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To:
Indiana Attorney General
Indiana Bureau of Motor Vehicles

Re: Notice of Tort Claim pursuant to Indiana Code 34-13-3

Claimant: Robbin Stewart
Address: POB 29164 Cumberland IN 46229
Date of Incident: February 17, 2026
Time: Approximately 3:00 PM
Location: BMV Branch, East Washington Street, Marion County, Indiana

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1. Introduction

This correspondence serves as formal Notice of Tort Claim under Indiana Code 34-13-3 arising from events occurring on February 17, 2026 at the BMV branch on East Washington Street, Marion County, Indiana.

Claimant is an individual with a disability resulting from a 2015 automobile accident. Due to injury, Claimant signs legal documents using an “X.”

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2. Factual Summary

1 The clerk, and then her supervisor CC, Jane Doe #2, refused to allow me to sign the document with my signature, an x. They made up some rule about only the illiterate  may sign that way, which A) isn't true B) is none of their business C) would probably be unlawful if that was the rule. This was denial of service. Possibly a breach of contract since by then they had accepted my $9.40. 

2 A BMV employee (Jane Doe #1) refused this request, incorrectly stating that an “X” may only be used by those who cannot write. This was false and inconsistent with ADA requirements. I was in process of requesting a copy of this policy when I was attacked by the guard. 

Her supervisor cc (Jane Doe #2) backed her up, lectured me for awhile, then called for the guard to eject me. While she did not touch me herself, if there was a battery, she was complicit in it. 

3. Claimant requested a reasonable accommodation under the Americans with Disabilities Act (ADA Title II) to allow use of their established signature mark (“X”).

4. Claimant requested a public record documenting the visit and the ADA denial. Instead of providing it, Claimant was directed to leave the premises.

5. Claimant did not comply immediately because they were attempting to document the incident.

6.  A security officer John Doe #1 (name unknown) then intentionally made contact on four separate occasions, including:

   Forcibly removing Claimant’s camera, prying the camera away from Claimant’s hands;

 Lifted him up out of his chair.

Striking Claimant’s chest to prevent them from sitting;

Struck him on the left arm. 

These contacts constitute battery under Indiana law (rude, angry, or insolent touching). The contacts were offensive, not other injurious.

7.    Responding officers, acting in their official capacity, interfered with Claimant’s ability to document the incident and obtain copies of public records, after directing Claimant to leave and failing to take a promised report.

8.    Upon information and belief, the actions described were undertaken pursuant to inadequate training, supervision, or policies regarding ADA compliance, use of force, and handling of public records.

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3. Legal Basis

The events described constitute:

• Battery under Indiana law (intentional rude, angry, or insolent touching).

  Assault 

• Negligent supervision and training of employees and security contractors.

• ADA Title II violations: denial of reasonable accommodation and retaliation.

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4. Damages

As a direct and proximate result of these events, Claimant has suffered:

• Offensive physical contact 

• Emotional distress and humiliation

• Denial of public services

• Interference with federally protected rights

• Inability to document evidence

The full extent of damages continues to be evaluated.

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5. Preservation / Litigation Hold

Claimant hereby demands that the following evidence be preserved:

• Interior and exterior surveillance video

• Body camera footage of responding officers

• Incident reports and employee communications

• Public records related to the visit and ADA request

• Security contractor policies and contracts

• Employee training materials regarding ADA compliance and use of force

Destruction or alteration of this evidence may give rise to additional claims.

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6. Notice Compliance

This notice is provided within the statutory time period required by Indiana Code 34-13-3 and is intended to preserve Claimant’s right to pursue claims related to the incident.

7. Claims: Claimant offers to settle this for $7000. This offer is withdrawn if not accepted in principle w/i 10 days, with payout within 40 days.

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Sincerely,
Robbin Stewart /s/x.

2/18/2026

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✅ This draft is ready to send via certified mail to:

• Indiana Attorney General

• Indiana Bureau of Motor Vehicles (BMV)

It accurately preserves: