FILED BY D.C.

JLd 2 i 2222

ANGELA E. NOBLE

c LE R K .tJ s . DI S .T cm

S. n, OF FtA. - FT. LAUD.

M r. Piero A Bugoni Pro - Se

160 W Cam ino Rcal #191

l3oca Raton, FL 33432

IN T1-1E UNITED STATES DIS'1'RIC'I' COURT

IN AND FOR 'I-HE DISTRIC'I' OF l7l-()RlDA

Pi Casc No.: ero A . Bugoni

PLA INTIFF

vs

Broward County Florida,

Gfegory Tony,

E merald Towing,

Emcrald Towing Towing Agcnt

BCSO Dcpblty Scpot

l3CSO D eputy A lvarcz

BCSO D cputy Fitzpatrick

BCSO D eputy Laing

U nknown BCSO Deputy //1

Unknown BCSO Dcputy #2

U nkntlwn BCSO D eputy //3

DEFEND A NTS

C OM PLA INT A ND

CRIMINAL REPORT AFFIDAVIT

JURY DEH AN DED

1. Jurisdiction And Ventle:

I7laintiff seeks more than $75,000 in dam ages, and becattse llcfcndant Em erald Towing is a

l-florida Ctll-ptll-atitln opcrating in and doing business in this State.

A 11 statutory claim s of Jurisdiction are pursuant to Thc Constittltion ()f The U nited

States of A l-nerica, and pcr A rticle 11l thercof.

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3) F'cdcral Question:

This Colmplaint Pleads on its face Federal Qtlcstions purstlant t() 42 U.S.C. j 1983 et seq.,

and l 8 U.S.C. $ 24 1 ct scq.

Supplemental Jurisdiction.

This Court m ay supplem cnt its Jurisdiction in this M attcr w ith Florida State Law because

thc statutory violations of Florida Law com m ittcd by D cfcndants are inscparable in nexus to

thc Fcdcral Claims presentcd.

28 U.S.C. j 1 39 1 grants Venue hcrcin becatlsc thc acts of dcfendant that arc charged

by claim hcrein wcrc com m ittcd, and thc dam ages causcd by that conduct, w crc incurrcd by

Plaintiffs, and are being incun-ed in thc State ()f Florida.

11. Partics :

6) Broward County Florida, a M unicipal Corporation and Political Subdivision of Thc

Statc of Florida, as Rcspondcat Supcrior liable for thc actions of its O fficcrs and quasigovcrnm cntal agcnts.

G regory 'l-ony in his O fficial Capacity as supcrvising officcr rcsponsiblc for the

actions of his subordinatc officers, and individually as responsiblc for his actions in his

O fficial Capacity as Sheriff of Broward County, an O fficcr of trust, of thc State of Florida.

8) Em crald Towing, a Florida Corporation, acting in :1 quasi-govcrnm ental capacity.

9) E- m erald Towing Agcnt, an ind ividual person actual llannc unknown, ind ividually and

in his capacity as :1 quasi-govcrnlucntal officer for-p. rofit.

28

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BCSO Dcputy Scpot individuallys and in his Official Capacity as an Officer, tbr-profit

()f the Statc of Florida.

BCSO Deputy Alvarez individtlally, and in his Official Capaeity as an Offieer forprofit of the State of Florida.

BCSO Dcputy Fitzpatrick individually and in hcr Official Capacity as an Offiecr forprofit of thc State of Florida.

BCSO D eputy Laing individually and in hcr O fficial Capacity as a14 O fficer for-profit

of the Statc of Florida.

l4) Unknown BCSO Dcputy #1 individttally and in hcr Official Capacity as an Officcr

for-profit ()f the State of Florida.

Unknow n BCSO D eputy #2 individually and in hcr O fficial Capacity as an O fficer

for-p. rofit ()f the Statc of Florida.

Unknown BCSO Deputy #3 individually and in his Offieial Capaeity as an Offieer forprofit of the State of Florida.

