Case :-cv-00-l-jma Document Filed /0/ PageID. Page of Gastone Bebi, SBN THE LAW OFFICES OF GASTONE BEBI 0 West Broadway Avenue, Suite 0 San Diego, California Telephone: --0 Facsimile: -- E-Mail: bebilaw@aol.com Attorneys for Plaintiff, MARCO AMARAL 0 MARCO AMARAL, v. UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA Plaintiffs, CITY OF SAN DIEGO, SHELLEY ZIMMERMAN, FNU WILLIAMS, an individual, and DOES -, inclusive Defendant. CASE NO: 'CV0 L JMA FOR: ( UNLAWFUL DETENTION ( U.S.C. ( EXCESSIVE FORCE ( U.S.C. ( ARREST WITHOUT PROBABLE CAUSE ( U.S.C. ( FALSE IMPRISONMENT ( U.S.C. ( ASSAULT ( BATTERY ( INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS ( NEGLIGENCE ( FAILURE TO PROPERLY SCREEN AND HIRE ( FAILURE TO PROPERLY TRAIN ( FAILURE TO SUPERVISE AND DISCIPLINE ( MONELL LIABILITY FOR A PATTERN OF BRUTALITY ( VIOLATION OF CALIFORNIA CIVIL CODE. JURY TRIAL IS HEREBY DEMANDED
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 Plaintiff MARCO AMORAL, by and through his attorneys of record, hereby demand Trial by Jury and, allege and complain as follows: INTRODUCTION. On November, 0, Marco Amoral, observed approximately four San Diego Police Officers on top of and beating a prone man who had been part of an anti-trump protest near th and C street in San Diego, CA. Mr. Amaral shouted several times for the police to stop hurting this man.. Suddenly, and without warning or provocation, Mr. Amaral was blindsided and tackled by defendant San Diego police officer, FNU Williams. Defendant Williams tackled Mr. Amaral so hard that his body was thrown into a parking lot near to where plaintiff had been standing. The tackle causing plaintiff to hit his head, and lose consciousness.. The police officers took Mr. Amaral s home and car keys and Mr. Amaral was then placed in the back of a police car. His ribs, collar and head hurt. Mr. Amaral drifted in and out of consciousness, but eventually kicked at the police door asking for medical attention.. Mr. Amaral continued to drift in and out of consciousness, but estimates it took over one hour before the unknown police officers called for medical assistance for Mr. Amaral.. Eventually, an unknown police officer opened the police car door and ordered Mr. Amaral to get out of the vehicle. Mr. Amaral explained that he needed
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 help to physically exit the vehicle. Eventually he was given assistance, and exited the car. Due to recently having had surgery on his left knee, he could only bear weight on his right leg. Mr. Amaral was forced to stand on one leg for approximately 0 minutes when he again lost consciousness and fell. Unknown police officer(s then began screaming at him to get up, and demanding to know why he fell. Eventually he was ordered to remain on the ground.. Mr. Amaral estimates that approximately. hours passed before an ambulance arrived. He was thereafter transported to Sharp Hospital in San Diego where he received treatment for his injuries, which included a concussion, broken collar bone, and bruised ribs. GENERAL ALLEGATIONS. Jurisdiction is proper in the United States District Court for the Southern District of California pursuant to U.S.C. and U.S.C. ( and (, et. seq.. This Court has supplemental jurisdiction over the pendent state law claims under U.S.C. (a.. Venue is proper in the Southern District of California because the acts or omissions which form the basis of the Plaintiff s claims occurred in San Diego, California, within the Southern District.. Plaintiff has complied with Government Code 00 et seq.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 PARTIES. At all times relevant to this complaint, Plaintiff was an individual residing in San Diego County, California.. At all times relevant to this complaint, Defendant FNU WILLIAMS was an individual believed to reside in San Diego County, California.. At all times relevant to this complaint, Defendant SHELLEY ZIMMERMAN was the chief of San Diego Police Department and a policy-maker.. At all times relevant to this complaint, Defendant San Diego was a municipal corporation operating in San Diego County, California and operating the San Diego Police Department and employing the individual defendant officers, who were acting within the scope of their employment.. Plaintiff is truly ignorant of the true names and capacities of DOES through, inclusive, and/or is truly ignorant of the facts giving rise to their liability and will amend this complaint once their identities have been ascertained as well as the facts giving rise to their liability. FIRST CAUSE OF ACTION (Civil Rights Action ( U.S.C. Unlawful Stop and Detention against Defendants Williams and Does -]. Plaintiff realleges all prior paragraphs of this complaint and incorporates. U.S.C. provides in part: Every person who, under color of any statute, ordinance,
