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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Devin Williams )

Khadijah Reed Aigoro )

(K.W. a Minor) )

Plaintiffs )

 )

Vs. )

)

City of North Bay Village )

Lt. Brian Collins - Individual Capacity )

Detective Sam Bejar - Individual Capacity )

Officer Jose Martinez - Individual Capacity )

Officer Frank Pieiga - Individual Capacity )

Officer Walter Sadjak - Individual Capacity )

Officer Hubert Molina - Individual Capacity )

Defendants

COMPLAINT AND JURY DEMAND

This is a civil rights action in which Plaintiff seeks relief for the violation of their 

rights secured by 42 USC 1983, 1988, the First, Fourth and Fourteenth Amendments 

to the United States Constitution and the Florida Constitution.

1. The claims arose on or about January 30, 2018 from an incident in which 

Officers of the North Bay Village Police Department; hereinafter, (NBVPD), 

acting under color of state law statutes, ordinances, regulations, policies, 

customs and usages of the City of North Bay Village and intentionally and 

willfully subjecting Plaintiffs to, inter alia, false arrest, false imprisonment, 

battery, excessive force and intentional infliction of emotional distress.

JURISDICTION

2. This action is brought pursuant to 42 U.S.C. 1983, the First, Fourth and 

Fourteenth Amendments to the United States Constitution and the laws of the 

State of Florida. Jurisdiction of this Court is also predicated on 28 U.S.C. 

§1331 and the supplemental jurisdiction of this court under 28 U.S.C. 

§1367(a), and 28 U.S.C. §1988. 

3. The amount in controversy exceeds $75,000 excluding interest and costs.

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VENUE

4. Venue is proper within the in the Southern District of Florida because the 

incident that gave rise to this action occurred in the City of North Bay Village, 

Florida which is located therein and the officers that are responsible for the 

constitutional violations live and or work within its boundaries.

PARTIES

5. At all times material hereto Plaintiff, Devin Williams, an African American 

male was a resident of the City of North Bay Village, Florida which is located

in Miami-Dade County Florida and at all times relevant hereto was sui juris.

6. At all times material hereto Plaintiff, Khadija Reed Aigoro an AfricanAmerican female, was a resident of the City of North Bay Village, Florida 

which is located in Miami-Dade County Florida and at all times relevant 

hereto was sui juris.

7. At all times material hereto Plaintiff, (K.W. a Minor) an African-American 

male/minor, was s a resident of the City of North Bay Village, Florida which 

is located in Miami-Dade County Florida and at all times relevant hereto was 

sui juris.

8. Defendant, City of North Bay Village, Florida is a municipality located in 

Miami-Dade County and is the employer of all Defendants that are listed in 

this suit.

9. Defendant, Lt. Brian Collins, at all times relevant hereto and in all actions 

described herein, was acting under color of law working in the capacity of 

Detective for the City of North Bay Village Police Department and is being 

sued in his individual capacity.

10. Defendant, Detective Sam Bejar, at all times relevant hereto and in all actions 

described herein, was acting under color of law working in the capacity of 

Detective for the City of North Bay Village Police Department and is being 

sued in his individual capacity.

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11. Defendant, Officer Hubert Molina, at all times relevant hereto and in all 

actions described herein, was acting under color of law working in the

capacity of a Police Officer for the City of North Bay Village Police 

Department and is being sued in his individual capacity.

12. Defendant, Officer Jose Martinez, at all times relevant hereto and in all 

actions described herein, was acting under color of law working in the

capacity of Police Officer for the City of North Bay Village Police Department 

and is being sued in his individual capacity.

13. Defendant, Officer Frank Pieiga, at all times relevant hereto and in all 

actions described herein, was acting under color of law working in the

capacity of Police Officer for the City of North Bay Village Police Department 

and is being sued in his individual capacity.

14. Defendant, Officer Walter Sajdak, at all times relevant hereto and in all 

actions described herein, was acting under color of law working in the

capacity of Police Officer for the City of North Bay Village Police Department 

and is being sued in his individual capacity.

STATEMENT OF THE FACTS

15. On or about January 30, 2018, Plaintiffs Devin Williams, Khadijah Reed 

Aigoro and (K.W. a Minor) were home with their front door locked at the 

Moda North Bay Village Apartments located at 8000 West Drive, Apartment 

728, North Bay Village, Florida 33141.

16. An individual believed to be working as a police officer for the North Bay 

Village Police Department pried open the lock on Plaintiffs’ front door and 

police officers rushed inside; in violation of Plaintiffs’ First, Fourth and 

Fourteenth Amendment’s rights

17. The officer were equipped with military style weapons resembling the AR-15 

and trained them on the three Plaintiffs, one being the minor child. 

18. Plaintiffs Devin Williams and Khadija Reed Aigoro, were seized, slammed to 

the floor, handcuffed and led to the living room and placed on the couch at 

gunpoint and then questioned. 

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19. The minor (K.W.) was not handcuffed but had weapons drawn on him as he 

was led into the living room with Williams and Aigoro at that point neither 

Plaintiff was free to leave constituting the arrest and detention.

20. Plaintiffs were questioned for a substantial period of time while officers 

searched Plaintiffs’ home. 

21. Officers eventually removed the handcuffs from Williams and Aigoro and 

they left without further incident. 

22. Prior to Officers leaving Plaintiff’s apartment one of the officers placed a 

military style service weapon to (K.W. Minor’s) head only to further 

intimidate Plaintiffs.

23. Neither adult was transported to the Miami-Dade County Jail nor was (Minor, 

K.W. minor), removed from the home and placed in DCF custody

24. The North Bay Village Police Department’s intrusion into plaintiffs’ home 

and apprehension of their person was without probable cause, arguable 

probable cause, exigent circumstances or hot pursuit, constituting an illegal 

arrest, detention, search and seizure. 

