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Marvin L_ Booker, Et Al_ V_ Denver, Et Al_ - Complaint

Marvin L_ Booker, Et Al_ V_ Denver, Et Al_ - Complaint

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Marvin L. Booker, Et Al. v. Denver, Et Al. - ComplaintScribd Upload a Document Search DocumentsExploreDocumentsBooks - FictionBooks - Non-fictionHealth &MedicineBrochures/CatalogsGovernment DocsHow-ToGuides/ManualsMagazines/NewspapersRecipes/MenusSchool Work+ allcategoriesFeaturedRecentPeopleAuthorsStudentsResearchersPublishersGovernment & NonprofitsBusinessesMusiciansArtists & DesignersTeachers+ all categoriesMostFollowedPopularSign UpLog In1First PagePrevious PageNext Page/ 26Sections not availableZoom OutZoom InFullscreenExit FullscreenSelect View ModeView ModeSlideshowScroll ReadcastAdd a CommentEmbed & ShareReading should be social! Post a message on your social networks to let othersknow what you're reading. Select the sites below and start sharing.Readcast this DocumentLogin to Add a CommentShare & EmbedAdd to CollectionsDownload this Document for FreeAuto-hide: on DISTRICT COURT, CITY AND COUNTY OF DENVER,COLORADODenver City & CountyBuilding1437 Bannock Street, Room 256Denver, CO 80202 ▲COURT USE ONLY▲ESTATE OF MARVIN L. BOOKER,REVEREND B.R.BOOKER, SR., andROXEY A. WALTON, asCo-PersonalRepresentatives, Plaintiffs, v. CITY AND COUNTY OF DENVER;DeputyFAUNGOMEZ, individually and in her official capacity; DeputyJAMES GRIMES,individually and in his official capacity;DeputyKYLE SHARP, individually and inhis officialcapacity; DeputyKENNETH ROBINETTE, individuallyand in his officialcapacity; and SergeantCARRIERODRIGUEZindividually and in her official capacity,Defendants. Case No: Div:ATTORNEYS FOR PLAINTIFFS: Darold W.Killmer, #16056Mari Newman, #30192David Lane, #16422Lauren L. Fontana, #40234KILLMER , LANE& NEWMAN, LLP1543 Champa Street Suite 400Denver, CO 80202Phone:(303) 571-1000Fax No.: (303) 571-1001dkillmer@kln-law.com mnewman@kln-law.comdlane@kln-law.com lfontana@kln-law.com COMPLAINT ANDJURYDEMAND 1Plaintiffs, by and through their attorneys, Darold W. Killmer, Mari Newman,David A.Lane, and Lauren L. Fontana of KILLMER, LANE & NEWMAN, LLP respectfullyallege for their Complaint as follows:I. INTRODUCTION 1. This is an action fordamages and injunctive relief against Defendants City andCounty of Denver(“Denver”), Deputy Faun Gomez, Deputy James Grimes, Deputy Kyle Sharp,DeputyKenneth Robinette, and Sergeant Carrie Rodriguez.2. In one of many instances oflaw enforcement misconduct sanctioned by Denver,the individual Defendants,through the use of excessive force, caused the death of MarvinBooker in the VanCise-Simonet Detention Center (“the Jail”) on July 9, 2010.3. Denver thenengaged in an extensive cover-up of the events of July 9, 2010, as isthe custom, practice, and policy after instances involving the use of excessive force byDenver Department of Safety law enforcement officers.II. JURISDICTION ANDVENUE4. The Court has jurisdiction over the claims asserted herein pursuant toCOLO. R EV. STAT. § 13-1-124, Title 42 U.S.C. Sections 1983 and 1985, and otherapplicable law.5. Venue is proper in this Court pursuant to COLO. R. CIV. P.98(c), in that all of theevents alleged herein occurred within the City andCounty of Denver.III. PARTIES6. At all times relevant to the subject matter of
 
