IN THE UNITED STATES DISTRICT COURT
 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
 

DAMEKABEY 

6138 Chew Avenue 

Philadelphia, PA 19138 

and 

ACQUANOBEY 

6138 Chew Avenue 

Philadelphia, PA 19138 

and 

ALlYAH MUHAMMAD, a minor, 

by DAMEKA BEY, her guardian 

613 8 Chew Avenue 

Philadelphia, PA 19138 

and 

AMEERAH MUHAMMAD, a minor, 

by DAMEKA BEY, her guardian 

6138 Chew Avenue 

Philadelphia, PA 19138 

Plaintiffs 

v. 

CITY OF PHILADELPHIA 

Department of Human Services and 

Philadelphia Police Department 

1515 Arch Street 

Philadelphia, PA 19102 

and 

ALBA E. MARTINEZ, in her capacity 

as Commissioner of DHS 

Department of Human Services 

1515 Arch Street 

Philadelphia, PA 19102 

and 

KRISTEN SHATZS, individually and in: 

her capacity as Social Work Supervisor 

Department of Human Services 

1515 Arch Street 

Civil Action No.05-CY-686 

Jury Trial Requested 

Philadelphia, PA 19102 

/

/ "..",

/. 

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and 

NORMA BRlGGS, individually and in 

her capacity as Social Worker 

Department of Human Services 

1515 Arch Street 

Philadelphia, PA 19102 

and 

ETTA FIELDS, individually and in her 

capacity as Social Worker 

Department of Human Services 

1515 Arch Street 

Philadelphia, PA 19102 

and 

JEFFREY JEWS 

2810 Poplar Street 

Philadelphia, PA 19130 

and 

PIO BYRNE (previously identified as 

PIO Bryan) BADGE No. 3150, 

14th District, individually and his 

capacity as a Police Officer 

Philadelphia Police Department 

1515 Arch Street 

Philadelphia, PA 19102 

and 

PIO LANDHERR (previously identified: 

as PIO Land) BADGE No. 3083 

14th District, individually and his 

capacity as a Police Officer 

Philadelphia Police Department 

1515 Arch Street 

Philadelphia, PA 19102 

and 

SGT. JOHN DOE, BADGE No. 8500 

14th District, individually and his 

capacity as a Police Officer 

Philadelphia Police Department 

1515 Arch Street 

Philadelphia, PA 19102 

Defendants 

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AMENDED COMPLAINT 

I. INTRODUCTION 

1. This is a civil rights action brought by the plaintiffs, Dameka Bey, 

Acquano Bey, Aliyah Muhammad, a.ld Ameerah Muhammad under the, Civil Rights Act 

of 1866,42 U.S.C § 1983. Plaintiffs seek injunctive and declaratory relief, damages and 

attorney's fees to redress their claims. 

II. JURISDICTION AND VENUE 

2. The Jurisdiction of this Court is invoked pursuant to 28 U.S.C Section 

1331 and 42 U.S.C Sections 1983. Venue is based on 28 U.S.C. Section 1391(b). 

Plaintiff also invokes the pendent jurisdiction of this Court to hear and decide claims 

arising under the laws of the Commonwealth of Pennsylvania. 

III. PARTIES 

3. Plaintiffs, Dameka Bey, Acquano Bey, Aliyah Muhammad, and Ameerah 

Muhammad are citizens of the United States and reside at 6138 Chew Avenue, 

Philadelphia, Pennsylvania. Dameka Bey and Acquano Bey are husband and wife. Aliyah 

and Ameerah Muhammad are minors. Dameka Bey is the biological mother of Aliyah 

and Ameerah. 

4. Defendant, City of PhiJadelphia, is a municipal corporation, organized and 

existing under the laws of the Commonwealth of Pennsylvania and is a person within the 

meaning of 42 U.S.c. § 1983 of the United States Code. 

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5. Defendant, Alba Martinez, is and was at all times relevant to this action the 

Commissioner of the Philadelphia Department of Human Services (hereinafter DHS), and 

was at all times relevant to this action an authorized policy maker for the defendant, City 

of Philadelphia. 

6. Defendant, Kristen Shatz was at all times relevant to this action a supervisor 

for the Philadelphia Department of Human Services and was acting as an agent, servant, 

and/or employee of the defendant, City of Philadelphia. 