25. According to the North Bay Village Police Department website there are 25 

officers on staff in their Police Department and it is believed that every officer 

on shift participated in this illegal and unconstitutional raid.

26. Plaintiff will seek leave of the Court to amend their petition to add the other 

officers as their names are obtained through the discovery process.

27. Officer’s actions were done maliciously and sadistically for the very purpose 

of causing harm and intimidating the Plaintiffs.

28. NBVPD Officers assisted each other in the performance of various actions 

described herein lending their physical presence, support and authority of their 

office to violate Plaintiff’s Fourth Amendment Constitutional rights. 

29. No officer on the scene took reasonable steps to protect the Plaintiffs/Victims 

from fellow officers’ use of excessive force and is each is liable for their 

individual nonfeasance in their illegal actions. 

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30. The North Bay Village Department’s Officers were motivated by racial 

animus toward the Plaintiffs in violating their First, Fourth and Fourteenth 

Amendment Rights. 

31. Defendants’ actions were plainly incompetent while knowingly violating 

Plaintiffs Constitutional rights.

32. All Plaintiffs are African-American. There are approximately two other 

African American families living in the building while all of the Defendants 

are Non-African-American. 

33. The misconduct described in this complaint was undertaken with malice, 

willfulness, and reckless indifference to the constitutional rights of the 

Plaintiffs.

34. 42 USC 1983 provides a remedy against ‘any person’ who, under color of 

state law, deprives another of rights protected by the Constitution.”

35. Plaintiff will establish that Defendants are liable in their individual capacity

under § 1983, as they were acting under color of state law, caused the 

deprivation of a federal right of the Plaintiffs. 

INDIVIDUAL CAPACITY

36. Plaintiffs seek to impose individual liability upon Defendant officer for 

actions taken under color of state law which cause the deprivation of 

Plaintiffs’ Federal Rights.

37. The officers were carrying out law enforcement functions, was on duty, 

wearing police uniforms, used police equipment; squad cars, handcuffs, 

badges, claimed to be officers, and carried out the arrest. 

38. Defendant’s actions violated Plaintiffs’ Fourth Amendment right to be secure 

in their persons, houses, papers, and effects, against unreasonable searches 

and seizures, shall not be violated, and no Warrants shall issue, but upon 

probable cause,

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39. The conduct of the Defendant Officers included but not limited to the 

following; home invasion, illegal search and seizure, aggravated assault with 

deadly weapons, battery, trespass, excessive force, false imprisonment and 

violation of equal protection of the law violations.

40. According to North Bay Village Police Department website there are 25 

officers on staff and it is believed that every officer that worked on shift 

participated in this illegal and unconstitutional action.

41. The city of North Bay Village is directly responsible for the actions of their 

officers because high ranking members from cities police department were on 

the scene sanctioning and supervising officer’s activities. 

QUALIFIED IMMUNITY

42. Qualified immunity is not available to the Defendants because the

aforementioned conduct described herein violates clearly established statutory 

and constitutional rights of which reasonable officers would have known at 

the time that their actions were taken.

43. Defendants’ actions were unreasonable, as no reasonable officer in the same 

situation could have believed that his actions were lawful. 

44. The Defendants are not entitled to qualified immunity because their conduct 

violates clearly established statutory and constitutional rights which a 

reasonable police officer would have known at the time of their misconduct.

45. Defendants were not carrying out discretionary duties. Defendants’ actions 

were tantamount to criminal behavior as their behavior was plainly 

incompetent while knowingly violating federal law. 

NOTICE OF CLAIM

46. Within the time period outlined by Florida Law, Plaintiff filed written notice 

of the claim with the Florida Office of Professional Responsibility, the Mayor 

of North Bay Village and the Police Chief of North Bay Village. The statutory 

time period has lapsed since filing that notice, and this matter has not been 

settled or otherwise disposed of. A copy of the notices accompany this 

complaint.

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47. Plaintiff Devin Williams and Khadijah Aigoro will file sworn statements 

evincing the allegations alleged. Plaintiff K.W., will not as he is a minor.

CONDITIONS PRECEDENT

48. All conditions precedent has been performed or has occurred. Plaintiff 

complied with notice requirements of Florida Statutes which requires notice 

of injury to the Department of Financial Responsibility in Tallahassee, Florida

and to the city mayor. 

49. A copy of the notice was also sent to the Mayor of North Bay Village. City 

Officials have made no attempt to resolve the claims, and has forced Plaintiff 

to file this action seeking relief and damages.

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COUNT ONE

RESOPNDENT SUPERIOR

CITY OF NORTH BAY VILLAGE

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

50. The City of North Bay Village is a city located in Miami-Dade County, 

Florida which possesses its own Police Department.

51. On January 30, 2018 at least seven North Bay Village Police Officer acting 

within the scope of their employment and under color of law raided Plaintiffs’ 

home subjecting them to battery, home invasion, intentional infliction of 

emotional distress, excessive force, false imprisonment and being placed in 

handcuffs for an extended period of time. 

52. The city of North Bay Villages Police Officer conduct was tantamount to 

negligence and intentional torts which are covered under the doctrine of 

respondent superior. 

53. The city of North bay Village is not immune from liability for intentional torts 

committed by its police officers in course or scope of their employment.

54. The aforementioned actions took place without probable cause, arguable 

probable cause, exigent circumstances, a warrant, or credible information that 

a crime had been committed therein constituting an unlawful detention of all 

Plaintiffs.

55. Officers from the city of North bay Village handcuffed Plaintiffs Williams 

and Aigoro and seated them on the couch, held and questioned them at 

gunpoint while the child watched in visible fear. 

