First Internal Affairs Complaint

The Players

I, Marc Perkel am a Springfield resident. I am the 1998 Democratic Candidate for the United States House of Representatives in the 7th district of Missouri. I am a computer programmer and electronic technician and I have an extensive web site with over 35,000 web pages that include law libraries, computer technical information, political opinion, and my congressional web site. My political opinion includes "People before Lawyers" which advocates judicial ethics and the elimination of self regulation of the courts. The site contains over 100 pages of legal briefs I have filed as a pro se lawyer. I am a law abiding upstanding member of the Springfield community with no criminal background. I don't even have any points on my drivers license.

I am an advocate for the decriminalization of prostitution and have written web pages on the subject. Also included is an extensive legal brief dealing in detail with legal definitions of prostitution and its relation to the escort service business.

I have a friend who has been charged with promoting prostitution. I have helped bail him out of jail and appeared with him in court and have helped his counsel do legal research and suggest defensive strategies. I have been present and privy to confidential conversations between him and his lawyer. Information that Officer Hollie wants to know.

Kevin Hollie is a police officer working for the City of Springfield and is investigating my friend who is accused of being in the escort service business.

The Arrest

On September 8th 1998 at approximately 10:30 p.m., Officer Kevin Hollie and the second police officer arrested me at my home. I was sitting on the sofa watching television when I heard a knock on the door. I opened the door and recognized Officer Hollie. I stepped out onto the porch and closed the door behind me. Officer Hollie informed me that he was here to arrest me. I responded, "for what?" and he replied "trespassing". I laughed at him. I asked him where I was supposedly trespassing and he refused to tell me where I trespassed and who made the complaint.

I asked him to show me the arrest warrant. He had a metal covered form pad and flipped it open for less than one second. What little I saw looked like a traffic ticket that was partially filled out. I told officer Hollie that I wanted to read the warrant and he wouldn't let me. I informed Officer Hollie that what he appeared to have wasn't a legal arrest warrant and I wanted to read it. He refused. It was clear to me that it appeared that Officer Hollie knew that his paperwork didn't constitute a proper document for which to make an arrest. I asked him what judge issued the warrant and he said there wasn't a judge involved. He explained that he had the right to arrest me using some name of a procedure that I don't remember and wasn't familiar with. I continued to insist that the arrest was illegal. There was no doubt in my mind that he knew that what he was doing was wrong.

I again demanded to know where I was supposedly trespassing and who made the complaint. The officers refused to answer. They asked me to step into the house. I refused. I told them that I did not want them in my house. They again repeated that they wanted me to go into my house and I asked them if they had a search warrant. They indicated they did not. I told them that they were not to go into my house. They told me to put my hands behind my back and turn around. I complied.

They then handcuffed me behind my back. At that point both officers opened the door, pushing their way past me, and entered the house. I followed them in yelling at them telling them to get out of the house and that they had no right to search my house. They said that they wanted to make sure there wasn't anyone else in the house with a gun. They walked through every room and opened only a few drawers. Their search lasted only a few minutes and I didn't see them take anything. I was never read my rights; however, I never answered any of their questions.

I had asked for my shoes and I turned off the television using my nose. I was then led to an unmarked car to be transported to the city jail. On the way to the car Officer Hollie indicated that he was interested in information relating to my friends case and that jail could be avoided if I were willing to talk. He didn't ask me anything specific and I indicated that there was no chance that we were going to have a conversation about anything. I was then put in the front seat of the unmarked car and taken to the city police station.

The Booking

I was taken into the police station. They emptied my pockets and searched me. I had my wallet and slightly over $200 on me. I remember there being two officers in a caged area where the paperwork was processed. I announced loudly that I wanted to see the paperwork that I was being arrested on. They said I could see it later. I insisted on seeing it now and said that all I was told was that I had been charged with trespassing. I didn't know what address I was accused of trespassing on nor who filed a complaint against me.

One of the officers went through my wallet looking for my drivers license. They then handed it to me and I found it. I was uncuffed by then. I was then questioned about information having to do with filling out the paperwork. After filling out the paperwork I was put into the drunk tank with six other men. I want not allowed to make a phone call or post bail. I didn't even know how much the bail was. After about 10 minutes or so Officer Hollie opened the window of the cell and said the address where I supposedly trespassed. He did not tell me the name of the person who made the complaint. I did not recognize the address. He again asked if I wanted to talk and held what looked like a cassette tape up to the window and said that he had me on tape. I declined his invitation and he said he was leaving for the night.