111. Short And Plain Statem ent 0 1' Claim :

This Colmp. laint allcgcs Five Counts against BroNvard County O fficers of trust. and forprofit, and against quasi-govelmluental actors for unlaw ful scizure of Ilcrson and Prop. crty,

for violating Plaintifps ltight to Privacy and -1-0 R clmain S ilent, and for l-larassm ent by Statc

O fficers acting under Color of Official Right. lt alleges both tortious and crim inal violations

28 of Law by the individtlal, official and quasi-governm ental D efendants. Brow ard County

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1 Sheriff Gregory Tony is held liable for failure t() properly train, supervise, and maintain

Constitutional and Statutory Compliance by his subordinatcs. Broward County Florida is

hcld liablc as Respondeat Superior for thc tortious and crim inal conduct conducted undcr

Color of Official Right by its Official Actors.

1V . Facts:

0n 17 M ay 2020 E m crald Towing by and through its individtlal Agent, and with the

aid of and at the solicitation of Dcfcndants Sepot, Fitzpatrick, and Alvarez did in violation of

U nited Statcs Constitution A m endm ent IV scize one rental M otor V ehicle w orth m ore than

$20,000 from Plaintiff, costing him a $300 lm pound Fee, plus m orc than $400 in additional

costs for storagc of thc vehicle, and accrucd rcntal chargcs for failurc t() relcasc the vchicle

to its Rightful Owner. Defcndants had no right whatsocvcr t() takc that vehiclc, and because

they w cre acting as govelmm cnt agents and quasi-govcrnm ental agcnts did act under Color

of Official Right and in violation ()f 42 U.S.C. j

19) Bccause Defendants that did take the vehicle were not performing any kind of official

duty, at all timcs rclcvant to this matter thcy actcd solely in an individual capacity, and did

commit Grand Theft in thc Sccond Dcgrce in violation ()f 171. Stat. 8 12.0 14( 1)(a), 8 12.014(1)

and 8 12.0 14(2)(b)( 1).

At thc timc of thc scizurc of thc Vchicle, it was lockcd, not in operation in any way.

and parked legally and lawfully on Privatc Property. in a Parking l-ot that was Ope,n -1-0 Thc

Public. Plaintiff w as outsidc the vchicle, ()n that sam c Publicly-open Privatc Property, w ith

the keys to the vehicle in his hand.

A t no tim e during the circum stances relevant to this m atter did the O wncr of that

l7ropcrty request thc rcm oval of that Vchicle from that Property.

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At no tim e during thc events rclevant to this m atter was the contact from Defendants

Sepot, Alvarez nor Fitzpatrick part of a dd-l-raffic Stop''. Neither Plaintiff nor thc Vchicle

wcrc ()n any Public lttladw ay, nor was the Vchicle bcing opcratcd thereupon.

23) Regardless, whilc Plaintiff was standing in a Public Placc, Deputy Alvarez assaulted

Plaintiff by running up ()n him , and battcrcd Plaintiff by grabbing his arm and forcing his

wrists into metallic physical restraints. Alvarez thcn unlawfully imprisoned Plaintiff by

forcing Plaintiff into the back of a police car which was locked and from which Plaintiff was

unablc to escape.

As a result of thc battery and unlawful imprisonlmcnt by Deputy Alvarez, Plaintiff

suffcred physical injury to his wrists, and thc nerves thcrcin, and loss ()f thc normal use of

his hands and fingers for no lcss than onc week afterward, and continucd dim inished usc of

thcm to the time ()f filing this complaint.

25) At the time thcsc cvcnts occurred, BCSO Defcndants Alvarez, Sepot, and Fitzpatrick

had no Probable Cause whatsocvcr to know nor believe that Plaintiff had com mitted any

crim e w hatsoever.

At al1 tilnes relcvant t() this m atter Plaintiff notificd D efcndants Scpot, A lvarez,

Fitzpatrick and Emerald Towing Agcnt, m ultiple tim cs that thc ltightful Owncr of thc

Vehiclc would rctricve thc vchicle via their own towing agcncy, and that the tclephone

number to contact that agency was on the Rental Contract locatcd in the vehiclc.