56. No officer on the scene intervened to protect Plaintiffs constitutional rights 

guaranteed by the first and fourth amendment. 

57. Plaintiffs’ detention was unreasonable and not warranted by the 

circumstances.

58. Plaintiffs will be seek damages which are outlined in the prayer for relief.

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COUNT TWO

VIOLATION OF Civil Rights While Acting Under The

Color of Law 42 U.S.C. 1983; False Imprisonment.

Lt. Brian Collins

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

59. Plaintiffs files this count against Lt. Brian Collins of the North Bay Village 

Police Department for his presence and participation in a police raid that took 

place at Plaintiffs’ home on or about January 30, 2018. 

60. At all times hereto, Lt. Collins was operating under color of law for the City 

of North Bay Village Police Department which is located in Miami-Dade 

County, Florida.

61. Prior to entering Plaintiff’s home, an officer under the control of Chief 

Noriega pried open the front door lock to Plaintiffs’ home and officers from 

his department proceeded in with their military style assault weapons drawn 

and trained on the Plaintiffs. 

62. The aforementioned actions took place without probable cause, arguable 

probable cause, exigent circumstances, a warrant, or credible information that 

a crime had been committed therein constituting an unlawful detention of all 

Plaintiffs.

63. Officers from the North Bay Village Police Department handcuffed Plaintiffs 

Williams and Aigoro seating them on the couch and questioned them at 

gunpoint while the minor child watched in visible fear. 

64. Plaintiffs’ detention was intentional as Plaintiffs were not free to leave which 

violates their clearly established constructional rights. 

65. Plaintiffs’ detention was unreasonable and not warranted by the 

circumstances.

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COUNT THREE

VIOLATION OF Civil Rights While Acting Under The

Color of Law 42 U.S.C. 1983; False Imprisonment.

Detective Sam Bejar

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

66. Plaintiffs files this count against Detective Sam Bejar of the North Bay 

Village Police Department for his presence and participation in a police raid 

that took place at Plaintiffs’ home on or about January 30, 2018. 

67. At all times hereto, Detective Bejar was operating under color of law for the 

City of North Bay Village Police Department which is located in Miami-Dade 

County, Florida.

68. Prior to entering Plaintiff’s home, an officer under the control of Chief 

Noriega pried open the front door lock to Plaintiffs’ home and officers from 

his department proceeded in with their military style assault weapons drawn 

and trained on the Plaintiffs. 

69. The aforementioned actions took place without probable cause, arguable 

probable cause, exigent circumstances, a warrant, or credible information that 

a crime had been committed therein constituting an unlawful detention of all 

Plaintiffs.

70. Officers from the North Bay Village Police Department handcuffed Plaintiffs 

Williams and Aigoro seating them on the couch and questioned them at 

gunpoint while the minor child watched in visible fear. 

71. Plaintiffs’ detention was intentional as Plaintiffs were not free to leave which 

violates their clearly established constructional rights. 

72. Plaintiffs’ detention was unreasonable and not warranted by the 

circumstances.

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COUNT FOUR

VIOLATION OF Civil Rights While Acting Under The

Color of Law 42 U.S.C. 1983; False Imprisonment.

Officer Jose Martinez 

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

73. Plaintiffs files this count against Officer Jose Martinez of the North Bay 

Village Police Department for his presence and participation in a police raid 

that took place at Plaintiffs’ home on or about January 30, 2018. 

74. At all times hereto, Officer Jose Martinez was operating under color of law 

for the City of North Bay Village Police Department which is located in 

Miami-Dade County, Florida.

75. Prior to entering Plaintiff’s home, an officer under the control of Chief 

Noriega pried open the front door lock to Plaintiffs’ home and officers from 

his department proceeded in with their military style assault weapons drawn 

and trained on the Plaintiffs. 

76. The aforementioned actions took place without probable cause, arguable 

probable cause, exigent circumstances, a warrant, or credible information that 

a crime had been committed therein constituting an unlawful detention of all 

Plaintiffs.

77. Officers from the North Bay Village Police Department handcuffed Plaintiffs 

Williams and Aigoro seating them on the couch and questioned them at 

gunpoint while the minor child watched in visible fear. 

78. Plaintiffs’ detention was intentional as Plaintiffs were not free to leave which 

violates their clearly established constructional rights. 

79. Plaintiffs’ detention was unreasonable and not warranted by the circumstances

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COUNT FIVE

VIOLATION OF Civil Rights While Acting Under The

Color of Law 42 U.S.C. 1983; False Imprisonment.

Officer Frank Pieiga 

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

80. Plaintiffs files this count against Officer Frank Pieiga of the North Bay 

Village Police Department for his presence and participation in a police raid 

that took place at Plaintiffs’ home on or about January 30, 2018. 

81. At all times hereto, Officer Frank Pieiga was operating under color of law 

for the City of North Bay Village Police Department which is located in 

Miami-Dade County, Florida.

82. Prior to entering Plaintiff’s home, an officer under the control of Chief 

Noriega pried open the front door lock to Plaintiffs’ home and officers from 

his department proceeded in with their military style assault weapons drawn 

and trained on the Plaintiffs. 

83. The aforementioned actions took place without probable cause, arguable 

probable cause, exigent circumstances, a warrant, or credible information that 

a crime had been committed therein constituting an unlawful detention of all 

Plaintiffs.

84. Officers from the North Bay Village Police Department handcuffed Plaintiffs 

Williams and Aigoro seating them on the couch and questioned them at 

gunpoint while the minor child watched in visible fear. 

85. Plaintiffs’ detention was intentional as Plaintiffs were not free to leave which 

violates their clearly established constructional rights. 