The Jail

Jail is an interesting experience. We started out with six and ended up with ten of us by morning. It was a room about 15 x 15 with one toilet that doesn't flush. The top of the toilet had a water fountain that barely worked. It was cold and it had one metal bench across the back big enough for about three people to lay down on. Everyone else, including me had to sit or lay on the floor. The floor was dirty and the walls had old blood stains and appeared to not have been cleaned for a long time. The jail was disgraceful and the City of Springfield should not only be ashamed of it, but should do something to avoid liability as a health risk.

I was locked up with a variety of people. One guy was a felon who wasn't having a very good time at all. He was angry and beat on the door and yelled obscenities at the cops who didn't appear to feel particularly threatened. Another guy was in on a bad check charge. Apparently his ex-wife had cleaned out his checking account and he bounced two checks for $180 and was arrested for it. He seemed to think there was plenty of jail space and didn't know why they weren't using it. They had him in a cell where there was a bed and removed him and another guy to put them in the drunk tank as he tells it.

Another guy was wearing a tank top and was really cold. He asked several times for a shirt but the guards refused to give him one. I tried to sleep but I couldn't get comfortable on a concrete floor. Most everyone else managed to sleep. In fact, it seemed that sleeping was the way people passed time. It was as if that's the only way to shut off what was happening in the real world.

Eventually someone came in with some food. Breakfast was a microwaved sausage egg biscuit like what you would find at a convenience store and a red room temperature drink that I think was Hi C. I wasn't hungry or thirsty and wasn't ready to eat grease thinking the smell from the toilet would cause me to vomit, so I gave my meal to someone who was hungrier than I was. About a half hour later the toilet flushed and I declared it the start of a new day.

Bonding Out

At 9:00 a guard came in and asked if anyone needed to make a phone call. I said yes and he let me out. I was asking about the procedures to make a call when he asked if I had $100 on me. I said I did when I came in. He informed me that my bond was $100 and asked me if I wanted to bond out. I said "sure". He then said that I could have bonded out the night before. I commented that I didn't know that, but I doubted that was in the plan. The morning officer was very nice to me. They then filled out the paperwork, took my picture, and released me. I walked home.

The Trespassing Complaint

In the morning when I was released I got to see for the first time the charges against me. The trespass supposedly occurred at 934 E. Cherokee, the address of Shirley Ann Montgomery who I know as "Ann". The complaint was on the same form as a traffic ticket and titled "Missouri Uniform Complaint and Summons". It's a municipal court ticket. Under the section "Described Violation" it says, "Trespassing - Remained unlawfully at the residence of Shirley Montgomery after being told not to return 3 wks. Previous". There is a box not filled in where a person normally signs the ticket when they are not arrested promising to appear at the given date, in this case 09-24-98. The part where the prosecutor signs is blank. No where on the form is a signature of Ann who is the one supposedly making the complaint.

Who is Ann

Ann worked as a phone operator for Centerfold Escorts. Several months ago she told a mutual friend she was interested in buying a computer to surf the web. He told her about me saying that I went through a lot of computers and a lot of my used computers are very up to date.

Ann called me and I said I had a used computer I could sell for $850 loaded with everything she needed. She was originally supposed to get it in June but fell ill. I held onto it for her.

In early August, after her friend had been arrested for Second Degree Promotion of Prostitution, I dropped by her house to ask her if she still wanted the computer. She invited me in. Of all those who got busted, it was unusual that she wasn't one of them. She felt the need to explain to me that she hadn't made any deal with the cops and talk about her friend's case. I wasn't interested in discussing it with her other than saying that he was fine. We talked about other friends we both knew. She said that she still wanted the computer and said that she would have the money in a few weeks. I said I'd try to hang onto it but if someone else wanted it I'd call her first.

On or around September 5th 1998 I came back to see if Ann still wanted the computer. She changed phone numbers and I didn't have her new number. I knew by then due to evidence disclosed that she had made recorded statements to the police. I had also heard rumors that she had started her own escort service and that she had a partnership arrangement with Officer Hollie. I had no actual knowledge if these rumors were true. In spite of all this I'm not involved in these escort businesses myself and I had a computer to sell and wanted to find out if she still wanted it. Her daughter, who I know as "Dee" answered the door. I asked if Ann was home. Dee asked me what I wanted with her. I said I wanted to know if she still wanted the computer. She said that Ann didn't want it and that she thought someone had sent me and told me to leave. I immediately left.