this litigation, the decedent, MarvinBooker, was a citizen of the United Statesof America and a resident of the State of Colorado.7. At all times relevant tothe subject matter of this litigation, Plaintiffs ReverendB.R. Booker and RoxeyA. Walton, co-personal representatives of the estate of Marvin Booker,were thefather and mother of Marvin Booker and have been citizens of the United Statesandresidents of the State of Tennessee.8. Defendant Denver is a Coloradomunicipal corporation. Denver
’s Department of Safety is responsible for theoversight, supervision, and training of both the Denver PoliceDepartment and the Denver Sheriff’s Department.9. At all times relevant to the subject matter ofthis litigation, Defendant FaunGomez was a citizen of the United States and aresident of Colorado and was acting under color of state law in her capacity asa law enforcement officer employed as a Deputy at the Jail.10. At all timesrelevant to the subject matter of this litigation, Defendant JamesGrimes was acitizen of the United States and a resident of Colorado and was acting undercolor of state law in his capacity as a law enforcement officer employed as aDeputy at the Jail. 211. At all times relevant to the subject matter of this litigation, DefendantKyle Sharpwas a citizen of the United States and a resident of Colorado and wasacting under color of statelaw in his capacity as a law enforcement officeremployed as a Deputy at the Jail.12. At all times relevant to the subject matter of this litigation, Defendant KennethRobinette was a citizen of the UnitedStates and a resident of Colorado and was acting under color of state law in his capacity as a law enforcement officer employed as a Deputy at the Jail.13. Atall times relevant to the subject matter of this litigation, DefendantCarrieRodriguez was a citizen of the United States and a resident of Coloradoand was acting under color of state law in her capacity as a law enforcementofficer employed as a Sergeant at the Jail.IV. FACTUAL ALLEGATIONSA. MARVINBOOKER’S LIFE14. Marvin Louis Booker was born in Memphis, Tennessee, on February4, 1954. Hewas the son of Plaintiffs Reverend B.R. Booker, Sr., and Roxey A.Walton. Marvin Booker (middle child on the left, wearing striped tie) with his family in Memphis, TN. Marvin Booker (sitting on his father’s knee)is picturedwith his family. 3 15. Marvin Booker joined the United States Army in 1971at age 17. 16. Marvin Booker was a respected member of his community, and wasoften invitedto speak publically. Marvin Booker speaking at an Energy Conference in Denver, Colorado in the late 1970s. Marvin Booker speaking at Shaw University Heritage Gospel Show, Raleigh, NC, April 11, 1980. 417. Mr. Booker came from a long line of pastors. His father, Benjamin Booker, Sr., isa prominent Memphis pastor, and his brother, C.L. Booker, is the pastorat Cathedral of FaithCommunity Church in Memphis. His other brother, SpencerBooker, is currently a pastor at theBethel AME Church in Kansas City, Missouri.His brother, David Booker, is a Bishop with theShelter in the Storm Ministriesin Nashville, TN. Likewise, several of Marvin Booker’s nephewsand nieces areordained ministers. Like his father, brothers, and other relatives, MarvinBooker served the communities where he lived as a pastor. Marvin Booker(pictured in the front row, on the left side, wearing a silver robe) waiting tospeak at the Lorraine Motel in Memphis, TN 1991, the same location where Dr.Martin Luther King was assassinated in 1968. Marvin was the principle speakerat this gathering.18. Marvin followed in the footsteps of his father andsiblings, devoting his life toserving the poor by reaching out to the homelesscommunity as a street preacher.19. Mr. Booker made it his life’s work tocommunicate the message of hope andequality championed by Dr. Martin LutherKing, Jr. During the 1980s, he helped to establish theMartin Luther King
 
Museum.20. Mr. Booker famously memorized Dr. King’s speeches and recited thematcommunity events and on the streets. Homeless people whom he helped inMemphis andelsewhere often referred to him as “Martin” because of his ability torecite Dr. King’s speeches.21. Mr. Booker’s skill at impersonating Dr. King canbe viewed in a video taken by acitizen who encountered Mr. Booker in Memphis in2006 and posted the video onYouTube:http://www.youtube.com/watch?v=8slzROAs5qM&playnext=1&list=PL8111287C3DDF6CEE.5Marvin L. Booker, Et Al. v. Denver, Et Al. - ComplaintDownload this Document for FreePrintMobileCollectionsReport DocumentReport thisdocument?Please tell us reason(s) for reporting this document Spam or junk Porn adult content Hateful or offensiveIf you are the copyright owner of thisdocument and want to report it, please follow these directions to submit acopyright infringement notice.Report CancelThis is a private document.Info and RatingReads:282Uploaded:02/24/2011Category:GovernmentDocs>FormsRated:Copyright:Attribution Non-commercialFollownicklucchesiShare & EmbedRelated DocumentsPreviousNextp.p.p.p.p.p.p.p.p.p.p.p.p.p.p.p.p.More from this userPreviousNext9 p.44 p.2 p.3 p.98 p.22 p.8 p.2 p.2 p.2 p.2 p.34 p.1 p.7 p.1 p.18 p.8 p.12 p.6 p.

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