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 regulation, custom, or usage of any State or Territory subjects, or causes to be subjected, any person of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws shall be liable to the party injured in an action at law, suit at equity or other proper proceeding for redress.. Plaintiff had a firmly established right under the Fourth Amendment to be free from unreasonable seizure. 0. A detention without reasonable suspicion that a citizen has committed a crime violates the Fourth Amendment prohibition on unreasonable searches and seizure.. A police officer may stop and briefly detain a citizen based on a reasonable suspicion of involvement in a crime.. Plaintiffs had committed no criminal offense or a traffic offense when Williams initiated the stop and no charges were ever brought against plaintiff.. Defendants knew that there was no basis for a stop.. Defendants acted unreasonably in stopping by plaintiff by tackling and rendering him unconscious, subjecting him to a prolonged investigatory detention when they had no reason to suspect that plaintiff had engaged in illegal activity.. As a result of Defendants actions, Plaintiff suffered damages in the amount to be proven at trial. SECOND CAUSE OF ACTION [Civil Rights Action ( U.S.C. Excessive Force against Defendants Williams and Does -0
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. Plaintiff realleges all prior paragraphs of this complaint and incorporates. Plaintiffs had a firmly established right under the Fourth Amendment to be free from official infliction of physical abuse, assault, battery, and intentional infliction of emotional distress.. Plaintiffs had a firmly established right to be free from excessive force being used against them.. On November, 0, Plaintiff posed no threat to Defendants when they used excessive force. 0. There was no basis for the initial stop or the detention that followed.. There was no need for use of any force in this situation because there was no probable cause for an arrest.. The use of force in tackling to the pavement a peaceful, unarmed pedestrian was unnecessary and excessive.. Defendants acted under color of state law in violating Plaintiff s rights.. Defendants were acting in purported compliance with a policy promulgated by the San Diego Police Department, in using force against citizens who had broken no law.. During the relevant period, defendants were acting under color and pretense of law, to wit: under color of the statutes, ordinances, regulations, customs and usages of the State of California and the City of San Diego.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. Defendants, acting under the color of statute, ordinances, regulations, customs and usages of the State, knew that use of force in these circumstances was illegal under clearly established law.. The conduct alleged herein caused Plaintiff to be deprived of his civil rights that are protected under the United States Constitution which has also legally, proximately, foreseeably and actually caused Plaintiffs to suffer physical injury, emotional distress, pain and suffering, and further damages according to proof at the time of trial.. The conduct alleged herein was done in deliberate or reckless disregard of and plaintiff s constitutionally protected rights; justifying the award of exemplary damages against defendant officers in an amount according to proof at the time of trial in order to deter the defendant from engaging in similar conduct and to make an example by way of monetary punishment.. Plaintiff is also entitled to attorney fees and costs of suit herein. THIRD CAUSE OF ACTION (Civil Rights Action ( U.S.C. False Arrest against Defendants Williams and Does -] 0. Plaintiff realleges all prior paragraphs of this complaint and incorporates. Plaintiffs had a firmly established right under the Fourth Amendment to be free from arrest without probable cause. Defendants arrested Plaintiff without a warrant despite the fact that he had committed no crime.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. Defendants were at this time performing their duties as officers for the defendant, City of San Diego.. During the relevant period, Defendants were acting under color and pretense of law, to wit: under color of the statutes, ordinances, regulations, customs and usages of the State of California and the City of San Diego.. The Defendants, separately and in concert, engaged in the illegal conduct to the injury of the Plaintiff, and deprived Plaintiff of the rights, privileges and immunities secured to Him by the Fourth Amendment to the Constitution of the United States and the laws of the United States. Defendants acted with callous disregard for the constitutionally protected rights of Plaintiff.. Plaintiff was subjected to humiliation, fear, and pain and suffering by the illegal acts of Defendants and suffered injuries as a result of the Defendants actions.. Plaintiff is entitled to compensatory damages, punitive damages, attorney s fees under U.S.C., and all applicable law, and such additional relief as the Court deems just. FOURTH CAUSE OF ACTION [Civil Rights Action ( U.S.C. False Imprisonment against Defendants Williams and Does -. Plaintiff realleges all prior paragraphs of this complaint and incorporates