86. Plaintiffs’ detention was unreasonable and not warranted by the 

circumstances.

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COUNT SIX

VIOLATION OF Civil Rights While Acting Under The

Color of Law 42 U.S.C. 1983; False Imprisonment.

Officer Walter Sajdak

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

87. Plaintiffs files this count against Officer Walter Sajdak of the North Bay 

Village Police Department for his presence and participation in a police raid 

that took place at Plaintiffs’ home on or about January 30, 2018. 

88. At all times hereto, Officer Walter Sajdak was operating under color of law 

for the City of North Bay Village Police Department which is located in 

Miami-Dade County, Florida.

89. Prior to entering Plaintiff’s home, an officer under the control of Chief 

Noriega pried open the front door lock to Plaintiffs’ home and officers from 

his department proceeded in with their military style assault weapons drawn 

and trained on the Plaintiffs. 

90. The aforementioned actions took place without probable cause, arguable 

probable cause, exigent circumstances, a warrant, or credible information that 

a crime had been committed therein constituting an unlawful detention of all 

Plaintiffs.

91. Officers from the North Bay Village Police Department handcuffed Plaintiffs 

Williams and Aigoro seating them on the couch and questioned them at 

gunpoint while the minor child watched in visible fear. 

92. Plaintiffs’ detention was intentional as Plaintiffs were not free to leave which 

violates their clearly established constructional rights. 

93. Plaintiffs’ detention was unreasonable and not warranted by the 

circumstances.

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COUNT SEVEN

VIOLATION OF Civil Rights While Acting Under The

Color of Law 42 U.S.C. 1983; False Imprisonment.

Officer Hubert Molina

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

94. Plaintiffs files this count against Officer Hubert Molina of the North Bay 

Village Police Department for his presence and participation in a police raid 

that took place at Plaintiffs’ home on or about January 30, 2018. 

95. At all times hereto, Officer Hubert Molina was operating under color of law 

for the City of North Bay Village Police Department which is located in 

Miami-Dade County, Florida.

96. Prior to entering Plaintiff’s home, an officer under the control of Chief 

Noriega pried open the front door lock to Plaintiffs’ home and officers from 

his department proceeded in with their military style assault weapons drawn 

and trained on the Plaintiffs. 

97. The aforementioned actions took place without probable cause, arguable 

probable cause, exigent circumstances, a warrant, or credible information that 

a crime had been committed therein constituting an unlawful detention of all 

Plaintiffs.

98. Officers from the North Bay Village Police Department handcuffed Plaintiffs 

Williams and Aigoro seating them on the couch and questioned them at 

gunpoint while the minor child watched in visible fear. 

99. Plaintiffs’ detention was intentional as Plaintiffs were not free to leave which 

violates their clearly established constructional rights. 

100. Plaintiffs’ detention was unreasonable and not warranted by the 

circumstances.

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COUNT EIGHT

VIOLATION OF Civil Rights While Acting 

Under Color of Law 42 U.S.C. 1983 EXCESSIVE FORCE

Lt. Brian Collins

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

101. On or about January 30, 2018, Lt. Brian Collins and approximately six 

officer from the North Bay Village Police Department participated in a raid 

on Plaintiffs’ home. 

102. An officer pried open Plaintiffs’ locked front door, and the rest entered and 

placed Williams and Aigoro in handcuffs holding them at bay without 

probable cause or an arrest warrant. 

103. Plaintiffs were placed on their couch and questioned for an extended period 

of time. Plaintiffs were not free to leave.

104. The 3 year old child in in the home (K.W.) who watched in horror unfold as 

his father and step-mother were being accosted by the heavily armed officers. 

At one point one of the officers trained a weapon on the child’s head

105. The force used against the Plaintiffs was without provocation, without 

legitimate penal justification, and no officer on the scene tried to stop the 

unprovoked and unjustified excessive force against the Plaintiffs. 

106. The actions of Collins, were performed under color of state law and violated 

Plaintiffs’ rights under the First, Fourth and Fourteenth Amendment of the 

United States Constitution.

107. The acts of excessive force by Brian Collins was the direct and proximate 

cause of serious and ongoing injuries to Plaintiffs.

108. The conduct of Collins was willful and exhibited a flagrant disregard for 

Plaintiffs’ federally secured due process rights, and accordingly this 

Defendant is liable to Petitioner under 42 USC 1983.

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COUNT NINE

VIOLATION OF Civil Rights While Acting 

Under Color of Law 42 U.S.C. 1983 EXCESSIVE FORCE

Detective Sam Bejar

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49 above 

and incorporates same herein by reference.

109. On or about January 30, 2018, Detective Sam Bejar and approximately six 

officer from the North Bay Village Police Department participated in a raid 

on Plaintiffs’ home. 

110. An officer pried open Plaintiffs’ locked front door, and the rest entered and 

placed Williams and Aigoro in handcuffs holding them at bay without 

probable cause or an arrest warrant. 

111. Plaintiffs were placed on their couch and questioned for an extended period 

of time. Plaintiffs were not free to leave.

112. The 3 year old child in in the home (K.W.) who watched in horror unfold as 

his father and step-mother were being accosted by the heavily armed officers. 

At one point one of the officers trained a weapon on the child’s head

113. The force used against the Plaintiffs was without provocation, without 

legitimate penal justification, and no officer on the scene tried to stop the 

unprovoked and unjustified excessive force against the Plaintiffs. 

114. The actions of Bejar, were performed under color of state law and violated 

Plaintiffs’ rights under the First, Fourth and Fourteenth Amendment of the 

United States Constitution.

115. The acts of excessive force by Sam Bejar was the direct and proximate cause 

of serious and ongoing injuries to Plaintiffs.

