXER

"CARGO 2-iius
BODY 3-VEHICLE TOWING
ANOTHER MOTOR VEHICLE
CONTAINER CHASSIS
6 -CARGOVAN
/ENCLOSEDBOX
9 - CARGO TANK
10-FLAT BED
U - AUTOTRANSPORTER
14-GAR8AGE/REFUSE
,

(^. . ^.
- TURN SIGNALS 4 - BRAKES 7-WORN OR SLICK TIRES 9-MOTOR TROUBLE 99-OTHER/UNKNOWN

-HEAOLAMPS S - STEERING 8-TRAILER EQUIPMENT 10-DISABLEDFROM PRIOR

6 - TIRE BLOWOUT DEFECTIVE ACCIDENT
- TAIL LAMPS
D-NO DAMAGE [0] [.]-UNDERCARRIAGE [ 14 ]
1 - INTERSECTION - 4-MID8LOCK- 7 - SHOULDER/ROADSIDE 10-DRIVEWAY ACCESS 99 - OTHER/UNKNOWN

MARKEDCROSSWALK MARKED CROSSWALK 8 - SIDEWALK 11 -SHARED USE PATHS D-TOP[13] D-ALLAREAS[1S]

"NON:-' 2 - INTERSECTION - 5-TRAVEL LANE' OR TRAILS
MOTORIST UNMARKFD FRn^WAI K OTHER LOCATION
9 - MEDIAN/CROSSING 12-FIRST RES PONDER D-UNIT NOTAT SCENE[ 16]
iSLAND AT INCIDENT SCENE
LOCATION 3 , INTERSECTION- OTHER 6 - 810'CLE LANE

1 -STRAIGHT AHEAD 9-LEAVING TRAFFIC IS-WALKING, RUNNING, 21 " STANDING OUTSIDE INITIAL POINT OF CONTACT
1 - NON-CONTACT
2 - BACKING LANE JOGGING,PLAYING DISABLED VEHICLE
0-NO DAMAGE 14 - UNDERCARRIAGE
2 - NON-COLLISION 10-PARKED 16-WORKING 99-OTHER/UNKNOWN
3-CHANGING LANES

3 - STRIKING 4 - QVERTAKING/PASSiNG 11 -SLOWING OR STOPPED 17-PUSHING VEHICLE 12 1-12-REFERTOUNIT 15 - VEHICLENOTAT SCENE

PRE-CRASH S-MAKING RIGHTTURN IN TRAFFIC 18-APPROACHINGOR DIAGRAM
99 -UNKNOWN
4-STRUCK ^IONS 6-MAKING LEFTTURN 12-DRIVERLESS LEAVINGVEHICLE
13-TOP
5 - BOTH STRIKING 7 ^ MAKING U-TURN 13 - NEGOTIATING A CURVE 19-STANDING
81 STRUCK 8 - ENTERING TRAFFIC 14-ENTERINGOR CROSSING 20 - OTHERNON-MOTORIST
9-OTHER/UNKNOWN IANE SPECIFIEDLOCATION
8 - FOLLOWING TOO CLOSE 13 - IMPROPER START FROM 18 - OPERATING DEFECTIVE 23 - OPENING DOOR INTO) TRAFFIC CONTROL
1 - NONE TRAFFICWAY FLOW
/AC DA A PARKEDPOSITION EQUIPMENT ROADWAY
2 - FAILURE TO YIELD 1 " ONE-WAY 1 -BOUNDABOUT 4 - STOP SIGN
3 -RAN RED LIGHT 9-IMPROPER LANE 14-STOPPEDOR PARKED 19 - LOAD SHIFTING 99-OTHER IMPROPER
2 - TWO-WAY 2 - SIGNAL S - YIELD SIGN
CHANGE ILLEGALLY /FALLING/SPILLING ACTION
4 - RAN STOP SIGN 2 3-FLASHER 6 - NO CONTROL
5 - UNSAFE SPEED 10-IMPROPER PASSING 15-SWERVING TO AVOID 20-IMPROPER CROSSING

CONTRIBUTING 5 . IMPROPER TURN 11 - DROVE OFF ROAD 16-WRONGWAY 21 - LYING IN ROADWAY

CIRCUMSTANCES 12-IMPROPER SACKING 17-VISION OBSTRUCTION 22-NOT DISCERNIBLE OOF THROUGH LANES RAIL GRADE CROSSING
7 - LEFTOFCENTER
ON ROAD 1 -NQT1NVLOVED

SEQUENCEOF EVENTS 2 - INVOLVEO^ACTIVECROSSING

EVENTS 3 - INVOLVED-PASS!VE CROSSING
1 - OVERTURN/ROLLOVER 7 - SEPARATIONOF UNITS 12 - DOWNHILLRUNAWAY 19 - ANIMAL-OTHER 23 - STRUCK BY FALLING.

