911 calls made in HS toddler death still withheld, suit filed against police chief

IN THE CIRCUIT COURT OF GARLAND COUNTY, ARKANSASDIVISION

MATTHEW CAMPBELL PLAINTIFF

V. Case No.:

CHIEF DAVID FLORY, in his official capacity DEFENDANTas custodian of certain records

AFOIA COMPLAINT AND REQUEST FOR HEARING

The plaintiff, Matthew Campbell, brings this appeal from denial of rights

under the Arkansas Freedom of Information Act ("AFOIA"), ArkCodeAnn. §§

25-19-101 through -110, and, in support thereof, he states:

Parties, Jurisdiction, and Venue

1. PlaintiffMatthew Campbell is an adult citizen of the State of Arkansas,

and he brings this appeal as a matter of right under Ark. Code Ann. § 25-

19-107, as he requested specific public records, which Defendant refused

to provide, entitlingPlaintiffto a hearingin this Court. SeeArk. Code Ann.

§ 25-19-107(b); see also Orsini v. State, 340Ark. 665,13 S.W.3d 167 (2000).

2. Defendant David Flory is the Chief of Police for the Hot Springs Police

Department ("HSPD"), andhe is suedin his official capacity.

3. The HSPD is an agency, department, branch, or similar entity of the City

of Hot Springs, Arkansas, which is itself a municipal corporation formed

under the laws of the State of Arkansas located in whole or in part within

the geographical boundaries of GarlandCounty, Arkansas.

Campbell v.PloryComplaint&Req. for Hrg.

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