116. The conduct of Bejar was willful and exhibited a flagrant disregard for 

Plaintiffs’ federally secured due process rights, and accordingly this 

Defendant is liable to Petitioner under 42 USC 1983.

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COUNT TEN

VIOLATION OF Civil Rights While Acting

Under Color of Law 42 U.S.C. 1983 EXCESSIVE FORCE

Officer Jose Martinez 

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

117. On or about January 30, 2018, Officer Jose Martinez and approximately six 

police officer from the North Bay Village Police Department participated in a 

raid on Plaintiffs’ home. 

118. An officer pried open Plaintiffs’ locked front door, and others entered and 

placed Williams and Aigoro in handcuffs holding them at bay without 

probable cause, arguable probable cause, hot pursuit or exigent circumstances 

or an arrest warrant. 

119. Plaintiffs were placed on their couch and questioned for an extended period 

of time and as such were not free to leave.

120. A 3 year old child in in the home (K.W.) who watched in horror as his father 

and step-mother were being accosted by the heavily armed officers. 

121. At one point one of an officers maliciously and illegally trained a weapon on 

the child’s head.

122. The force Officer Jose Martinez used against the Plaintiffs was without 

provocation, without legitimate penal justification, and no officer on the scene 

tried to stop the unprovoked and unjustified excessive force against the 

Plaintiffs. 

123. The actions of Officer Jose Martinez were performed under color of state law 

and violated Plaintiffs’ rights under the First, Fourth and Fourteenth 

Amendment to the United States Constitution.

124. The acts of excessive force by Officer Jose Martinez was the direct and 

proximate cause of serious and ongoing injuries to Plaintiffs.

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125. The conduct of Officer Jose Martinez was willful and exhibited a flagrant 

disregard for Plaintiffs’ federally secured due process rights, and accordingly 

this Defendant is liable to Petitioner under 42 USC 1983.

126. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT ELEVEN

VIOLATION OF Civil Rights While Acting

Under Color of Law 42 U.S.C. 1983 EXCESSIVE FORCE

Officer Frank Pieiga 

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

127. On or about January 30, 2018, Officer Frank Pieiga and approximately six 

police officer from the North Bay Village Police Department participated in a 

raid on Plaintiffs’ home. 

128. An officer pried open Plaintiffs’ locked front door, and others entered and 

placed Williams and Aigoro in handcuffs holding them at bay without 

probable cause, arguable probable cause, hot pursuit or exigent circumstances 

or an arrest warrant. 

129. Plaintiffs were placed on their couch and questioned for an extended period 

of time and as such were not free to leave.

130. A 3 year old child in in the home (K.W.) who watched in horror as his father 

and step-mother were being accosted by the heavily armed officers. 

131. At one point one of an officers maliciously and illegally trained a weapon on 

the child’s head.

132. The force Officer Frank Pieiga used against the Plaintiffs was without 

provocation, without legitimate penal justification, and no officer on the scene 

tried to stop the unprovoked and unjustified excessive force against the 

Plaintiffs. 

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133. The actions of Officer Frank Pieiga were performed under color of state law 

and violated Plaintiffs’ rights under the First, Fourth and Fourteenth 

Amendment to the United States Constitution.

134. The acts of excessive force by Officer Frank Pieiga was the direct and 

proximate cause of serious and ongoing injuries to Plaintiffs.

135. The conduct of Officer Frank Pieiga was willful and exhibited a flagrant 

disregard for Plaintiffs’ federally secured due process rights, and accordingly 

this Defendant is liable to Petitioner under 42 USC 1983.

136. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT TWELVE

VIOLATION OF Civil Rights While Acting

Under Color of Law 42 U.S.C. 1983 EXCESSIVE FORCE

Officer Walter Sajdak 

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

137. On or about January 30, 2018, Officer Walter Sajdak and approximately six 

police officer from the North Bay Village Police Department participated in a 

raid on Plaintiffs’ home. 

138. An officer pried open Plaintiffs’ locked front door, and others entered 

slammed Williams and Aigoro and slammed Williams and Aigoro to the floor 

and placed them in handcuffs holding them at bay.

139. This was done without probable cause, arguable probable cause, hot pursuit 

or exigent circumstances or an arrest warrant. 

140. Plaintiffs were placed on their couch and questioned for an extended period 

of time and as such were not free to leave.

141. A 3 year old child in in the home (K.W.) who watched in horror as his father 

and step-mother were being accosted by the heavily armed officers. 

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142. At one point one of an officers maliciously and illegally trained a weapon on 

the child’s head.

143. The force Officer Walter Sajdak used against the Plaintiffs was without 

provocation, without legitimate penal justification, and no officer on the scene 

tried to stop the unprovoked and unjustified excessive force against the 

Plaintiffs. 

144. The actions of Officer Walter Sajdak were performed under color of state law 

and violated Plaintiffs’ rights under the First, Fourth and Fourteenth 

Amendment to the United States Constitution.

145. The acts of excessive force by Officer Walter Sajdak was the direct and 

proximate cause of serious and ongoing injuries to Plaintiffs.

146. The conduct of Officer Walter Sajdak was willful and exhibited a flagrant 

disregard for Plaintiffs’ federally secured due process rights, and accordingly 

this Defendant is liable to Petitioner under 42 USC 1983.

147. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT THIRTEEN

VIOLATION OF Civil Rights While Acting

Under Color of Law 42 U.S.C. 1983 EXCESSIVE FORCE

Officer Huberto Molina

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

148. On or about January 30, 2018, Officer Hubert Molina and approximately six 

police officer from the North Bay Village Police Department participated in a 

raid on Plaintiffs’ home. 