7. Defendant, Norma Briggs was at all times relevant to this action a social 

worker for the Philadelphia Department of Human Services and was acting as an agent, 

servant and/or employee of the defendant, City of Philadelphia. 

8. Defendant, Etta Fields was at all times relevant to this action a social 

worker for the Philadelphia Department of Human Services and was acting as an agent, 

servant and/or employee of the defendant, City of Philadelphia. 

9. Defendant, Jeffrey Jews, is a citizen of the United States and resides at 2810 

Poplar Street, Philadelphia, Pennsylvania. He is the biological father of Aliyah and 

Ameerah Muhammad. 

10. Defendant, Sergeant John Doe, Badge No. 8500, was at all times 

relevant to this action a supervisor for the Philadelphia Police Department and was acting 

as an agent, servant, and/or employee of the defendant, City of Philadelphia. 

11. Defendants, Officers Byme, Badge No. 3150 and Landherr, Badge No. 

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3083 were at all times relevant to this action police officers of the Philadelphia Police 

Department, and were acting as agents, servants and employees of the defendant, City of 

Philadelphia. 

12. Plaintiff sues each and all municipal defendants in both their individual and 

official capacities. 

IV. FACTUAL ALLEGATIONS 

13. The averments set forth in all preceding paragraphs, inclusive, are 

incorporated herein by reference. 

14. On or about November 8,2002, the Honorable Myrna P. Field granted 

plaintiff, Dameka Bey, primary physical custody of her two children, plaintiffs Aliyah and 

Ameerah Muhammed. 

15. The November 8, 2002 custody order also granted visitation rights to 

defendant, Jeffrey Jews. 

16. The relationship between Mrs. Bey and Mr. Jews has been contentious since 

before Aliyah and Ameerah were born. 

17. Mr. Jews has a criminal record for physically abusing Mrs. Bey during their 

marriage and has a history of abuse against a female sibling. 

18. Pursuant to the custody order, Mrs. Bey delivered Aliyah and Ameerah to 

Mr. Jews on July 26, 2003 for their weekend visit. 

19. On July 27, 2003, Mrs. Bey was notified that Mr. Jews had called the 14th 

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police district and reported that Aliyah had been abused by her stepfather, plaintiff 

Acquano Bey. 

20. Mrs. Bey was subsequently informed by defendant, OHS, worker Norma 

Briggs that an investigation into the allegations of abuse would have to be done and that 

the children would have to remain with Mr. Jews. 

21. OHS employee Norma Briggs made the decision to allow Aliyah and 

Ameerah to remain with Mr. Jews without conducting an investigation of Mr. Jews and 

his home. 

22. OHS employee Norma Briggs allowed Aliyah and Ameerah to remain with 

Mr. Jews without ascertaining the whereabouts ofMr. Jews' brother who had sexually 

abused Aliyah when she was four years old. 

23. OHS employee Norma Briggs and/or employees ofOHS also made the 

decision to allow Aliyah and Ameerah to remain with Mr. Jews notwithstanding Judge 

Field's court order granting custody to Mrs. Bey. 

24. OHS failed to consider Mr. Jews' conduct regarding his sexual abuse of his 

female sibling before terminating Mrs. Bey's parental rights and giving custody of Aliyah 

and Ameerah to him. 

25. OHS failed to ascertain that defendant, Mr. Jews had not been making child 

support payments for Aliyah and Ameerah before taking them from Mrs. Bey and placing 

them with Mr. Jews. 

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26. Between July 27, 2003 and October 1, 2003, DHS also failed to seek a court 

order terminating or modifYing Mrs. Bey's parental rights or Judge Field's cOUl1 order. 

27. On or about July 28, 2003, the case of alleged abuse of Aliyah and Ameerah 

was assigned to defendant and supervisor, Christian Shatzs who subsequently assigned 

the case to defendant, Etta Fields. 

28. On July 28, 2003, defendant Fields, notified Mrs. Bey that Aliyah and 

Ameerah would be staying with Mr. Jews until Ms. Fields completed her investigation 

which could take two weeks to a month. 

29. Despite placing Aliyah and Ameerah with the defendant, Jeffrey Jews, 

defendant, Etta Fields failed to conduct and investigation into the background of Jeffrey 

Jews. 