27) Upon being givcn such notice Defendants Alvarcz, Sepot, and Fitzpatrick all claimcd

that thcy do not obey The Constitution ()f The United Statcs ()f A m erica, nor any Statc nor

l'Cederal Law , and that thcy take persons vchicles w ith the aid of Em erald Tow ing when

28 aln-csting persons so that thcy can ultim atcly scll the vchiclcs at County Auction becausc

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pcople will be unable to pay the towing fec beeause it is exccssive, and likewise because

additional daily storage charges will accruc whilc thc vchicle owners are dctained in county

jail, and that they usc the procceds from these salcs t() pay thcir salarics.

28) Plaintiff has eausc to know and bclieve those claims arc true bccause according t() thc

Broward County Budget, no less than Eighty Perccnt of the proceeds collected by the

County are used to pay Personnel Costs. Judieial Notiee thereof is hcreby given.

Likewise upon being given notice multiple times that the Rightful Owncr of thc

Vchiclc would rctrieve it via their own towing agcncy, Defcndant Emerald Towing Agent

actcd with m alicc and Deliberate lndiffcrencc to this notice and did procecd to take thc

vehiclc, in violation of 171. Stat. 812.014(1)(a), 812.()14(l)(b), and 812.()14(2)(b)( 1). This

condklct was m aliee because as a rl-owing Agcnt, Defcndant Em crald 'l-owing Agent knows

and has eause to know that A utom obile Rental A geneies eontinually use Tow ing A gencies

such as Emcrald Towing to retricve and rctulm their propcl-ty, and bccausc it is a crim e in

violation of Florida State I-aw.

30) W hile Plaintiff w as unlawfutly imprisoned in thc police car, Deputics Fitzpatrick,

calling hil'n an iiasshole'' and other profane epithcts, and to t'sit'' like a dog.

Plaintiff notified them that such conduct was not any kind of Offieial Duty, but

regardless, they refused to stop. Dcputy F itzpatrick claim ed that bccause thcir ''Proccdural

M anttal'' supposedly stated that they m ay use profanity that sueh conduet w as pa14 of their

O fficial D uty.

Later w hile w aiting to bc released from thc Brow ard County detention faeility,

Ullknow n BCSO D eputy #2, who w as seated to D eputy l-aing's right, continued to claim

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1 that Plaintiff was a ttreal asshole'' bccausc he continued t() object to notify Dcputy Laing that

he w as not rcquired to answcr any qucstions in order to be rclcased.

Likewise at about that sam c tim e while Plaintiff' was notifying Laing that he w as not

requircd to answer her questions in order to bc releascd, and she continucd t() pester Plaintiff

to do so, at som e point Plaîntiff stated in rcsponsc to her qucstions'. ''1 don't fucking know''.

A t that point U nknow n BCSO D eputy #3 said: 'sl-ley, w atch your fucking m outhl''. H is tone

w as hostile and threatcning and com municated an intent to com mit an act of violcncc

against Plaintiff.

V . Cause ()f Action:

Count 1:

Unlawful Seizure, (Property), By Dcfendants Alvarez, Sepot, Fitzpatrick and Emerald

Tow ing Agent.

34) Facts stated supra in Section IV of this Complaint as thcy apply to this Count arc

incorporated by rcfcrcnce hercin.

Defendants named in this Count did unlawfully seize the Vchicle in question and hold

for an ever-incrcasing fee that Propcrty. D efendants w ere notified m ultiple tim es that the

renting agency was in full capacity to rcceive its own propcrty, and that thcir contact

inform ation was in the vehiclc. Thc vchicle was parked lcgally and lawfully, in thc parking

1ot of Privatc C om m crcial Propcrty that is O pcn -r0 The Public, and the vehiclc w as closed

and locked. The conduct of dcfendants chargcd in this Count constitutes M alicc becausc

Dcfcndants nam ed in this Count were all given Noticc m ultiplc tim cs that the Rightful

O w ner of the Vehicle w ould retrieve it prom ptly, and because it w as parked legally,

28 law fully, safcly and securely, and because they had no law ful authority of any kind to take

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that Property.