149. An officer pried open Plaintiffs’ locked front door, and others entered and 

slammed Williams and Aigoro to the floor placing them in handcuffs holding 

them at bay without probable cause, arguable probable cause, hot pursuit or 

exigent circumstances or an arrest warrant. 

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150. Plaintiffs were placed on their couch and questioned for an extended period 

of time and as such were not free to leave.

151. A 3 year old child in in the home (K.W.) who watched in horror as his father 

and step-mother were being accosted by the heavily armed officers. 

152. At one point one of an officers maliciously and illegally trained a weapon on 

the child’s head.

153. The force Officer Hubert Molina used against the Plaintiffs was without 

provocation, without legitimate penal justification, and no officer on the scene 

tried to stop the unprovoked and unjustified excessive force against the 

Plaintiffs. 

154. The actions of Officer Hubert Molina were performed under color of state law 

and violated Plaintiffs’ rights under the First, Fourth and Fourteenth 

Amendment to the United States Constitution.

155. The acts of excessive force by Officer Hubert Molina was the direct and 

proximate cause of serious and ongoing injuries to Plaintiffs.

156. The conduct of Officer Hubert Molina was willful and exhibited a flagrant 

disregard for Plaintiffs’ federally secured due process rights, and accordingly 

this Defendant is liable to Petitioner under 42 USC 1983.

157. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT FOURTEEN

FAILURE TO INTERVENE 42 USC 1983

Lt. Brian Collins

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

158. Plaintiffs filing this count against defendant, Lt. Brian Collins as he is directly 

responsible for his actions and the actions of other officers from the North 

Bay Village Police Department. 

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159. As a Police Lt. Brian Collins, had a duty to intervene when fellow officer 

violated Plaintiffs clearly established constitutional rights including but not 

limited to excessive force, to be free from illegal search and seizure, and false 

arrest.

160. Lt. Brian Collins stood by at the scene and watched the entire event and was 

in voice and visual contact with the offending officers.

161. Lt. Collins had time and a duty to intervene and order the offending officers 

not to commit the constitutional violations but failed to do so. 

162. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT FIFTEEN

FAILURE TO INTERVENE 42 USC 1983

Detective Sam Bejar

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

163. Plaintiffs filing this count against defendant, Detective Sam Bejar as he is 

directly responsible for his actions and the actions of other officers from the 

North Bay Village Police Department. 

 

164. As a Detective, Sam Bejar had a duty to intervene when his fellow officer 

violated Plaintiffs clearly established constitutional rights including but not 

limited to excessive force, to be free from illegal search and seizure, and false 

arrest.

165. Detective Sam Bejar stood by at the scene and watched the entire event and 

was in voice and visual contact with the offending officers.

166. Bejar had time and a duty to intervene and order the offending officers not to 

commit the constitutional violations but failed to do so. 

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167. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT SIXTEEN

FAILURE TO INTERVENE 42 USC 1983

Officer Jose Martinez

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

168. Plaintiffs filing this count against Officer Jose Martinez as he is directly 

responsible for his actions and the actions of the other officers from the North 

Bay Village Police Department. 

 

169. Officer Jose Martinez had a duty to intervene when his fellow officer violated 

Plaintiffs clearly established constitutional rights including but not limited to 

excessive force, illegal search and seizure, and false arrest.

170. Officer Jose Martinez stood by at the scene and watched the entire event as he 

and was in voice and visual contact with the offending officers.

171. Officer Jose Martinez had time and a duty to intervene and order the offending 

officer not to commit the constitutional violations but failed to do so. 

172. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT SEVENTEEN

FAILURE TO INTERVENE 42 USC 1983

Officer Frank Pieiga

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

173. Plaintiffs filing this count against Officer Frank Pieiga is directly responsible 

for his actions and the actions of the other officers from the North Bay Village 

Police Department. 

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174. Officer Frank Pieiga had a duty to intervene when his fellow officer violated 

Plaintiffs clearly established constitutional rights including but not limited to 

excessive force, illegal search and seizure, and false arrest.

175. Officer Frank Pieiga stood by at the scene and watched the entire event as he 

and was in voice and visual contact with the offending officers.

176. Officer Frank Pieiga had time and a duty to intervene and order the offending 

officer not to commit the constitutional violations but failed to do so. 

177. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

COUNT EIGHTEEN

FAILURE TO INTERVENE 42 USC 1983

Officer Walter Sajdak

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

178. Plaintiffs filing this count against Officer Walter Sajdak he is directly 

responsible for his actions and the actions of the other officers from the North 

Bay Village Police Department. 

179. Officer Walter Sajdak had a duty to intervene when his fellow officer violated 

Plaintiffs clearly established constitutional rights including but not limited to 

excessive force, illegal search and seizure, and false arrest.

180. Officer Walter Sajdak stood by at the scene and watched the entire event as 

he and was in voice and visual contact with the offending officers.

181. Officer Walter Sajdak had time and a duty to intervene and order the offending 

officer not to commit the constitutional violations but failed to do so. 

182. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

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COUNT NINETEEN

FAILURE TO INTERVENE 42 USC 1983

Officer Hubert Molina

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

183. Plaintiffs filing this count against Officer Molina as he is directly responsible 

for his actions and the actions of the other officers from the North Bay Village 

Police Department. 

184. Officer Hubert Molina had a duty to intervene when his fellow officer violated 

Plaintiffs clearly established constitutional rights including but not limited to 

excessive force, illegal search and seizure, and false arrest.

185. Officer Molina stood by at the scene and watched the entire event as he and 

was in voice and visual contact with the offending officers.

186. Officer Molina had time and a duty to intervene and order the offending 

officer not to commit the constitutional violations but failed to do so. 