30. Despite placing Aliyah and Ameerah with the defendant, Jeffrey Jews, Ms. 

Fields failed to conduct and investigation into the background of Jeffrey Jews' brother 

who had previously sexually abused Aliyah. 

31. Notwithstanding the taking of Aliyah and Arneerah from their mother and 

placing them with the defendant, Jeffrey Jews, defendant Shatzs and Fields failed to 

obtain a voluntary placement agreement; a restraining order; and/or any other cOUl1 order 

authorizing suspension of Mrs. Bey's parental rights and placement with defendant, 

Jeffrey Jews. 

32. After taking Aliyah and Arneerah from their mother and placing them with 

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the defendant, Jeffrey Jews, defendant Shatzs and Fields failed to ascertain that 

defendant, Jeffrey Jews had not been making child support payments for Aliyah and 

Ameerah. 

33. At no time while Aliyah and Ameerah were in the custody of defendant, 

Jeffrey Jews due to the DHS placement did DHS file a petition with the Court of 

Common Pleas to determine if the allegations of abuse were true and that protective 

custody was needed. 

34. Due to Ms. Shatzs and Ms. Fields' refusal to allow Ms. Bey to see her 

children Aliyah and Ameerah, Mr. and Mrs. Bey retained legal representation. 

35. On or about August 21, 2003, Mrs. Bey was informed by her counsel that 

no court orders had been issued authorizing DHS to take her children and tum them over 

to defendant, Jews, therefore, she was entitled to have her children. 

36. On or about August 21, 2003, Mrs. Bey went with a police officer to the 

home of defendant, Jeffrey Jews and retrieved Aliyah and Ameerah. 

37. On the evening of August 21, 2003, defendant Jeffrey Jews along with 

defendants, PIO Byrne, PIO Landhen# 3083 and Sergeant John Doe# 8500 went to the 

home of Mrs. Bey and based on a letter written and signed by defendant, Etta Fields, 

entered the home and took Aliyah ard Ameerah from their mother, Mrs. Bey. (See 

Exhibit I). 

38. When Mrs. Bey showed the officers her custody order they indicated that 

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they were aware of Judge Field's court order but the DHS letter from defendant, Etta 

Fields ovenode Judge Field's court order. 

39. In September, 2003, Mrs. Bey with the assistance of counsel petitioned 

Philadelphia Common Pleas Court which allowed her to retrieve Aliyah and Arneerah 

from defendant, Jews. 

40. Despite the court ruling defendant, DHS continued to seek access to Mrs. 

Bey's home to allegedly conduct an ;:J.vestigation. 

41. At another court hearing held in October, 2003, it was ruled that defendant 

DHS did not have any evidence of abuse against Mr. and Mrs. Bey. 

42. Despite the court hearings regarding the matter of alleged abuse, defendant, 

DHS continued to seek admission to Mr. and Mrs. Bey's home to conduct an 

investigation and place some type of social service assistance in the Bey home. 

43. No court ever ruled that Mr. and Mrs. Bey or their children were in need of 

any home services provided by DHS. 

44. Notwithstanding the court ruling, defendant, DHS advised the 

Commonwealth of Pennsylvania's Department of Public Welfare that Mr. and/or Mrs. 

Bey had abused Aliyah. 

45. After receiving the report of abuse from DHS, the Commonwealth of 

Pennsylvania issued what is known as an "indication" which means that Mr. and Mrs. 

Bey were listed as perpetrators of child abuse. This status was to remain for a period of 

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23 years from Aliyah' s date of birth. 

46. Mr. and Mrs. Bey appealed the Report of Indication of Child Abuse and on 

August 3 1, 2004, it was ordered that the indicated report of child abuse be expunged. 

COUNT I
 

Dameka Bey v. City of Philadelphia (DHS)
 

(42 U.S.C.§1983 - Due Process)
 

47. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

though fully set forth below. 

48. At all times relevant hereto, plaintiff, Dameka Bey was the custodial parent 

of Aliyah and Ameerah Muhammad pursuant to a court order issued by Judge Myrna P. 

Field. 

49. Due to unsubstantiated charges of abuse, defendant City of Philadelphia, 

placed Aliyah and Ameerah in the custody of their biological father, defendant Jeffrey 

Jews. 

50. Between July 28,2003 and October 2003, defendant, City of Philadelphia 

failed to seek a hearing regarding the charges of abuse and the suspension of Mrs. Bey's 

parental rights. 