8 - RAN OFF ROAD RIGHT 13 - OTHERNON-COLUSION 20 - MOTORVEHICLEIN SHIFTING CARGO OR

2 - FIRE/EXPLOSION UNIT /NON-MOTORIST DIRECTION
TRANSPORT ANYTHING SET IN
3 -IMMERSION 9 ^ RAN OFF ROAD LEFT 14 - PEDESTRIAN
MOTION BY A MOTOR 1 - NORTH 5 - NORTHEAST
4 - JACKKNIFE 10-CROSS MEDIAN 5 - PEDALCYCLE 21 - PARKED MOTOR
VEHICLE
5-CARGO/EQUIPMENT 11 - CROSS CENTERLINE- 6-RAILWAY VEHICLE VEHICLE 2 - SOUTH 6 - NORTHWEST
24-OTHER MOVABLE
LOSSORSHIR- OPPOSITE DIRECTION 7-ANIMAL- FARM 22 - WORKZONE OBJECT 3 - EAST 7 - SOUTHEAST
OFTRAVEL 18-ANIMAL-DEER MAINTENANCE
6 - EQUIPMENTFAILURE 4 - WEST 8 - SOUTHWEST
EQUIPMENT
9 -OTHER/UNKNOWN
COLLISION WITH FIXED OBJECT - STRUCK
25 - IMPACTATTENUATOR 31 -GUARDRAIL END 38 - OVERHEAD SIGN POST 45 - EMBANKMENT 52 - BUILDING

/CRASH CUSHION 32 - PORTABLE BARRIER 39-LIGHT/LUMINARiES 46 - FENCE 53-TUNNEL UNIT SPEED DETECTED SPEED
26-BRIDGEOVEKHEAO 33 - MEDIAN CABLE BARRIER SUPPORT 47 - MAILBOX 54-OTHER FIXED
STRUCTURE 34^ MEDIANGUARORAIL 40 - UTILITY POLE 48 ^ TREE OBJECT
27-BRIDGEPIEROR BARRIER 41 - OTHER POST, POLE 49-FIRE HYDRANT 99-OTHER/UNKNOWN 40 1 - STATED/ ESTIMATEDSPEED
OR SUPPORT 50-WORK ZONE
ABUTMENT 35-MEDIAN CONCRETE
28 - BRIDGE PABAPET BARRIER 42 - CULVERT
MAINTENANCE 1 I 2-CALCULATED/EDR
EQUIPMENT POSTED SPEED
29 - BRIDGE RAIL 36 - MEDIAN OTHER BARRIER 43 - CURS
30-GUARDRAIL FACE 37 - TRAFFIC SIGN POST 44 - DITCH St -WALL
3 ^ UNDETERMINED

FIRST HARMFUL EVENT MOST HARMFUL EVENT

40

PAGE 2 OF 5
 Case: 1:25-cv-00481-DRC-KLL Doc #: 6 Filed: 08/21/25 Page: 80 of 80 PAGEID #: 735

Past Weather in Cinclsinatl, Ohio; USA -- March 202:0

Time/General Weather v Time Zone DST Changes Sun & Moon

Weather Today Weather Hourly 14 Day Forecast Yesterday/Past Weather Climate (Averages)

Currently; 77 °F. Light rain. Broken clouds. (Weather station: Cincinnati Municipal Airport Lunken Field, USA), See more current weather >

Select month: March 2020

March 2020 Weather in Cincinnati -~ Graph

<il°F
Wed, Mar 11 Thu, Mar 12 Fri. Mar 13 Sat, Mar 14 Sun, Mar 15 Mon, Mar 16 Tue, M;
12am Sam 12pm 6pm 12am Sam 12pm 6pm 12am Sam 12pm 6pm 12am Sam 12pm Kpfn 12am 6am 12pm 6pm t2 am 6am 12pm 6pm | 12am

Iip
.

F)

S6 Hi:64
Hi:61 . .... Hi:61 Hi:63
60 Lo:63
54 > Hi:54 Hi:52 Lo:59 Hi:52 Hi:54 Hi:52
H.:46 Hi:4B Lo:50 Lo:54 Lo:52 Hi:46 H!:45 Hi:46 Hi:46 Hi'48 Hi:46 Hi:45
48 Hi:45 H1:43 Hi:43 Lo:46 Lo:45 I Lo:45
<2' j Lo:4S Lo:45 Lo:46
Lo:43 Hi:37 Hi;37 Hi;37 Hi:39 Lo:43 Lo:43
Lo:37 Lo:37 Lo:37 Lo:36 Lo:36 Lo:36 Lo:39 Lo:39
Lo:38 Lo:37
36
Lo:36
30

/ - -- 0 0 ^ ! \ s ^ ^. \ 0 ^ ^ /' ^ /- ^ ^ ^ . - \ \ /
ind 1277 10 10 11 4
;h)

Saturday, March 14, 2Q2Q, ''2:00 pf'n -- 6'00 pn''

/, ^ / 07 op
.

tl.,* / (..

Sun. Man Mon. MarS Tue, Mar3 Wed, Mar4 Thu, Mar5 Fri, Mar 6 Sat, Mar7 Sun, Mar 8 Mon, Mar9 Tue, Mar 10 Wed, Mar 11 Thu, Mar
12 Fri, Mar 13 Sat, Mar 14 Sun, Mar 15 Man, Mar 16 Tue, Mar 17 Wed, Mar 18 Thu, Mar 19 Fri, Mar 20 Sat, Mar21 Sun, Mar 22 Mon, Mar
23 Tue, Mar 24 Wed, Mar 25 Thu, Mar 26 Fri, Mar 27 Sat, Mar 28 Sun, Mar 29 Man, Mar 30 Tue, Mar 31

S.ge. w.eath.er. OY.aryj.&w >

.

High & Low Weather Summary for March 2020

Temperature Humidity Pressure

High 79°F(Mar28, 2:S3pm) 100% (Mar 2, 11:37 pm) 30. 61 "Hg (Mar 2, 11:37pm)

Low 20 °F (Mar 1, 3:53 am) 20% (Mar 8, 5:53 pm) 29. 59 "Hg (Mar3, 6:53am)
Average 49 "F 73% 30. 09 "Hg

. Reported Mar 1 12:53 am - Mar 31 11:35 pm, Cincinnati. Weather by CustomWeather, ® 2025

Note: Actual official high and low records may vary slightly from our data, if they occured in-between our weather
recording intervals... Ma[ejibQj|jtjour_weath6U.ec.Qrds