187. A substantive due process violation exists where rights are violated no matter 

what process precedes, accompanies, or follows the unconstitutional action.

188. Before the officers left the home one of the officers placed a gun to the child’s 

head to further intimidate the Plaintiffs.

COUNT TWENTY

FALSE ARREST/FALSE IMPRISONMENT

Lt. Brian Collins

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

189. This count sets forth claims on behalf of Plaintiffs, (Williams, Aigoro and KW 

a minor), against Defendant Brian Collins for common law false 

imprisonment/arrest, and is pled in the alternative. For the purpose of this 

count, the actions of this Defendants was outside the course and scope of his

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employment with the City of North Bay Village and the laws of the state of 

Florida. 

190. These Plaintiffs are entitled to relief against Defendant Lt. Brian Collins in 

that this Defendant intentionally and unlawfully detained and restrained these 

Plaintiffs against their will, deprived them of their liberty without any 

reasonable cause, and maintained such complete restraint and deprivation for 

a period of time 

191. This unlawful restraint of these Plaintiffs’ liberty was also accomplished by 

this Defendant in confining these Plaintiffs to an area or areas in which they 

did not wish to be confined, and/or by compelling these Plaintiffs to go where 

they did not wish to go. 

192. These Plaintiffs were further restrained by these Defendants through the use 

of his displayed of weapon, coercive words, threats of force as well as actual 

force, and immediate means of coercion against these Plaintiffs, so that these 

Plaintiffs were restrained and deprived of liberty. This Defendants restrained 

these Plaintiffs without any justification and in the absence of probable cause. 

193. At all pertinent times, and at all times during which these Plaintiffs were being 

unlawfully restrained, they were restrained against their will, and without 

consent, so that these Plaintiffs were not free to leave their places of 

confinement. These Defendants acted in bad faith and/or with malicious 

purpose or in a manner exhibiting wanton and willful disregard of human 

rights or safety. 

COUNT TWENTY-ONE

FALSE ARREST/FALSE IMPRISONMENT

Detective Sam Bejar

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

194. This count sets forth claims on behalf of Plaintiffs, (Williams, Aigoro and KW 

a minor), against Defendant Brian Collins for common law false 

imprisonment/arrest, and is pled in the alternative. For the purpose of this 

count, the actions of this Defendants was outside the course and scope of his 

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employment with the City of North Bay Village and the laws of the state of 

Florida. 

195. These Plaintiffs are entitled to relief against Defendant Det. Brian Collins and 

in that this Defendant intentionally and unlawfully detained and restrained 

these Plaintiffs against their will, deprived them of their liberty without any 

reasonable cause, and maintained such complete restraint and deprivation for 

a period of time 

196. This unlawful restraint of these Plaintiffs’ liberty was also accomplished by 

this Defendant in confining these Plaintiffs to an area or areas in which they 

did not wish to be confined, and/or by compelling these Plaintiffs to go where 

they did not wish to go. 

197. These Plaintiffs were further restrained by these Defendants through the use 

of his displayed of weapon, coercive words, threats of force as well as actual 

force, and immediate means of coercion against these Plaintiffs, so that these 

Plaintiffs were restrained and deprived of liberty. This Defendants restrained 

these Plaintiffs without any justification and in the absence of probable cause. 

198. At all pertinent times, and at all times during which these Plaintiffs were being 

unlawfully restrained, they were restrained against their will, and without 

consent, so that these Plaintiffs were not free to leave their places of 

confinement. These Defendants acted in bad faith and/or with malicious 

purpose or in a manner exhibiting wanton and willful disregard of human 

rights or safety. 

COUNT TWENTY-TWO

FALSE ARREST/FALSE IMPRISONMENT

Officer Jose Martinez

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

199. This count sets forth claims on behalf of Plaintiffs, (Williams, Aigoro and KW 

a minor), against Officer Jose Martinez for common law false 

imprisonment/arrest, and is pled in the alternative. 

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200. For the purpose of this count, the actions of this Defendants was outside the 

course and scope of his employment with the City of North Bay Village and 

the laws of the state of Florida. 

201. These Plaintiffs are entitled to relief against Defendant Officer Martinez and 

in that this Defendant intentionally and unlawfully detained and restrained 

these Plaintiffs against their will, deprived them of their liberty without any 

reasonable cause, and maintained such complete restraint and deprivation for 

a period of time 

202. This unlawful restraint of these Plaintiffs’ liberty was also accomplished by 

this Defendant in confining these Plaintiffs to an area or areas in which they 

did not wish to be confined, and/or by compelling these Plaintiffs to go where 

they did not wish to go. 

203. These Plaintiffs were further restrained by these Defendants through the use 

of his displayed of weapon, coercive words, threats of force as well as actual 

force, and immediate means of coercion against these Plaintiffs, so that these 

Plaintiffs were restrained and deprived of liberty. This Defendants restrained 

these Plaintiffs without any justification and in the absence of probable cause. 

204. At all pertinent times, and at all times during which these Plaintiffs were being 

unlawfully restrained against their will, and without consent, so that these 

Plaintiffs were not free to leave their places of confinement. These Defendants 

acted in bad faith and/or with malicious purpose or in a manner exhibiting 

wanton and willful disregard of human rights or safety. 

COUNT TWENTY-THREE

FALSE ARREST/FALSE IMPRISONMENT

Officer Frank Pieiga

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

205. This count sets forth claims on behalf of Plaintiffs, (Williams, Aigoro and KW 

a minor), against Defendant Officer Frank Pieiga for common law false 

imprisonment/arrest, and is pled in the alternative. For the purpose of this 

count, the actions of this Defendant was outside the course and scope of his

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employment with the City of North Bay Village and the laws of the state of 

Florida. 

