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Good Samaritan Federal Civil Rights Complaint (1)

Good Samaritan Federal Civil Rights Complaint (1)

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Published by Robert Chilson

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Published by: Robert Chilson on May 04, 2012
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08/16/2013

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UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY
_____________________________________________________________________________
ROBERT CHILSON, : CASE No.:Plaintiff, ::v. :
COMPLAINT
 :TRENTON POLICE OFFICER MARK ICE; :TRENTON POLICE OFFICER BARRY HOLLO; :TRENTON POLICE SERGEANT PAUL :GENDRON; TRENTON POLICE OFFICER :LAUREL ROGERS; TRENTON POLICE :DIRECTOR IRVING BRADLEY; THE CITY OF :TRENTON; THE TRENTON POLICE :DEPARTMENT; SABOR LATINO BAR & :RESTAURANT; and JOHN AND JANE DOES :#1-10, :Defendants. :_________________________________________Plaintiff, Robert Chilson, through his attorney, Patrick J. Whalen, Esquire, by way of Complaint against the Defendants, alleges the following:
I.
 
INTRODUCTION AND FACTUAL BACKGROUND
 1.
 
This case involves claims based upon violations of the United States Constitution,the United States Civil Rights Act, including violations of 42 U.S.C. §, 1983, as well asviolations of the New Jersey Constitution and the New Jersey Civil Rights Act, and common lawcauses of action.2.
 
Specifically, Plaintiff, Robert Chilson, asserts that, as a result of his attempt tohelp a woman who appeared to be being beaten and harassed by an unknown male, he was (a)subjected to excessive and unreasonable force; (b) negligently and falsely arrested andimprisoned; and (c) falsely charged with and maliciously prosecuted for disorderly conduct-
 
 
2improper behavior, obstruction, and failure to disperse.
II. JURISDICTION
 3. J
urisdiction over Plaintiff’s claims is conferred on this Court pursuant to Title 42
U.S.C. §1983 and Title 28 U.S.C. §§1339 and 1343(a). This Court has supplemental jurisdictionover the State law claims pursuant to Title 28 U.S.C. §1367(a).
III. VENUE
4. Venue in this District is proper, pursuant to28 U.S.C.A. § 1391,because Plaintiff resides in Mercer County and certain unconstitutional acts, practices, and misconduct occurredwithin this District.
IV. RELIEF SOUGHT
5. This action seeks money damages, punitive and exemplary damages, attor
ney’s
fees, and costs.
V. PARTIES
6.
 
Plaintiff, Robert Chilson, is an individual who currently resides at 547 GreenwoodAvenue, #506, Trenton, New Jersey 08609.7.
 
Defendant Trenton Police Officer Mark Ice, at all times relevant to this Complaint,was employed by the City of Trenton Police Department. He is being sued in both his individualand official capacities. 8.
 
Defendant Trenton Police Officer Barry Hollo, at all times relevant to thisComplaint, was employed by the City of Trenton Police Department. He is being sued in both hisindividual and official capacities. 
 
 
39.
 
Defendant Trenton Police Sergeant Paul Gendron, at all times relevant to thisComplaint, was employed by the City of Trenton Police Department. He is being sued in both hisindividual and official capacities. 10.
 
Defendant Trenton Police Officer Laurel Rogers, at all times relevant to thisComplaint, was employed by the City of Trenton Police Department. She is being sued in bothher individual and official capacities. 11.
 
At all times relevant to this Complaint, Defendant, former Trenton PoliceDirector, Irving Bradley, was employed by the Trenton Police Department. He is being sued inboth his individual and official capacities.12.
 
Defendant, the City of Trentonwas at all times relevant herein a municipalcorporation organized under the laws of the State of New Jersey and was the legal entity
responsible for all actions engaged in by Defendants the Trenton Police Department (“TPD”). For 
the purposes of all causes of action pleaded herein under N.J.S.A. 10:6-2 et seq., Defendant Cityof Trenton is a person under law.13.
 
Defendant Trenton Police Department (“TPD”) was at all times relevant herein a
policymaking agency/department of the City of Trenton, organized under the laws of the State of New Jersey. It was responsible for enforcing all criminal laws of the State of New Jersey andcriminal municipal ordinances of the City of Trenton, as well as for the hiring, supervision,training and retention of police officers in the City of Trenton and all other respective duties of amunicipal law enforcement agency. At all times relevant herein, Defendant TPD was theemployer and principal of the individual Defendants, Trenton Police Officer Mark Ice, Trenton

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