Third Circuit: Emil Jutrowski v. Township of Riverdale

Although a plaintiff in a S1983 suit needs to be able to identify the law enforcement officer who injured him in order to present an issue for trial, an allegation of after-the-fact conspiracy supported by omissions or inconsistencies in contemporaneous records can present an issue for trial on the same facts.

http://www2.ca3.uscourts.gov/opinarch/172594p.pdf