Ulterior Motive?

I also wanted to express my concerns to Ann that if what I had heard was true, that she was running an escort service, that what she was doing might be against the law and she could get in trouble even though she was operating in a partnership with the Springfield Police Department. I personally don't consider the Springfield police to be safe and reliable as partners in the escort business and wanted to recommend the virtues of obeying the law.

I also have a twisted sense of humor and I found the idea amusing that the police and prosecutors, who are making in my opinion an election year raid on prostitution, are getting into the prostitution business themselves. People who know me know that I think it's funny and can't help but to laugh at the idea that the same cops who are "cleaning up prostitution in Springfield" are running a whorehouse. What a world, what a world!

If this is true then the citizens of Springfield can rest assured that their latest law enforcement tax increase is hard at work. I have been criticized for my views on legalizing prostitution, which stem from my belief that when you prosecute prostitutes that it only moves the prostitution. I believe that the formula that Women + Poverty = Prostitution always holds true even under strict law enforcement. In fact law enforcement usually increases prostitution because when a woman gets busted, she has to do more tricks to pay her legal bills and fines. And the tricks are often more dangerous resulting in women getting hurt.

If you bust whorehouses you get escort services. If you bust escort services you get street walkers and women hanging out at hotels and bars doing more tricks for less money. If this law enforcement money were spent on drug rehabilitation, day care, and job training the number of prostitutes would reduce especially among those who sell themselves out of need than by choice. And the ones who are doing it because they want to are doing the same things that are legal to do for free. The crime therefore is not the sex act but the price, and the government shouldn't be in the business of pricing sex.

Although my views are not popular among those who are running for office, I am right about this and I have the satisfaction, for what it's worth, of saying I told you so.

Filing a Complaint

I am in the process of preparing a complaint against these police officers. I had an informal conversation with the internal affairs officer, a man named Joe, who was very nice to me. He gave me a packet of forms to fill out and encouraged me to file a written complaint because they are easier to process. He also got the arrest record and there was at that time neither a warrant for my arrest nor a complaint from Ann indicating that she initiated the complaint against me. Joe appeared to be concerned about this. I believe that it is likely that Officer Hollie, who might be acting as a partner with Ann, initiated the complaint and that Ann might not even know about it. I believe it is also likely that a signed complaint might appear having been generated after the arrest in order for Officer Hollie to cover his tracks and make the arrest appear to be legitimate.

I have been informed by several people about something that disturbs me about filing a complaint. I have been told that I can be sued for filing an internal affairs complaint. In fact I've been informed that a local attorney, Richard Crites, files a lot of lawsuits against people who file internal affairs complaints I'm told and that I'm likely to be sued if I complain.

I find that the idea that someone can be sued for filing an internal affairs complaint against an officer to be very disturbing. This would discourage people like myself who have and are being harassed by the police to keep quiet and let them get away with it. It gives one the impression that we live in a "police state" where the police do whatever they want and rule the citizens through terrorism rather than "To Protect and to Serve". I'm amazed that citizens don't have immunity from suit for filing a police complaint.

Scary Thoughts

The thing that scares me the most about this situation is if the acts of Kevin Hollie are determined to be legal. Although I don't affiliate myself with any religion now, I was raised Jewish and I was raised in a city where there were a lot of Jews who had the numbers tattooed on their arms. I remember hearing stories about the "knock on the door in the middle of the night" where they would come for you and haul you away.

Suppose a cop sees you driving without a seat belt or you fail to use your turn signals when changing lanes. Then he comes to your door late at night, arrests you, and hauls you off to jail. Then they keep you in the drunk tank all night with convicted felons who are screaming and kicking at the door. Do we condone the police torturing people for information when they are doing an investigation? Is that legal in Springfield? If that's legal, that scares the hell out of me. The idea that this could possibly be legal shocks the conscience.

I also fear that this isn't the last of this, that Kevin Hollie will continue to show up at night and arrest me. He has done this with other people and I can only assume that he's going to continue to do this with me unless he's stopped. And if he can do this to me as an upstanding citizen and a congressional candidate, he can do this to anyone. This must stop now.

