Mother Claims She Called Sheriffs to Split Up Fight Between Her Daughter and Son-in-Law -- Officers Instead Shoot Them Both to Death
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"In response to witnessing his wife being shot Robert Prine became hysterical. As he ran towards his wife's body screaming and unarmed he was shot and killed by the defendants Dubus, [Deputy Mark] Ceravalo and Powell.
"At no time did Robert Prine ever threaten any of the defendant deputies with any weapon.
"As a result of being shot by the defendant deputies, Dubus, Powell, Barran and Newsom, Deborah Prine endured pre-death mental and physical pain and suffering.
"As a result of being shot by the defendant deputies, Dubus, Powell and Ceravolo, Robert Prine endured pre-death mental and physical pain and suffering.
"All of the above was witnessed by Deborah Prine's mother, the plaintiff, Doyle, who stood behind the defendant deputies when the shootings occurred.
"At the time of the killings Doyle was talking on the telephone to the plaintiffs, Heather Prine and Karen Prine, the daughters of Deborah and Robert Prine, who although not present could hear their grandmother plead with the police not to kill Deborah Prine.
"Heather Prine and Karen Prine heard the gunshots that killed their mother and father and listened to their grandmother's hysterical reaction to the events as they occurred.
"As a result of witnessing her daughter and son-in-law's killing, the plaintiff, Patricia Doyle, sustained severe, debilitating and foreseeable mental anguish and/or emotional distress.
"As a result of hearing their grandmother contemporaneously describe the killing of their mother and father by the defendant deputies, and hearing the fatal gunshots, the plaintiffs, Heather Prine and Karen Prine, sustained severe, debilitating and foreseeable mental anguish and/or emotional distress.
"Immediately after the shootings, the defendant deputies, except for Sheriff Tregre, in concert with one another, conspired and concocted a false version of the shooting of Deborah and Robert Prine in order to justify the Prines' deaths and in order to protect themselves from discipline and future legal action for their negligent and/or intentional wrongdoing. These conspiratorial acts on the part of the defendants to cover up their wrongdoing included planting a knife and fork on Robert Prine in order to support their claims that he was armed when he was shot and fabricating a claim that Deborah Prine manipulated the bolt of her rifle and pointed it at the deputies.
"Additional specific misrepresentations fabricated by the defendants as part of the conspiracy include the claims by Dubus, [Deputy Matthew] Woodruff, Barran,
Ceravolo, Powell, [Det. Maurice] Rodriguez, Newsom, [Det. Michael] Shard and [Deputy Victor] Campuzano that Doyle told them that Robert Prine hit Doyle and threatened to stab Doyle, that Deborah Prine had told Doyle she was going to shoot deputies, that Robert Prine verbally threatened to kill the defendant deputies, that Robert and Deborah Prine were on the porch fighting over control of the rifle, that Deborah Prine continually pointed the gun at the defendant deputies, and that after the shooting Robert Prine jumped onto his wife's body then returned to the house only to then run back out of the house toward the deputies with a shiny object, knife and/or fork, in his hand threatening to kill the deputies.
"After shooting Deborah Prine and Robert Prine to death, the defendant deputies worked individually, together and in concert, to concoct these false claims. Further, they conspired with one another and other unknown deputies or employees of Sheriff Tregre to cover up their illegal use of deadly and excessive force. This conspiracy included the making of false statements and preparing false reports by all of the named defendants which include claims identified in paragraphs 27 and 28. [The two paragraphs immediately before this one.] Additionally, these defendants fabricated evidence and failed to collect and/or destroyed or ignored exculpatory evidence including witness' statements and committed other acts to make it appear that their actions were justified.