The conduct allcgcd against Dcfendants nam ed in this Count is a violation of

A m endm ent 1V , U nited States Constitution, 42 U .S.C , 1983, 18 U .S.C. 241, 242, FL, Stat

8 l 2.0 14(1)(a), 8 12.0 14( 1 )(b), and 8 12.0 14(2)(b)( 1), and Common Law.

Count 2:

Grand Theft, Second Degree By Dcfendants Alvarez, Sepot, Fitzpatrick and Emerald

'l-ow ing Agcnt.

Facts statcd supra in Section IV of this Complaint as thcy apply t() this Count are

incorporated by reference herein.

Count 1 supra is incorporated by rcfcrcnce as to thc allcgations in this Count. ln

addition to pleading a Civil Cause ()f A ction, supra, this Count alleges a Crim inal Com plaint

against thcse dcfcndants pursuant to 1 8 U.S.C. 24 1, 242. and FL. Stat 8 12.0 14( 1)(a),

8 l2.()14(1)(b), and 812.014(2)(b)(l), for the same acts alleged in Count 1.

C oun t 3:

l7a1sc Imprisonment / Unlawful Scizurc (Pcl'son), by Defcndant Laing and Unknown BCSO

Ilcputy #1 .

39) Facts statcd supra in Scction IV of this Complaint as they apply to this Count arc

incorporated by refcrcnce herein.

40) Upon being bookcd into thc Broward County Jail Plaintiff had a pre-set bond amount

()f $ 100, and was ordcred by a magistrate to be released im mediately upon paym ent of that

28 bond. Plaintiff had those funds available for paym cnt im m ediately. A n unknow n sheriffs

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dcputy, (Unknown BCSO Deputy #1), refuscd to releasc Plaintiff nor inform him of that

bond bccause Plaintiff informcd her that hc had n() fixed residcncc address, and that the

addrcss that was provided to them by the arresting officer was incorrcct. Upon appcaring

beforc a m agistratc the following morning Plaintiff was ordcrcd relcascd on his own

recognizance, At that timc Plaintiff was free to go. Llowcvcr, Plaintiff was kcpt incarccrated

until later that cvcning. (morc than 12 hours), and at such time as jail staff bcgan proccssing

his relcasc. dcputy Laing refused to release Plaintiff unless Plaintiff answcred num erous

questions including revealing private information, (Social Sccurity Number, Address), and

what Plaintiff was charged w ith. Plaintiff at that moment could not rccall exactly what thc

charges against him werc, but eventually after his clothing and other property was returncd

to him , hc produccd thc printcd charging docum ents that were issucd to him by the arresting

officer, and showed thcm t() Deputy Laing. Rcgardless, D cputy Laing rcfuscd t() accept that

information, and statcd that shc would not relcasc Plaintiff until he vcrbally answcrcd her

and statcd to her what the charges wcrc. Plaintiff inform cd Dcputy Laing that it was thc

states duty to inform a person of the charges not vice versa. D cputy Laing then inform ed

Plaintiff that hc wotlld not be releascd until such time as he providcd the information. and

that he would be rcturned to a cell and continued to be held in the jail tlntil such time as hc

did. Deputy Laing claim cd that because they had errantly rclcased detainccs in the past that

Plaintiff was required to identify him sclf to them by providing that and other privatc

information, (Social Security Number, Address) and would not be rclcased until he did. 'l-he

conduct alleged in this Count against Dcputy Laing is in violation ()f The U.S. Constitution.

C oun t 4 :

V iolation of ltight to Privacy / ltigllt -1-0 ltem ain Silent by Deputy Laing.

Count 2 supra is incorporated by refcrcnce as to the facts m atcrial to this Count.