51. The defendant, City of Philadelphia's taking of Mrs. Bey's daughters and 

the failure to provide a hearing violated the due process clause of the 14th Amendment of 

the federal constitution. 

52. By interfering with the parent and child relationship the City of Philadelphia 

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violated the 14th Amendment of the federal constitution's substantive due process rights of 

Mrs. Bey. 

53. By taking and keeping Aliyah and Ameerah from Mrs. Bey without having 

a hearing where she could be heard violated her procedural due process rights. 

54. Defendant, City of Philadelphia, engaged in a practice of failing to train and 

supervise its employees in the constitutional rights of the citizens it serves. 

55. Defendant, City of Philadelphia's employees, servants and or agents 

treatment of Mrs. Bey and their ignoring Judge Field's court order demonstrated a pattern 

of deliberate indifference to the rights of Mrs. Bey. 

56. Due to defendant, City of Philadelphia's conduct, plaintiff has suffered 

extreme anguish and humiliation causing her to seek and receive medical treatment. 

Plaintiff has also had to procure the services of counsel and miss work as a result of 

defendant's conduct. 

WHEREFORE, Plaintiff, Dameka Bey requests judgment in her favor and 

against the City of Philadelphia for compensatory damages in excess of One 

Hundred Thousand Dollars. 

COUNT II
 

Dameka Bey v. Alba E. Martinez
 

(42 U.S.C.§1983)
 

57. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

though fully set forth below. 

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58. As commissioner of DHS, defendant Martinez knows, knew or should have 

known that her employees, agents, or servants were not trained or supervised in the 

constitutional rights of the citizens her agency serves. 

59. Moreover, defendant Martinez knew or should have known that the 

constitutional rights of Dameka Bey were being violated by her employees and 

acquiesced in their conduct. 

WHEREFORE, Plaintiff, Dameka Bey requests judgment in her favor and 

against defendant, Alba E. Martinez for compensatory damages in excess of One 

Hundred Thousand Dollars. 

COUNT III
 

Dameka Bey v. Kristen Shatzs
 

(42 U.S.C.§1983)
 

60. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

though fully set forth below. 

61. At all times relevant to this action, defendant Shatzs was a DHS supervisor 

and was actively involved in the taking of Mrs. Bey's daughters and the failure to provide 

her with a hearing. 

62. Ms. Shatzs ignored court orders regarding the custodial rights of Ms. Bey 

and allowed her subordinate, Etta Fields, to do the same. 

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WHEREFORE, Plaintiff, Dameka Bey requests judgment in her favor and 

against defendant, Kristen Shatzs for compensatory damages in excess of One 

Hundred Thousand Dollars. 

COUNT IV
 

Dameka Bey v. Norma Briggs and Etta Fields
 

(42 U.S.C.§1983)
 

63. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

fully set forth below. 

64. Defendants, Briggs and Fields knew or should have known that their 

actions of taking Aliyah and Ameerah from their mother, who had a valid court order 

granting her primary custody, was a violation of Mrs. Bey's federal constitutional rights. 

65. Defendants, Briggs and Fields knew or should have known that their 

actions of not providing Mrs. Bey with a hearing either before or more than sixty days 

after the taking of her daughters was a violation of established federal constitutional 

rights. 

WHEREFORE, Plaintiff, Dameka Bey requests judgment in her favor and 

against defendants, Norma Briggs and Etta Fields for compensatory damages in 

excess of One Hundred Thousand Dollars. 

COUNT V
 

Dameka and Acquano Bey v. City of Philadelphia
 

(42 U.S.C.§ 1983 - Fourth Amendment)
 

66. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

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though fully set forth below. 

67. Police Officers Byrne, Landherr and Sgt. John Doe did enter the home of 

Dameka and Acquano Bey on August 21,2003, without a warrant and without probable 

cause. 

68. The officers were aware of the court order granting custody to Mrs. Bey but 

believed the letter from defendant, Etta Fields abrogated it. 

69. The officers removed Aliyah and Ameerah from their home and mother. 

70. The officers knew or should have known that a letter from a social worker 

does not repeal a court order. 

71. The officers' conduct resulted from Defendant, City of Philadelphia 

engaging in a pattern, practice, and/or custom of failing to train and supervise its officers 

in searches and seizure in child welfare cases. 

