Under Minnesota law, civil plaintiffs are not allowed to request punitive damages when they file a complaint (lawsuit). They are required, instead, to request permission from the court to add a claim for punitive damages after the complaint has been filed. The request (motion) must include affidavits that provide clear and convincing prima facie evidence that the defendant showed a deliberate disregard for the rights or safety of others (see Minn. Stat. § 549.191).
I requested a hearing on such a motion, scheduled for Tuesday, November 3rd, 2009. Below is a redacted version of my memorandum of law in support of the motion (the exhibits are not included).
A response was served by counsel for Boris Parker, Bassford Remele, and Saliterman & Siefferman (Paul Peterson, Esq.). In brief, they argue my evidence does not amount to prima facie clear and convincing evidence that the Parker Defendants had a willful disregard for the rights of others.
I wrote a reply brief, linked to below (again, exhibits are not included).