Date Filed: 5th of July, 2025

Plaintiff Name and Phone Number:
- Theresa Hrow Ahwaih
- Phone #: (554)-4014
Plaintiff Availability: EU & early NA hours.

Attorney Name and Phone Number:
- Annabelle Celestine
- Phone #: (555)-1328
Attorney Availability: EU & early NA hours.

Defendant:
- San Andreas State Prison Authority

Incident Date: 29th of June, 2025
Date of Service: 4th of July, 2025
Name of Person Served: SASPA Command Members

Name of Person Serving: Annabelle Celestine
Phone of Person Serving: (555)-1328

Reason for Suit:

On the 29th of June, following an arrest (#37780) on Miss Theresa Ahwaih by Deputy-999, France Gall of the Blaine County Sheriff’s Office, a horrible fate has befallen the plaintiff.

Rather than the expected incarceration for a duration of 15 months within the Bolingbroke Penitentiary, Miss Ahwaih found herself shoved into and locked behind the metal bars of a single cell within the State Penitentiary. Confusion settled into panic as no answer to her cries came. Out of options and defeated, Miss Ahwaih reached out to Annabelle Celestine (myself), informing of the situation, and said information of this horrific experience and obstruction of my client’s freedom was passed down to the arresting officer (Deputy F. Gall) which responded to the 911 call and decided to take time out of her busy day to help out.

Upon arrival on the scene of the Prison Cell Block, Deputy Gall found the plaintiff locked away behind tightly closed doors of the cell, noting additionally how many cells on the Block’s floor were also locked away.

Sadly, the help could not come any sooner, and Miss Theresa was forced to spend the entirety of her sentence with the freedom offered to all of the Bolingbroke inmates, forcefully removed.

Whole 15 months with nothing more than dreams of feeling the breeze of the prison courtyard, the taste of the canteen’s famous Pizza Soup, or simply the ability to visit the medical wing in case of an emergency.

No, due to the negligence of the Department of Corrections, known as the San Andreas State Prison Authority, my client has suffered extreme violations to her freedom and comfort, which will be the issue of the case, as the plaintiff is pursuing the following torts and damages associated with them:

1x Constitutional Rights Violation
$500,000 - (Violation of the 4th and 8th Amendment)
1x Negligence & Infliction of Emotional Distress
$150,000 - (Negligence)
$100,000 - (Infliction of Emotional Distress)
1x Legal Fees associated
$50,000 (Representation)
$2,000 (Filing Fee)
1x Punitive Damages
$100,000

In-depth explanation for each item on the list:

Constitutional Rights Violation:
Violation of the 4th amendment - Miss Theresa Ahwaih was sentenced to 15 months at Bolingbroke Penitentiary, but was instead locked in an isolated cell with no access to yard time, medical care, or basic inmate rights. This confinement went beyond the scope of her lawful sentence and amounted to an unlawful and unreasonable seizure of her person. By detaining her in these conditions without legal justification, the State violated her Fourth Amendment right to be free from arbitrary imprisonment.
Violation of the 8th amendment - Miss Theresa Ahwaih was subjected to harsh and inhumane conditions after being locked in isolation for her entire sentence, without access to yard time, medical care, or basic necessities afforded to other inmates. This prolonged deprivation caused undue suffering and emotional distress. By failing to provide humane treatment and adequate conditions, the State violated her Eighth Amendment protection against cruel and unusual punishment.

Negligence & Infliction of Emotional Distress:
Negligence - The Department of Corrections failed to ensure Miss Ahwaih was housed properly and safely, breaching their duty of care. This failure directly led to her unjust confinement and suffering.
Infliction of Emotional Distress - The Department’s actions caused Miss Ahwaih to endure extreme isolation and psychological harm, resulting in severe emotional distress that could have been avoided with proper oversight.

Legal Fees associated:
Filing Fee - Necessary cost to initiate this legal action caused by the defendant’s misconduct.
Legal Representation - Due to the complexity of suing a government agency and the seriousness of the rights violations, the plaintiff required private counsel. This cost reflects the necessary legal work caused directly by the defendant’s misconduct.

LIST OF ALL EVIDENCE:
1A - Photo from inside of LOCKED CELL
1B - Photo of LOCKED CELL (from outside)
2A - Arrest Report #37780 [1/2] [2/2]
3A - Proof of Service Happy 4th of July!
3B - Service Letter
3C - Proof of Filing Fee

Witness List:

Theresa Hrow Ahwaih
Deputy France Gall of the BCSO

respectfully submitted,
Annabelle Celestine, representing Theresa Hrow Ahwaih