WHEREFORE, Plaintiff, Dameka Bey requests judgment in her favor and 

against defendant, City of Philadelphia for compensatory damages in excess of One 

Hundred Thousand Dollars. 

COUNT VI
 

Dameka and Acquano Bey v. PIO Byrne, PIO Landherr and Sgt. John Doe
 

(42 U.S.C.§ 1983 - Fourth Amendment)
 

72. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

though fully set forth below. 

73. Officers Byrne, Landherr, and Sgt. John Doe, entered the home of Dameka 

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and Acquano Bey on August 21,2003, without a warrant or probable cause. 

74. The officers entered the home for the purpose of taking Aliyah and 

Ameerah from their mother, Mrs. Bey and placing them with their father Jeffrey Jews. 

75. The officers were aware that Mrs. Bey had a court order granting her 

primary custody of Aliyah and Ameerah. 

76. Defendant police officers were also aware of a letter from DHS worker Etta 

Fields stating that the father was to have custody pending an investigation. 

77. Defendant police officers saw no evidence that Mr. and Mrs. Bey were 

committing a crime. 

78. Defendant police officers knew or should have known that the entering of 

the home of Mr. and Mrs. Bey without a warrant or probable cause was a violation of 

clearly established constitutional rights. 

WHEREFORE, Plaintiff, Dameka Bey requests judgment in her favor and 

against defendants, PIO Byrne, PIO Landherr and Sgt. John Doe for compensatory 

damages in excess of One Hundred Thousand Dollars. 

COUNT VII
 

Aliyah and Ameerah Muhammad v. City of Philadelphia
 

(42 U.S.C.§ 1983 - Due Process)
 

79. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

though fully set forth below. 

80. At all times relevant hereto, plaintiffs, Aliyah and Ameerah Muhammad 

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were the biological daughters of Dameka Bey who was also their custodial parent 

pursuant to a court order issued by Judge Myrna P. Field. 

81. Due to unsubstantiated charges of abuse, defendant City of Philadelphia, 

placed Aliyah and Ameerah in the custody of their biological father, defendant Jeffrey 

Jews. 

82. Between July 28, 2003 and October 2003, defendant, City of Philadelphia 

failed to seek a hearing regarding the charges of abuse and the suspension of Mrs. Bey's 

parental rights. 

83. The defendant, City of Philadelphia's taking of plaintiffs and the failure to 

provide a hearing violated the due process clause ofthe 14th Amendment of the federal 

constitution. 

84. By interfering with the parent and child relationship the City of Philadelphia 

violated thel4th Amendment of the federal constitution substantive due process rights of 

Aliyah and Ameerah. 

85. By taking and keeping Aliyah and Ameerah from their mother without 

having a hearing violated their procedural due process rights. 

86. Defendant, City of Philadelphia, engaged in a practice of failing to train and 

supervise its employees in the constitutional rights of the citizens it services. 

87. Defendant, City of Philadelphia's employees, servants and or agents 

treatment of Aliyah and Ameerah an,l their ignoring Judge Field's comi order 

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demonstrated a pattern of deliberate indifference to their rights. 

88. Due to defendant, City of Philadelphia's conduct, plaintiffs have suffered 

extreme anguish and humiliation causing them to seek and receive medical treatment. 

WHEREFORE, Plaintiffs, Aliyah and Ameerah Muhammad requests 

judgment in their favor and against the City of Philadelphia for compensatory 

damages in excess of One Hundred Thousand Dollars. 

COUNT VIII
 

Aliyah and Ameerah Muhammad v. Shatzs, Fields and Briggs
 

(42 U.S.C.§ 1983 - Due Process)
 

89. Plaintiffs aver and inco.'-porate by reference all the preceding paragraphs as 

though fully set forth below. 

90. Defendants, Shatzs, Briggs, and Fields knew or should have known that 

their actions of taking Aliyah and Ameerah from their mother, who had a valid court 

order granting her primary custody, interfered with plaintiffs' right to be with their 

mother which is a violation of plaintiffs' clearly established federal constitutional rights. 

91. Defendants, Shatzs, Briggs, and Fields knew or should have known that 

their actions of not providing plaint{;s' mother with a hearing either before or more than 

sixty days after the taking was a violation of plaintiffs' clearly established federal 

constitutional rights. 