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. Defendants unlawfully detained Plaintiff for an unreasonable period of time after they knew or should have known that they had committed no crimes.. False imprisonment is the nonconsensual, intentional confinement of a person, without lawful privilege, for an appreciable length of time, however short. 0. The conduct of Defendants also amounts to oppression, fraud or malice within the meaning of California Civil Code et seq. and punitive damages should be assessed against each defendant for the purpose of punishment and for the sake of example. 0. As a result of Defendants actions, Plaintiff suffered damages in the amount to be proven at trial. FIFTH CAUSE OF ACTION Assault against Defendants Williams and Does -. Plaintiff realleges all prior paragraphs of this complaint and incorporate. Defendants assaulted Mr. Amaral by intentionally placing him in imminent apprehension of physical violence.. Defendants acted with an intent to cause harmful or offensive contact with the Plaintiff and the intended harmful or offensive contact did in fact occur. 0. The harmful or offensive contact was not privileged nor consented to and was excessive, unreasonable and done with deliberate indifference to the rights and
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 safety of Plaintiff and was done with the intent to inflict punishment, above and beyond the reason for using the force in the first place.. As a result of the defendants intent to cause harmful or offensive contact with Plaintiff and the fact that the intended harmful or offensive contact did in fact occur, Plaintiff suffered damages according to proof at the time of trial.. Defendants conduct also amounts to oppression, fraud or malice and punitive damages should be assessed against them for the purpose of punishment and for the sake of example. SIXTH CAUSE OF ACTION Battery against Defendants Williams and Does -. Plaintiff realleges all prior paragraphs of this complaint and incorporate. Defendants acted with an intent to cause harmful or offensive contact with the Plaintiff and the intended harmful or offensive contact did in fact occur.. The harmful or offensive contact was not privileged nor consented to.. As a result of the Defendants intent to cause harmful or offensive contact with Plaintiff and the fact that the intended harmful or offensive contact did in fact occur, Plaintiff has suffered damages according to proof at the time of trial.. Defendants conduct also amounts to oppression, fraud or malice and punitive damages should be assessed against them for the purpose of punishment and for the sake of example.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 SEVENTH CAUSE OF ACTION Intentional Infliction of Emotional Distress Against Defendants Williams and Does -0. Plaintiff realleges all prior paragraphs of this complaint and incorporate. By engaging in the acts alleged herein, Defendants Williams and Does - engaged in outrageous conduct with an intent to or a reckless disregard of the probability of causing Plaintiff to suffer emotional distress. 0. As a direct, proximate and foreseeable result, Plaintiff suffered severe emotional distress and the outrageous conduct was the cause of the emotional distress suffered by Plaintiff.. The conduct of Defendants also amounts to oppression, fraud or malice and punitive damages should be assessed against Defendants for the purpose of punishment and for the sake of example. EIGHTH CAUSE OF ACTION Negligence against All Defendants. Plaintiff realleges all prior paragraphs of this complaint and incorporate. Defendants had a duty to Plaintiff to act with ordinary care and prudence so as not to cause harm or injury to another.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. By engaging in the acts alleged herein, Defendants Williams and Does - failed to act with ordinary care and breached their duty of care owed to Plaintiffs.. Defendants Zimmerman and City of San Diego failed to act with ordinary care in failing to properly train and supervise their officers with respect to proper procedures on detention and arrest of citizens; and the use of force in effectuating detentions and arrests.. As a direct, proximate and foreseeable result of defendants breach of their duty of care, Plaintiff has suffered damages in an amount according to proof at the time of trial. NINTH CAUSE OF ACTION (Civil Rights Action ( U.S.C. Against Defendants ZIMMERMAN, SAN DIEGO and Does -0 For Failure to Properly Screen and Hire. Plaintiff realleges all prior paragraphs of this complaint and incorporate. The defendants, City of San Diego, Chief Zimmerman, their agents, servants and employees failed to adequately and properly screen and hire the defendant employees.. The failure of these defendants to properly screen and hire the defendant police officers as a matter of policy, custom and practice, in the exercise of their functions, was deliberately indifferent to the constitutional rights of plaintiffs and
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 done with conscious disregard for the dangers of harm and injury to the plaintiff and others similarly situated.. Due to the acts of the defendants, the failure to properly screen and hire police officers and the continued employment of the defendant police officers present a clear and present danger to the residents of the County of San Diego.. The lack of adequate screening and hiring practices by the defendants evince deliberate indifference to the rights of plaintiffs and others in their position.. These hiring practices led to the employment of defendants Williams and DOES - and caused the harms suffered by the plaintiff in this case.. As a result of Defendants actions, Plaintiff suffered physical and psychological injuries. TENTH CAUSE OF ACTION [Civil Rights Action ( U.S.C. For Failure to Properly Train Against Defendants ZIMMERMAN, CITY OF SAN DIEGO and Does -]. Plaintiff realleges all prior paragraphs of this complaint and incorporate 0. The defendants City of San Diego and Chief Zimmerman, as a matter of custom, practice and policy, failed to maintain adequate and proper training as to the constitutional rights of citizens and arrestees; to prevent the consistent and systematic use of excessive force; and to prevent extra judicial punishment by officers.