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Dawn Willis v. Sheriff May Amended Complaint

Dawn Willis v. Sheriff May Amended Complaint

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Published by: Matthew Seth Sarelson on Mar 09, 2012
Copyright:Attribution Non-commercial


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SHERIFF PAUL MAY in his officialcapacity as Sheriff of Okeechobee County,TOMMIE JOE BROCK, &JOHN DOES 1-10
Plaintiff, Dawn Morris Willis, hereby sues Defendants, Sheriff Paul May, in his officialcapacity as Sheriff of Okeechobee County (“the OSO”) for federal civil rights violations andTommie Joe Brock and John Does 1-10 for federal civil rights violations and sexual battery, andconspiracy.
This case is about a nightmare. Over an eight month period between November2008 and July 2009, Ms. Willis was used as a sex slave by T.J. Brock, then a Detective andSergeant with the Okeechobee County Sheriff’s Office. For the first half of the relevant period,Sheriff’s Deputy Brock forced Ms. Willis to have sexual intercourse with him and to performoral sex on him in exchange for Sheriff’s Deputy Brock not violating Ms. Willis’ probation.During the second half of the relevant time period, Ms. Willis was detained in the Okeechobee
This Amended Complaint is being filed to omit/dismiss the County as a distinct defendant, and to renameDefendant Okeechobee County Sheriff’s Office as “Sheriff Paul May in his official capacity as Sheriff of Okeechobee County.” All claims made against Sheriff May are filed pursuant to 42 U.S.C. § 1983.
Case 1:11-cv-23765-JAL Document 20 Entered on FLSD Docket 12/01/2011 Page 1 of 12
2County Jail. Sheriff’s Deputy Brock, who was not assigned to the jail, would have Ms. Willisremoved and transferred to his office. On numerous occasions outside of the jail, he raped Ms.Willis while she was shackled with handcuffs and leg irons. Sheriff’s Deputy Brock’s rape of Ms. Willis would not have been possible but for the assistance of other deputies.2.
The Okeechobee County Sheriff’s Office knew about Deputy Brock’smisconduct. He was a veteran deputy and was long suspected of having sex with juvenile andadult offenders in prison and providing alcohol and drugs to detainees. In fact, Deputy Brock,while on road patrol, detained Ms. Willis years earlier and offered to not arrest her for drivingunder the influence if she would only have sex with him. In his words, sex with him was betterthan jail. The OSO knew for decades that it had a problem officer, but did nothing. There werenumerous complaints about him and the OSO conducted internal affairs investigations into hismisconduct.3.
Ms. Willis informed prison officials about being raped by Deputy Brock but theydid nothing. Finally, Ms. Willis, through a family connection, contacted the Federal Bureau of Investigation on or about June 12, 2009. The FBI interviewed Ms. Willis concerning the sexualassaults by Sheriff’s Deputy Brock and then notified the OSO. Deputy Brock’s last rape of Ms.Willis occurred on July 2 or 3, 2009, after the FBI interviewed Ms. Willis. The next day, the FBIagain interviewed Ms. Willis. Ms. Willis obtained DNA evidence the proved, beyondperadventure, that Deputy Brock had sexual relations with her.4.
At all times throughout this nightmare, Deputy Brock was acting in his capacityas an Okeechobee County Sheriff’s Deputy. At all times throughout and before this nightmare,the OSO knew about Deputy Brock’s behavior. It is responsible for the violations of Ms. Willis’civil rights.
Case 1:11-cv-23765-JAL Document 20 Entered on FLSD Docket 12/01/2011 Page 2 of 12
 Parties, Jurisdiction & Venue
Plaintiff, Dawn Morris Willis, is a female resident of Miami-Dade County,Florida.6.
Defendant, Sheriff Paul May in his official capacity as Sheriff of OkeechobeeCounty (“the OSO”), is the sheriff of Okeechobee County and is the responsible party. Allclaims asserted against the OSO are asserted pursuant to 42 U.S.C. § 1983.7.
Defendant, Sheriff’s Deputy T.J. Brock, is a resident of Okeechobee County,Florida. At all material times, he was acting in his official capacity as a Deputy Sheriff. Hewore a badge and was armed with his official service pistol. He was an employee of the OSO.All claims asserted against Deputy Brock are asserted pursuant 42 U.S.C. § 1983, except for astate law claim of sexual battery. Deputy Brock was, at all times, an active-duty detectivesergeant. As a detective sergeant, he had unrestricted access to the county jail and any inmatehoused in the jail. He was not, however, assigned to the county jail. He was terminated from theSheriff’s Department on or about July 8, 2009. He served as a deputy sheriff for approximately23 years, most recently as the OSO’s homicide detective.8.
Defendants, John Does 1-10, are other deputies and employees of the OSO whoconspired with Deputy Sheriff Brock to rape and sexually batter Ms. Willis.9.
This Court has federal question jurisdiction because it arises under 42 U.S.C. §1983.10.
This Court has supplemental jurisdiction over the state claims against allDefendants pursuant to 28 U.S.C. § 1367(a).11.
Venue is proper because all facts occurred within the Southern District of Florida.
Case 1:11-cv-23765-JAL Document 20 Entered on FLSD Docket 12/01/2011 Page 3 of 12

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