28

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42) Plaintifps Right To Rem ain Silent is ultim ately a Privacy Right. Plaintiff is not

requircd to answer any questions from any state officcr for any reason. Plaintiff is not

required to provide his Social Security N um ber nor any other Private nor Personal

information to any state officer for any rcason. Bccause Plaintiff was free to go at thc timc,

Deputy Laing ultim ately wrongfully arrested and falsely imprisoned Plaintiff for exercising

his Right To Remain Silent, and his Right to Privacy in violation of The U.S. Constitution,

Count 5:

H arassm ent by D efendants A lvarcz, Fitzpatrick, Sepot, Unknow n BCSO Dcputy #2, and

Unknown BCSO Dcputy #3

43) The course of conduct by Fitzpatrick, Alvarcz, Sepot and Unknown BCSO Deputy #2,

describcd supra, and incorporated by reference in this Count, of them calling Plaintiff an

iiasshole'' and other profanc epithets and personal insults, and doing so continually after

being told to stop, was not any kind of Official Duty, and served no legitimate purpose

whatsocvcr. It was purely for t'he purpose of sadistic abuse, and in fact was thc most pathctic

display of dcgcnerate anal-sadism that Plaintiff has cver witncssed. That course of conduct

causcd Plaintiff substantial Emotional D istress in thc form of Outrage, Fury and Adequate

Provocation.

Fitzpatrick's elaim that such conduct w as O ffieial D uty bccause their dsprocedural

M anual'' claim ed it was allowcd is both errant and moronic, Uttering profane or vilc tcrm s

like ttshit'' or Eifuck'' or çépolice officer'' to exprcss frustration, or perhaps dislike of a

pal-ticular circum stancc, m ay not be l'Iarassm ent. I-low ever, w hen profanc epithets and

personal insults are directed toward a specific pcrson, 01* spoken about a particular person for

them to hear, and claim ed about their person or character i14 thcir prescnce, that is

28 Harassment in violation of FL. Stat. j' 784,048, and is a crimc under Florida Law, and

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1

28

I

tortious under Comm on Law.

45) The conduct of Unknown BCSO Dcputy #3 described supra and incorporated by

reference in this Count was not any kind of Official Duty, and did not serve any legitim ate

purpose. No law cnforcem cnt officcr has any authority of any kind to tell any person to

speak or not to speak, nor how to speak. A s such that conduct was Harassment in violation

of FL. Stat. q 784.048, and is a crime under Florida Law, and tortious undcr Common Law.

46) The conduct alleged in this Count against Defcndants Alvarez, Sepot, Fitzpatrick,

Unknown BCSO Dcputy #2 and Unknown BCSO Deputy #3, arc furthcr a violation of

FDLE 'tLE Ethical Standards of Conduct'' Rules 1. 1, 5.1, 5.2, and Principle Five. Judicial

Noticc thereof is hereby given.

47) Al1 conduct charged in this Count is adcquate provocation and as such was an

intcntional infliction of em otional distress, and bccause Plaintiff would have received a

felony charge for hitting these punks, Plaintiff was stuck with having to listen t() their shit,

and not bcing ablc to punch them in their mouth for it, and as such suffered cmotional

0 i hl t1*0 S S . 

)

Count 6: 

Violation of Right To Free Speech by Unknown BCSO Dcputy #3. t

' 48) At a11 times persons have a Right To Frce Spccch plotectcd by The U.S. Constitution. 

L

2 49) No governm ent officcr of any kind has any authority t() order any person to speak 

, or 

not to speak, nor how to spcak, now what to say, nor to refrain from any statcm cnt. j

'

t

50) Because violation of a Person's Right To Free Speech for any length of time '

j'

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constitutes lrreparable Harm , and because Unknown BCSO Deputy #3 attempted to threaten

and intim idate Plaintiff from excrcising his Right To Free Speech, the conduct of Unknown

BCSO Deputy #3 as described in Section IV supra is in violation of Plaintiffs Right to Free

Speech as protected by thc United States Constitution, 42 U.S.C. 1983, and 18 U.S.C. j 242.

VI. Claim s of Liability:

5l) For all Counts supra, each Defendant is liable individually and in their corporate,

Official or quasi-governmental capacity for the conduct alleged in each Count because that

eonduct is in violation of the laws stated in eaeh Count.