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. Defendants failed to provide adequate training to police officers on the proper protocol and procedure on detention and arrest of citizens; the use of force in effectuating arrests and detentions.. Therefore, these defendants, with deliberate indifference, disregarded a duty to protect the public from official misconduct.. The failure to promulgate or maintain constitutionally adequate training was done with deliberate indifference to the rights of plaintiffs and others in their position.. The constitutionally infirm lack of adequate training as to the officers in this case caused plaintiff s damages.. As a result of Defendants actions, Plaintiff suffered physical and psychological injuries. ELEVENTH CAUSE OF ACTION [Civil Rights Action ( U.S.C. For Failure to Supervise and Discipline Against Defendants ZIMMERMAN, CITY OF SAN DIEGO and Does -]. Plaintiff realleges all prior paragraphs of this complaint and incorporate. City of San Diego and Chief William Zimmerman, as a matter of custom, practice and policy, failed to supervise police officers to prevent, deter and punish the unconstitutional and excessive use of force.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. Upon information and belief, the defendants knew or should have known of the dangerous propensities of defendants Williams and DOES - but took no steps to supervise them, correct their abuse of authority, or discourage their unlawful use of authority.. To the contrary, defendants condoned and acquiesced in the abusive behavior of police officers by refusing to retrain them, discipline them, or correct their abusive behavior. 0. Defendants were not disciplined for their use of force on Plaintiff.. Defendants were, or should have been aware that the policy regarding supervision and discipline of officers who violated the civil rights of the citizens and commit assault and battery was so inadequate that it was obvious that a failure to correct it would result in further incidents of dangerous and lawless conduct perpetrated by their officers.. The constitutionally deficient investigation and lack of discipline was done with deliberate indifference to the rights of plaintiffs and others in their position.. The lack of adequate supervision and discipline caused plaintiff s damages.. As a result of Defendants actions, Plaintiff suffered physical and psychological injuries. TWELFTH CAUSE OF ACTION
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0 (Monell Municipal Liability Civil Rights Action ( U.S.C. Against Defendant CITY OF SAN DIEGO Policy of Use of Excessive Force. Plaintiff realleges all prior paragraphs of this complaint and incorporate. Defendant San Diego promulgated and maintained an unconstitutional policy, ordinance or regulation which allowed its police officers to use excessive force in violation of the rights of citizens.. Defendant was deliberately indifferent to the widespread misconduct on the part of San Diego police officers in detaining citizens who had committed no crimes.. Defendant was deliberately indifferent to the widespread misconduct on the part of San Diego police officers in the application of unnecessary and excessive use of force.. During the relevant period, defendant police officers were acting pursuant the policy of defendant San Diego. 0. Defendant knew or should have known of the risks posed by the Department s policies regarding the improper and excessive use of force.. The defendant was deliberately indifferent to the right of plaintiff to be free from, and protected from, harm by the brutality of police officers and to be secure in their bodily integrity.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. As a direct result, plaintiffs were battered, intentionally and negligently inflicted with emotional distress and their Constitutional rights were violated.. The unlawful and illegal conduct of the defendant deprived plaintiff of the rights, privileges and immunities secured to him by the Constitutions of the United States and of the State of California.. As a direct, proximate and foreseeable result, Plaintiff suffered damages in an amount according to proof at the time of trial. THIRTEENTH CAUSE OF ACTION [California Civil Rights Violation (Section. against all defendants]. Plaintiff realleges all prior paragraphs of this complaint and incorporate. Plaintiff had a firmly established right to be free from excessive force under the Fourth Amendment through the Fourteenth Amendment to the United States Constitution and the equivalent provisions of the California Constitution.. The California Legislature has declared that it violates our state civil rights act for any person to interfere with the exercise or enjoyment by any individual of his rights secured by the United States Constitution or state or federal law. This includes any interference of these rights by threats, intimidation, coercion or attempted threats, intimidation or coercion.