Iím not the only one

These following accounts are from what I heard directly. This is second hand and should be filtered as such. Some of the details may not be exact, but the point is that Kevin Hollie and his gang of rough cops are breaking the law and need to be stopped.

Kevin Hollie has harassed a lot of people the same way he harassed me. Kevin Hollie has been harassing Andrea. Andrea is under a court order that prohibits her from talking to Kevin Hollie and other stateís witnesses. She also has medical problems dealing with a difficult pregnancy. Nonetheless, Kevin Hollie has come to her door many times trying to ask her questions. He comes in the night and shines lights through her windows and lets her dog out and threatens to shoot it.

Another woman who I talked to told me Hollie came to her room with no warrant and arrested her taking about $400 of her money and keeping it. The arrest was over some minor traffic infraction.

These are but two other examples. There are several more but Iíll leave them for the investigators. I know of about ten people who have been harassed and continue to be harassed and will come forward only if it is safe to do so. My point is that this is not an isolated incident, but rather an ongoing problem.

It's not just one officer

This isn't only Kevin Hollie. There are several other officers who are doing this too. Some of my friends who have been hassled by the police in this manner have reported being awakened in the middle of the night by up to four officers, threatened, interrogated, and arrested if they didn't cooperate.

Trespassing charge against me

I don't know if the city is going to try to press this trespassing charge against me or not. I think it would be interesting to represent myself in a criminal case. If or when formal charges are filed against me, I will have the power and authority of the courts to issue subpoenas and depose witnesses. Then we'll find out what's going on.

What I Want

I want the City of Springfield, The Police Department, and the Internal affairs department to look into these allegations and take the necessary steps to correct the problem. If the allegations herein are true then Kevin Hollie, and other officers who are doing the same things, should be dismissed, reprimanded, suspended, demoted, or retrained in order to restore the integrity of the Police Department. Since this incident is part of a pattern of incidents I think that we need to investigate the management that is coordinating this effort. I think it is likely that what is happening is a result of bad examples from the top. Perhaps Kevin Hollie and others are only doing what they are told to do and what they have been trained by example to be proper police conduct. I wouldn't want to see good officers, and Officer Hollie may well be a good officer, lose their jobs or be punished for something they had legitimate reasons to believe were proper.

I also want the government and politicians to quit picking on whores in order to make themselves look good in an election year. I personally don't find the persecution of helpless women an inducement to making me want to vote. I think the community would be better served if the prosecutors concentrated on chasing crooks than chasing skirts. My neighborhood is crawling with crack dealers and the cops do nothing about it.

Further Reading and Contact Info

This document can be found online at My People before Lawyers web page if My main index is My legal brief arguing that escort services is not prostitution is at I can be reached at 866-1222.


I do not have any direct knowledge that the Springfield Police Department is running an escort service. As I have stated and tried to make clear these are rumors that I have heard from sources I consider reliable. I also have a business card from something called "Night Moves". The phone number for Night Moves is 417-887-6115. I make the statements out of concern that if this is true, that it would be prudent for Springfield to take immediate action to stop it. As a citizen of Springfield I feel it is my duty to inform the city when I have cause to believe that the city may be in the same business that they are putting people in jail for.

I have before me a document titled "Springfield Police Department Internal Affairs Complaint Procedure". It opens with some high minded civil rights language that includes this statement: "We take seriously the Department's obligations to uphold your guaranteed rights and freedoms. It is one of our highest priorities to ensure that every employee performs his/her job task in a professional manner under all circumstances. Please feel free to contact our department if you have knowledge of a department member's conduct which you believe is inappropriate or if you wish to commend the actions of any police employee."

Based on this statement and other factors, I would warn that any lawyer attempting to sue me over this complaint might be countersued by me personally. Unlike other lawyers in Springfield who won't sue other lawyers, I have no such limitations. I encourage any lawyer who feels like taking me on to read my People before Lawyers web page and take a good look at what you're up against. If what I'm hearing is true, I welcome the opportunity to prove that a person has a Constitutional right to immunity to file a complaint against a police officer. I look forward to arguing the case.

I hereby certify that the statements given by me herein are true and accurate to the best of my personal knowledge. I understand that making intentional false declarations to public servants or untrue statements under oath or affirmation may be punishable by law.


Marc Perkel * 09-11-98


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