For a1l Counts supra, Dcfendant Gregory Tony is l-iable in his Official Capacity per

42 U.S.C. j 1986, as supervising offieer for the conduct of all BCSO Defendants and all

quasi-govem mental Defendants acting in participation with the Brow ard County Sherift's

Office, and for failure to train thesc partics not to eom mit the eondttet alleged, and for

failure to propcrly supervise thcse parties to prevent the conduct comm itted by these parties,

53) For a1l counts supra, Broward County Florida is liable as Respondeat Supcrior for thc

eonduct of all Defendants nam ed herein.

54)

official conduct of Broward County Sheriff Gregory Tony.

As a party named hcrein, Defendant Gregory Tony is liablc individtlally for the

55) For a1l Counts alleged supra, the eonduct of all Defendants is in violation of Plaintiff's

Peace and D ignity, Thc Peace and D ignity of thc Peoplc of Broward County, The Peace and

D ignity of the People of The State of Florida, and the Peace and D ignity of the U nited States

28 of A m erica, its C itizens, and occupants.

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1 VlI. ltel ief ltequested :

56) Twenty Thousand Dollars ($20,000) compensatory damages for the Falsc

lm prisonm cnt claim s.

57) One Thousand Dollars ($1.000) Compcnsatory Damages for the ttnlawful seizurc of

Plaintiffs Vehicle, and Plaintifps tim c, effol't and expenses incurred thcrefrom .

58) Fifty Thousand Dollars ($50,000) Compensatory Damages for Plaintiff's Timc And

Effort to pursue this complaint to any Summary Judgment. Settlement Conference. or Jury

'l-rial .

59) One Hundred Thousand Dollars ($100.000) Compcnsatory Damages for pain and

suffcring and physical injury suffered by Plaintiff, and inflictcd upon him by Defendants.

60) One Hundred Thousand Dollars ($100,000) Compensatory Damages for Emotional

Distress infticted upon Plaintiff by Dcfendants.

61) One Hundred M illion Dollars ($ 100,000,000) Punitive Damages upon all Defendants

for the delibcrate, sadistic, and crim inally unlawful conduct com mitted by Defendants, and

for thc purpose of perm anently prohibiting any furthcr such conduct by them .

62) Permanent lnjunction ordering A1l BCSO Defendants to resign their employment as

state officers for-profit, and to never again pursue nor accept any kind of public office forprofit of any kind.

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1 V11I. Pre-Em ptivtt Settlem ent O ffer:

63) Ten Thousand Dollars, ($10,000), to settlc ALL Civil Claims allcged herein and ANY

OTHERS that may accrue from thc circumstances attendant to this Complaint. including any

subsequent False lm prisonment elaim s that m ay arise for the time between arfest and courtordered release, that may arise from acquittal or dismissal of the state crim inal charges

against Plaintiff. This offer expires perm anently upon the filing of any D ispositive or

Responsive Pleading by Defcndants. Thc purpose of this Offer is to direct funds that would

be used to pay attorneys to defend this matter toward an im m ediatc settlement without

litigation, and for lcss cost than such litigation. Because any attorncy who needlessly

dcfends a com plaint w hen it can be settled for less than the cost of sueh a defense is bilking

their elient, sueh needless litigation eonstitutes Attonncy M alpractice. Bccause the Clients in

this case are all Public or quasi-public entities, failure to pursue pre-litigative settlement

with the intent of obtaining revenue from that eonduet eonstitutes misuse or

m isappropriation of public fundsand resourees. As such, Plaintiff consents in advancc to

additional leave being grantcd to Defendants by the Court so that they may pursue prelitigative scttlem cnt without being requircd 13y tim e constraints to file Responsive Pleadings.

Subm itted to the Court, This 22 June, 2020.

11 Au

li

M r. Piero A. Bugoni. Plaintiff Pro - Se

This Com plaint constitutes a Crim inal Complaint against Defendants subscribed and sworn

to by Plaintiff, Piero Bugoni, ldentified by State ldcntification, this1î-l oay of

id't'''- 2020 5 , before al'. ( ô-svrtefcx.--

a N otary of the Statc of Florida.

%,= WY PtS$+ JOHN LAWXENCE $% '.T ExplREs: August 02, 2023 *ècvs.cmMY COMMISSION #œ340165

Pagc 14 of 14

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ropo Zu&zmw

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