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of 0. The Defendants interfered with Plaintiffs rights under the Fourth Amendment of the United States Constitution and the equivalent provisions of the state Constitution by the use of force alleged above.. This interference with Plaintiff s rights was perpetrated by the Defendants in violation of California Civil Code. and their right under the Fourth and Fourteenth Amendments to be free from excessive force under the Fourth Amendment and the Fourteenth Amendment to the United States Constitution and the California Constitution.. Due to the violation of Plaintiff s rights by all Defendants, Plaintiff suffered economic damages and non-economic damages, including, but not limited to, emotional distress, pain and suffering, medical expenses and fear caused by the acts complained of herein according to proof at the time of trial.. Plaintiff is also entitled to the statutory civil penalties set forth in Civil Code., attorneys fees and costs of suit incurred herein.. The conduct of Defendants also amounts to oppression, fraud or malice within the meaning of Civil Code Section et seq. and punitive damages should be assessed against each non-municipal defendant for the purpose of punishment and for the sake of example. Defendant City of San Diego is liable for the acts of its officers as they have agreed with and or ratified the acts. PRAYER FOR RELIEF
Case :-cv-00-l-jma Document Filed /0/ PageID. Page of WHEREFORE, Plaintiff demands trial by jury and prays for judgment in his favor and against Defendants as follows:. Directing Defendants to set forth policies and procedures as may be necessary and proper with respect to the use of force.. Entering judgment for compensatory general and special damages in an amount in accordance with proof.. Entering judgment for exemplary damages against each of the individual defendants in an amount sufficient to punish and to make an example of said defendants, and to deter said defendants and others from engaging in similar conduct.. Awarding reasonable attorney s fees, expenses, and costs of suit.. Granting such other and further relief as the Court deems proper. DEMAND FOR JURY TRIAL Plaintiffs demand a jury trial. 0 Dated: November, 0 Respectfully Submitted, /s/gastone Bebi GASTONE BEBI Attorney for Plaintiff
JS (Rev. 0 Case :-cv-00-l-jma Document - Filed /0/ PageID.0 Page of CIVIL COVER SHEET The JS civil cover sheet and the infonnation contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by Jaw, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September I, is requued fo r the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE JNSTRUCNS ON NEXT PAGE OF THIS FORM cwcjfumif~go, SHELLEY ZIMMERMAN, FNU WILLIAMS (b County of Residence of First Listed Plaintiff -=Sc::a:.:..n:...:D=-:.::ie""g'-'o;... County of Residence of First Listed Defendant _S=ac..: nc.:d=..:.: ieg'-"'-'o'--- - - -- (EXCEPT JN U.S. PLAINTIFF CASES (/N U.S. PLAINFF CASES ONLY NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED. ( c Attorneys {Firm Name, Addre.rs, and Telephone Nmber Gastone Bebi 0 West Broadway, Suite 0 San Diego CA, tel --0 II. BASIS OF JURISDICTION (Place an "X"inOneBoxOnty 0 U.S. Govenunent ~ Federal Question Plaintiff (U.S. Government Not a Party 0 U.S. Government 0 Oivcrsily Defendant (Indicate Citizemhip of Parties in Item Ill} Attorneys (I/Known 'CV0 L JMA III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X'' in one Box for l'laintijj (For Diversity Cases Only and One Box for O.fendant PTF DEF PTF DEF Citizen of This State IX I ((. I Inrorporated or Principal Place 0 0 of Business In This State Citizen of Another State O O Incorporated and Principal Place 0 S D of Business In Another State Citizen or Subject of a Forci '" Coun O O Foreign Nation 0 0 Click here for: Nature of Suit Code Descri tions. 