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WHEREFORE, Plaintiffs, Aliyah and Ameerah Muhammad request 

judgment in their favor and against defendants, Kristen Shatzs, Norma Briggs, and 

Etta Fields for compensatory damages in excess of One Hundred Thousand Dollars. 

COUNT IX
 

All PI;,jntiffs v. Jeffrey Jews
 

Abuse of Process
 

92. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

though fully set forth below. 

93. Defendant, Jeffrey Jews made an unfounded charge of child abuse against 

plaintiffs, Demeka Bey, his former wife, and Acquano Bey. 

94. The charge of child abuse was made by Mr. Jews to defendant, DHS which 

precipitated court proceedings. 

95. Upon information and belief it is averred that Mr. Jews made this 

accusation for the purpose of obtaining custody of Aliyah and Ameerah which would 

increase his welfare payments and eliminate his support payments. 

WHEREFORE, All plaintiffs request judgment in their favor and against 

defendant, Jeffrey Jews for compensatory damages in excess of One Hundred 

Thousand Dollars. 

COUNT X
 

Dameka and A<:quano Bey vs. All Defendants
 

Intentional Infliction of Emotional Distress
 

96. Plaintiffs aver and incorporate by reference all the preceding paragraphs as 

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though fully set forth below. 

97. Defendants knew or should have known that their deliberate action of taking 

Aliyah and Ameerah from their mother, interfered with plaintiff mother's right to be with her 

children and deprived plaintiff of her right to be with her children causing severe emotional 

distress to Plaintiff. 

98. Defendants deliberate action of taking Aliyah and Ameerah from their mother, 

interfering with plaintiff mother's right to be with her children and depriving plaintiff of her right 

to be with her children was a substantial factor in causing the severe emotional distress suffered 

by Plaintiff. 

99. As a direct and proximate result of the defendants' actions Plaintiff suffered 

severe emotional distress and suffered mental reactions including but not limited to fright, 

anxiety, grief, shame, humiliation, embarrassment, and worry. 

100. As a direct and proximate result of the conduct of defendants, Plaintiff was caused 

to suffer emotional distress and has in the past required and may in the future require medical 

care and treatment, and may in the future continue to incur costs of medical treatment and 

counseling 

101. As a direct and proximate result of the defendants' actions Plaintiff has in the past 

underwent great emotional anguish and may in the future continue to suffer mental anguish, 

humiliation and embarrassment. 

WHEREFORE, Plaintiffs, Dameka and Acquano Bey request judgment in their 

favor and against all defendants, for compensatory damages in excess of One Hundred 

Thousand Dollars. 

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COUNT XI
 

Aliyah and Ameerah Bey vs. All Defendants
 

Intentional Infliction of Emotional Distress
 

102. Plaintiffs aver and incorporate by reference all the preceding paragraphs as though 

fully set forth below. 

103. Defendants knew or should have known that their deliberate action of taking 

Aliyah and Ameerah from their mother, interfered with their right to be with their mother and 

deprived plaintiffs of their familia right to be with their mother causing severe emotional distress 

to Plaintiffs. 

104. Defendants deliberate action of taking Aliyah and Ameerah from their mother, 

interfering with their right to be with her and depriving plaintiffs of their right to be with their 

mother was a substantial factor in causing the severe emotional distress suffered by Plaintiffs. 

105. As a direct and proximate result of the defendants' actions Aliyah and Ameerah 

suffered severe emotional distress and suffered mental reactions induding but not limited to 

fright, anxiety, grief, shame, humiliation, embarrassment, and worry. 

106. As a direct and proximate result of the conduct of defendants, Plaintiff s were 

caused to suffer emotional distress and has in the past required and may in the future require 

medical care and treatment, and may in the future continue to incur costs of medical treatment 

and counseling. 

107. As a direct and proximab-: result of the defendants' actions Plaintiffs have in the 

past underwent great emotional anguish and may in the future continue to suffer mental anguish, 

humiliation and embarrassment. 

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WHEREFORE, Plaintiffs, Aliyah and Ameerah Bey request judgment in their favor 

and against all defendants, for compensatory damages in excess of One Hundred Thousand 

Dollars. 

BY~~3Z~ Kenneth S. Robinson, Esquire 

~tJ~

Date: ~<J ,2005

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