206. These Plaintiffs are entitled to relief against Defendant Det. Brian Collins and 

in that this Defendant intentionally and unlawfully detained and restrained 

these Plaintiffs against their will, deprived them of their liberty without any 

reasonable cause, and maintained such complete restraint and deprivation for 

a period of time 

207. This unlawful restraint of these Plaintiffs’ liberty was also accomplished by 

this Defendants in confining these Plaintiffs to an area or areas in which they 

did not wish to be confined, and/or by compelling these Plaintiffs to go where 

they did not wish to go. 

208. These Plaintiffs were further restrained by these Defendants through their use 

of his display of weapon, coercive words, threats of force as well as actual 

force, and immediate means of coercion against these Plaintiffs, so that these 

Plaintiffs were restrained and deprived of liberty. These Defendants restrained 

these Plaintiffs without any justification and in the absence of probable cause. 

209. At all pertinent times, and at all times during which these Plaintiffs were being 

unlawfully restrained, they were restrained against their will, and without 

consent, so that these Plaintiffs were not free to leave their places of 

confinement. These Defendants acted in bad faith or with malicious purpose 

or in a manner exhibiting wanton and willful disregard of human rights or 

safety. 

COUNT TWENTY-FOUR

FALSE ARREST/FALSE IMPRISONMENT

Officer Walter Sadjak

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

210. This count sets forth claims on behalf of Plaintiffs, (Williams, Aigoro and KW 

a minor), against Defendant, Officer Walter Sadjak for common law false 

imprisonment/arrest, and is pled in the alternative. For the purpose of this 

count, the actions of these Defendants were outside the course and scope of 

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his employment with the City of North Bay Village and the laws of the state 

of Florida. 

211. These Plaintiffs are entitled to relief against Defendant, Officer Walter 

Sadjak, and in that this Defendant intentionally and unlawfully detained and 

restrained these Plaintiffs against their will, deprived them of their liberty 

without any reasonable cause, and maintained such complete restraint and 

deprivation for a period of time 

212. This unlawful restraint of these Plaintiffs’ liberty was also accomplished by 

this Defendants in confining these Plaintiffs to an area or areas in which they 

did not wish to be confined, and/or by compelling these Plaintiffs to go where 

they did not wish to go. 

213. These Plaintiffs were further restrained by this Defendant through use of his 

display of a service weapon, coercive words, threats of force as well as actual 

force, and immediate means of coercion against these Plaintiffs, so that these 

Plaintiffs were restrained and deprived of liberty. This Defendants restrained 

these Plaintiffs without any justification and in the absence of probable cause. 

214. At all pertinent times, and at all times during which these Plaintiffs were being 

unlawfully restrained, they were restrained against their will, and without 

consent, so that these Plaintiffs were not free to leave their places of 

confinement. This Defendants acted in bad faith and/or with malicious 

purpose or in a manner exhibiting wanton and willful disregard of human 

rights or safety. 

COUNT TWENTY-FIVE

FALSE ARREST/FALSE IMPRISONMENT

Officer Hubert Molina

Plaintiff re-alleges the allegations set forth in Paragraphs 1-49

above and incorporates same herein by reference.

215. This count sets forth claims on behalf of Plaintiffs, (Williams, Aigoro and KW 

a minor), against Defendant Hubert Molina for common law false 

imprisonment/arrest, and is pled in the alternative. For the purpose of this 

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count, the actions of these Defendants were outside the course and scope of 

their employment with the City of North Bay Village and the state of Florida. 

216. These Plaintiffs are entitled to relief against Defendant Hubert Molina and in 

that this Defendant intentionally and unlawfully detained and restrained these 

Plaintiffs against their will, deprived them of their liberty without any 

reasonable cause, and maintained such complete restraint and deprivation for 

a period of time 

217. This unlawful restraint of these Plaintiffs’ liberty was also accomplished by 

this Defendants in confining these Plaintiffs to an area or areas in which they 

did not wish to be confined, and/or by compelling these Plaintiffs to go where 

they did not wish to go. 

218. These Plaintiffs were further restrained by these Defendants through their use 

of his display of weapon, coercive words, threats of force as well as actual 

force, and immediate means of coercion against these Plaintiffs, so that these 

Plaintiffs were restrained and deprived of liberty. These Defendants restrained 

these Plaintiffs without any justification and in the absence of probable cause. 

219. At all pertinent times, and at all times during which these Plaintiffs were being 

unlawfully restrained, they were restrained against their will, and without 

consent, so that these Plaintiffs were not free to leave their places of 

confinement. These Defendants acted in bad faith or with malicious purpose 

or in a manner exhibiting wanton and willful disregard of human rights or 

safety. 

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PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for the following relief:

a. Judgment for compensatory damages in excess of $75,000 dollars

b. Cost of Suit

c. General Damages

d. Compensatory damages

e. Damages for pain and suffering

f. mental anguish

g. Punitive damages

h. Trial by jury as to all issues so triable; and

i. Embarrassment and humiliation

j Loss of capacity for enjoyment of life

k. Such other relief as this Honorable Court may deem just and 

appropriate.

JURY DEMAND

Plaintiffs demands a trial by jury of all issues so triable pursuant to Rule 38 

of the Federal Rules of Civil Procedure.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have e-filed this amended complaint to the clerk 

of court and to Defendants’ attorney’s at their designated e-mail addresses listed this 

May 19, 2020.

Respectfully submitted by,

 

/s/Gregory D. Curtis Esq. 

Gregory D. Curtis Esq.

17325 N.W. 27th Avenue Suite 103

Miami Gardens, Florida 33056

Florida Bar No.: 0492108 

Tel: (305) 622 9199 

Fax: (305) 622 9129 

Florida Bar # 0492108

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