0 I IO Insurance PERSONAL INJURY PERSONAL INJURY D 0 Marine D Ailplane D Personal Injury O 0 Miller Act 0! Ailplanc Product Product Liability D 0 Negotiable Instrument Liability 0 Health Care/ 0 I SO Recovery of Overpayment 0 0 Assault Libel & Phannaceutical & Enforcement of Judgment Slander Personal Injury D I Medicare Act 0 0 Federal Employers' Product Liability D Recovery of Defaulted Liability 0 Asbestos Personal Student Loans D 0 Marine Injury Product (Excludes Veterans D Marine Product Liability O Recovery of Overpayment Liability PERSONAL PROPERTY of Veteran"s Benefits D 0 Motor Vehicle D 0 Other Fraud 0 0 Stockholders' Suits 0 Motor Vehicle O Truth in Lending 0 0 Other Contract Product Liability 0 0 Other Personol 0 Contract Product Liability 0 0 Other Personal Property Damage 0 Franchise Injury 0 S Property Damage 0 Personal Jnjmy Product Liability Medical 'R.J;ID;.l!JtO. 0 Land Condemnation er; 0 Other Civil Rights Habeas Corpus: 0 0 Foreclosure 0 Voting 0 Alien Deainee 0 0 Rent Lease & Ejectment 0 Employment 0 Motions to Vacate D 0 Torts to Land 0 Housing/ Sentence 0 Tort Product Liability Accommodations D 0 General 0 0 All Otler Real Property 0 Amer. w/disabilities 0 Death Penalty V. ORI GIN (Place an "X " in One Box Only Ji:: I Original Proceeding Employment Other: 0 Amer. w/disabilities D 0 Mandamus & Other Other D 0 Civil Rights D Education D Prison Condition 0 0 Civil Detainee Conditions of Confinement 0 Removed from State Court 0 Remanded from Appellate Court 0 Drug Related Seizure D Appeal USC 0 Folse Claims Act of Property use 0 Withdrawal 0 Qui Tam ( USC 0 0 Other USC (a 0 00 State Reapportionment 0 Antitrust 0 0 Copyrights 0 0 Banks and Banking D 0 Patent 0 0 Commerce 0 0 Deportation 0 0 Racketeer Influenced and Corrupt Organizations D 0 Consumer Credit 0 0 Cable/Sat TV 0 0 Securities/Commodities/ 0 0 Labor/Management Exchange Relations 0 0 Other Statutory Actions 0 0 Railway Labor Act 0 Agricultural Acts 0 l Family and Medical 0 Environmental Matters Leave Act 0 Fn:cdom oflnfonnation 0 0 Other L&bor Litigation Act 0 Employee Retirement 0 0 Taxes (U.S. Plaintiff 0 Arbitration Income Security Act or Defendant 0 Administrative Prncedure!MftOi: "-'UOJ\ 0 NalUnllization Application 0 Other Immigration Actions 0 Reinstated or Reopened 0 Transferred from Another District {specify D IRS-Third Party Act/Review or Appeal of use 0 Agency Decision 0 0 Constitutionality of State Statutes 0 Multidistrict Litigation Transfer 0 Multidistrict Litigation Direct File Cite the U.S. Civil Statute under which you are filing (Do " ot cite j urisdictional.iatutes unle.<.< diversity: VI. CAUSE OF ACTION '"a-~"' ~e--~"'de~ ~sc~ ~~.P~ tt~. 0 ~~~~:~ca~ -u-se-:--------------------------------------- Excessive Police Force, False Arrest VII. REQUESTED IN 0 CHECK IF THIS JS A CLASS ACTION : UNDER RULE, F.R.Cv.P. VIII. RELATED CASE(S (See instructions: JF ANY DATE //0 FOR OFFICE USE ONLY DEMANDS CHECK YES only if demanded in complaint JURY DEMAND: ~Yes ONo DOCKET NUMBER RECEIPT# AMOUNT APPL YING IFP JUDGE MAG. JUDGE